OECD Crypto-Asset Reporting Framework (CARF)

1. Overview & Mandate

The Crypto-Asset Reporting Framework (CARF) is a global tax transparency standard developed by the Organisation for Economic Co-operation and Development (OECD) to enable the automatic exchange of tax-relevant information on crypto-asset transactions between jurisdictions. CARF was finalized in June 2023 as part of the publication "International Standards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and Amendments to the Common Reporting Standard".

CARF was developed at the request of the G20, which recognized that existing tax transparency frameworks -- particularly the Common Reporting Standard (CRS) -- did not adequately cover crypto-assets. The framework is administered by the Global Forum on Transparency and Exchange of Information for Tax Purposes, which oversees implementation and monitors compliance across participating jurisdictions.

The core objective of CARF is to close the tax transparency gap created by crypto-assets, which can be transferred and held without traditional financial intermediaries, enabling potential tax evasion across borders.

Key Document Reference:

• OECD (2023), International Standards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and Amendments to the Common Reporting Standard, OECD, Paris.
• Source: https://www.oecd.org/en/about/news/announcements/2024/10/crypto-asset-reporting-framework-and-amended-common-reporting-standard-oecd-releases-it-format-for-transmitting-information-and-issues-interpretative-guidance.html

2. Key Publications & Guidance

3. Framework Details

3.1 Structure

The CARF model rules are organized into four sections:

1. Section I: Obligations of Reporting Crypto-Asset Service Providers -- defines who must report
2. Section II: Reporting Requirements -- specifies what information must be reported
3. Section III: Due Diligence Procedures -- sets out customer identification rules
4. Section IV: Defined Terms -- provides precise definitions for all key terms

Source: https://www.careyolsen.com/insights/briefings/introducing-carf-oecds-crypto-asset-reporting-framework

3.2 Reporting Entities (RCASPs)

A Reporting Crypto-Asset Service Provider (RCASP) is defined as any individual or entity that, as a business, provides a service effectuating exchange transactions for or on behalf of customers. This includes:

• Centralized exchanges -- acting as broker or market maker
• Brokers and dealers of crypto-assets
• Operators of crypto-asset ATMs
• DeFi platforms -- where an entity or individual exercises sufficient control over the platform to comply with reporting requirements
• Custodial wallet providers that facilitate exchange transactions

The RCASP definition is intentionally broader than FATF's VASP definition to capture a wider range of intermediaries.

Key exclusion: Passive investment funds holding crypto-assets do not constitute RCASPs, as they do not facilitate exchange transactions.

Source: https://www.careyolsen.com/insights/briefings/introducing-carf-oecds-crypto-asset-reporting-framework

3.3 Reportable Crypto-Assets

CARF covers a broad range of digital assets:

• Cryptocurrencies (Bitcoin, Ether, etc.)
• ERC-20 and similar tokens
• Tradeable NFTs (non-fungible tokens that function as investment assets)
• Stablecoins
• Certain crypto derivatives

Exclusions from CARF reporting:

• Central Bank Digital Currencies (CBDCs) -- covered instead by amended CRS
• Specified electronic money products -- covered by amended CRS
• Closed-loop crypto-assets -- restricted to use within fixed networks or limited merchant groups

Source: https://www.careyolsen.com/insights/briefings/introducing-carf-oecds-crypto-asset-reporting-framework

3.4 Reportable Transactions

Four categories of transactions trigger reporting obligations:

1. Exchange Transactions -- any exchange between crypto-assets and fiat currencies, or between one or more forms of crypto-assets
2. Transfer Transactions -- movements of crypto-assets from or to a customer's address/account other than one maintained by the same RCASP on the customer's behalf, where the RCASP cannot determine it is an exchange
3. Retail Payment Transactions -- merchant payments exceeding USD 50,000 in aggregate
4. Transfers to External/Unhosted Wallets -- transfers to wallet addresses not associated with VASPs or financial institutions

Source: https://www.careyolsen.com/insights/briefings/introducing-carf-oecds-crypto-asset-reporting-framework

3.5 Due Diligence Procedures

RCASPs must perform the following due diligence steps:

1. Self-certification collection -- obtain a self-certification from each customer to determine their tax residence(s)
2. TIN collection -- collect Tax Identification Numbers for each reportable jurisdiction
3. Reasonableness checks -- cross-check self-certifications against information on file and open-source material
4. Controlling person identification -- for entity customers, identify individuals who are controlling persons and their tax residences
5. Ongoing monitoring -- maintain procedures to identify changes in circumstances that affect a customer's reportable status

Failure to provide self-certification may result in service restrictions or penalties, though unlike FATF requirements, CARF itself does not mandate transaction blocking (this is a

EU DAC8 addition).

Source: https://rsmus.com/insights/tax-alerts/2025/dac8-and-carf-present-extensive-reporting-challenges-for-crypto-platforms.html

3.6 Information Exchanged

RCASPs must annually report the following to their national tax authority:

User identification data:

• Full name
• Address
• Tax residence jurisdiction(s)
• Tax Identification Number(s) (TINs)
• Date of birth (for individuals)
• Entity type and controlling persons (for entities)

Transaction data:

• Type of crypto-asset
• Aggregate gross amount paid and number of units for exchange transactions (crypto-to-fiat)
• Aggregate gross amount and number of units for crypto-to-crypto exchanges
• Aggregate fair market value and number of units for transfers
• Wallet addresses for external transfers

The CARF XML Schema defines data elements as either "validation" (mandatory for all records, subject to automated checks) or "optional."

Source: https://www.oecd.org/en/publications/crypto-asset-reporting-framework-xml-schema_578052ec-en.html

3.7 XML Schema and Technical Implementation

The OECD released the CARF XML Schema in October 2024, with an updated version published in July 2025. The schema supports:

• Domestic reporting by RCASPs to national tax authorities
• International exchange between tax administrations under the MCAA-CARF

The XML Schema body contains two main sub-sections:

1. RCASP Section -- the reporting entity's identity, reporting obligation, and nexus to the reporting jurisdiction
2. Crypto Users Section -- reportable users' identities and relevant transaction data

Technical document: https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/07/crypto-asset-reporting-framework-xml-schema-july-2025_d1f81247/6e60235b-en.pdf

4. Relationship with CRS (Common Reporting Standard)

4.1 Complementary Frameworks

CARF and the amended CRS (CRS 2.0) operate as two separate but complementary reporting regimes:

• CARF tracks crypto-asset transactions through service providers
• CRS 2.0 monitors electronic money and digital currency holdings through financial institutions

The frameworks are designed to avoid duplication of reportable information -- assets excluded from CARF (CBDCs, e-money) fall under CRS 2.0 instead.

4.2 Amendments to CRS

In 2023, the OECD adopted amendments to the CRS that:

• Bring certain crypto-assets within the scope of CRS for the first time
• Expand types of information reported under CRS
• Strengthen reporting obligations and due diligence procedures
• Include electronic money products and CBDCs

The Addendum to the CRS-MCAA reflects these amendments, with signatories listed as of December 2025.

Source: https://www.oecd.org/content/dam/oecd/en/topics/policy-issues/tax-transparency-and-international-co-operation/addendum-crs-mcaa-signatories.pdf

4.3 MCAA-CARF (Multilateral Competent Authority Agreement)

The MCAA-CARF is the multilateral legal instrument enabling automatic exchange of CARF information between tax authorities. As of March 2026, numerous jurisdictions have signed the MCAA-CARF, building on the model of the existing CRS-MCAA.

The approach to supporting CARF implementation is largely based on the approach followed for the CRS, leveraging significant similarities and synergies between the two AEOI standards.

Source: https://www.oecd.org/content/dam/oecd/en/topics/policy-issues/tax-transparency-and-international-co-operation/carf-mcaa-signatories.pdf

5. Implementation Status

5.1 Commitment Overview

As of the May 2025 update, 67 jurisdictions have made a political commitment to implement CARF, with 7 additional jurisdictions identified as relevant but not yet committed.

Source: https://www.taina.tech/resources-news-and-awards/48-jurisdictions-commit-to-implement-the-crypto-asset-reporting-framework-carf-by-2027

5.2 First Exchanges by 2027 (52 jurisdictions)

Austria, Azerbaijan, Belgium, Bermuda, Brazil, Bulgaria, Canada, Cayman Islands, Colombia, Croatia, Cyprus, Czechia, Denmark, Estonia, Faroe Islands, Finland, France,

Germany, Gibraltar, Greece, Guernsey, Iceland, Indonesia, Ireland, Isle of Man, Israel, Italy,

Japan, Jersey, Kazakhstan, Korea, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Mexico, Netherlands, New Zealand, Norway, Poland, Portugal, Romania, San Marino, Slovak Republic, Slovenia, South Africa, Spain, Sweden, Switzerland, Uganda, and the

UK.

5.3 First Exchanges by 2028 (15 jurisdictions)

Bahamas, Barbados, British Virgin Islands, Costa Rica, Hong Kong (China), Malaysia, Mongolia, Nigeria, Saint Vincent and the Grenadines, Seychelles, Singapore, Thailand, Turkey, United Arab Emirates, and the

US.

5.4 Not Yet Committed (7 jurisdictions)

Argentina,

Australia, El Salvador, India, Panama, Philippines, and Vietnam -- identified as relevant to CARF but requiring further action.

5.5 Implementation Timeline

Source: https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/commitments-carf.pdf

6. Comparison with Other Frameworks

6.1 CARF vs.

EU DAC8

Source: https://rsmus.com/insights/tax-alerts/2025/dac8-and-carf-present-extensive-reporting-challenges-for-crypto-platforms.html

6.2 CARF vs.

US Form 1099-DA

The

US has committed to aligning with CARF objectives but favors domestic reporting mechanisms (1099-DA) that can interoperate with international exchanges rather than direct adoption of OECD model rules.

Sources:

• https://www.irs.gov/instructions/i1099da
• https://camusocpa.com/global-crypto-tax-reporting/

7. Challenges: DeFi, Unhosted Wallets, and Privacy Coins

7.1 DeFi Protocols

CARF applies to DeFi applications where an entity or individual exercises sufficient control over the platform that they could comply with due diligence and reporting requirements. However, fully decentralized protocols without identifiable controllers remain outside CARF's direct reach.

The anonymous nature of many DeFi transactions makes it difficult for authorities to track and identify participants. The OECD has signaled that future updates may expand scope to include certain DeFi intermediaries.

7.2 Unhosted Wallets

RCASPs must report transfers to unhosted wallet addresses (i.e., addresses not associated with VASPs or financial institutions), including the wallet address and value transferred. However, wallet-to-wallet transfers without any intermediary are not directly reported under CARF. They may become reportable only when funds later flow through a covered service provider.

7.3 Privacy Coins

Privacy-enhancing cryptocurrencies (e.g., Monero, Zcash) present a fundamental challenge to CARF. While authorities are using blockchain analytics to track privacy coin activity, innovations like zero-knowledge proofs could render parts of the framework ineffective. The OECD has acknowledged this gap but has not yet issued specific guidance on privacy coins.

7.4 Peer-to-Peer Transactions

Direct peer-to-peer trades without intermediaries remain outside CARF's scope. The framework relies on the presence of a reporting intermediary (RCASP), which inherently excludes fully decentralized or informal transactions.

Sources:

• https://rsmus.com/insights/tax-alerts/2025/dac8-and-carf-present-extensive-reporting-challenges-for-crypto-platforms.html
• https://www.careyolsen.com/insights/briefings/introducing-carf-oecds-crypto-asset-reporting-framework

8. G20 Endorsement and Global Implementation

The development of CARF was strongly endorsed by the G20, which invited the Global Forum on Transparency and Exchange of Information for Tax Purposes to work toward widespread implementation. The G20 recognized that crypto-assets posed emerging risks to tax transparency and that existing frameworks were insufficient.

Key milestones in G20 support:

• 2021-2022: G20 requested OECD develop a reporting framework for crypto-assets
• 2022: OECD completed core rules for CARF
• 2023: G20 endorsed the finalized CARF alongside the IMF-FSB Synthesis Paper
• 2023 (November): 54 jurisdictions issued a joint statement committing to implement CARF by 2027
• 2024 (October): G20 Crypto-asset Policy Implementation Roadmap status report published
• 2025: Commitment list expanded to 67 jurisdictions

Source: https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/carf-signatories-joint-statement.pdf

9. OECD Tax Administration 3.0 and Crypto

Tax Administration 3.0 is the OECD's vision for digital transformation of tax administration, emphasizing the decentralization of tax processes through integration into the devices and software used by taxpayers. The OECD report "Tax Administration 3.0: From Vision to Strategy" considers strategic actions for achieving this vision.

CARF aligns with Tax Administration 3.0 principles by:

• Requiring digital-first reporting through XML schemas
• Enabling automated data exchange between jurisdictions
• Supporting risk-based compliance through standardized data formats
• Building on existing AEOI infrastructure (CRS, FATCA) for operational efficiency

Source: https://www.oecd.org/en/topics/sub-issues/digital-transformation-of-tax-administration.html

10. Monitoring and Peer Review Mechanisms

The Global Forum oversees CARF implementation through:

1. Pre-exchange confidentiality reviews -- ensuring jurisdictions have adequate data safeguards before exchanges begin
2. Post-exchange data safeguards peer reviews -- conducted by subject matter experts from Global Forum members and the Secretariat
3. Comprehensive capacity-building strategy -- including awareness-raising, training activities, tools, and guidance
4. Annual monitoring reports -- tracking implementation progress across committed jurisdictions (e.g., the 2025 Monitoring and Implementation Update)

The monitoring approach is modeled on the successful CRS peer review process, adapted for CARF-specific requirements.

Source: https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/crypto-asset-reporting-framework-monitoring-implementation-update-2025.pdf

11. Recommendations

For Jurisdictions Not Yet Committed

• Commit to CARF implementation to avoid becoming regulatory arbitrage destinations
• Engage with Global Forum capacity-building programs
• Align domestic crypto-asset definitions with CARF terminology

For Reporting Entities (RCASPs)

• Begin system development for CARF XML reporting now, using the July 2025 schema
• Implement customer self-certification collection processes
• Establish TIN validation and reasonableness-checking workflows
• Monitor jurisdiction-specific guidance as countries transpose CARF into domestic law

For Policymakers

• Coordinate CARF implementation with FATF AML/CFT requirements to avoid duplicative compliance burdens
• Address gaps in DeFi and privacy coin coverage in future CARF amendments
• Establish clear domestic penalties for non-compliance by RCASPs

12. Impact Assessment

Positive Impacts

• Tax transparency: CARF brings crypto-assets in line with traditional financial assets under CRS, closing a major information gap
• Revenue protection: Capital gains tax revenue at stake globally may be in the tens of billions of dollars (per IMF Working Paper WP/23/144)
• Level playing field: Standardized reporting reduces competitive advantages of non-compliant jurisdictions
• Deterrence effect: The announcement of CARF alone may encourage voluntary compliance

Limitations

• Coverage gaps: DeFi, unhosted wallets, privacy coins, and P2P transactions remain largely outside scope
• Implementation asymmetry: Varied timelines (2027-2029) create windows for regulatory arbitrage
• Non-participating jurisdictions: Major crypto markets (India, Argentina) have not yet committed
• Compliance costs: Significant technology investment required by RCASPs, particularly smaller operators

13. Recent Developments

• July 2025: Updated CARF XML Schema published by OECD
• May 2025: Commitment list expanded to 67 jurisdictions
• December 2025: CRS MCAA Addendum signatories list updated
• November 2024: 48 jurisdictions confirmed commitment to 2026 reporting period
• October 2024: OECD released initial XML Schemas and User Guides for CARF
• October 2024: OECD issued interpretative guidance on CARF and amended CRS

14. Assessment

CARF represents the most significant expansion of automatic tax information exchange since the original CRS. With 67 jurisdictions committed and a clear implementation timeline, it is well-positioned to become a global standard by 2027-2028. However, its effectiveness will depend on:

1. Closing the non-commitment gap -- particularly India, Australia, and Argentina
2. Addressing DeFi and privacy technology -- the framework's intermediary-based model has inherent limitations in a decentralized ecosystem
3. Coordination with DAC8 and 1099-DA -- avoiding compliance fragmentation across overlapping frameworks
4. Enforcement capacity -- particularly in developing countries that may lack technical infrastructure

The OECD's phased approach -- building on CRS infrastructure and leveraging Global Forum capacity -- provides a pragmatic path to implementation, but the crypto industry's pace of innovation will continue to challenge regulatory frameworks.

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Related coverage

OECD Crypto-Asset Reporting Framework (CARF) in other research domains:

• Crypto Mining Regulations

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Verification Notes

All claims in this document have been verified through web searches conducted on 2026-03-19. Sources include:

• OECD Official Publications: CARF rules, XML schemas, implementation guides, monitoring reports, MCAA signatory lists
• Carey Olsen Analysis: https://www.careyolsen.com/insights/briefings/introducing-carf-oecds-crypto-asset-reporting-framework
• RSM US Analysis: https://rsmus.com/insights/tax-alerts/2025/dac8-and-carf-present-extensive-reporting-challenges-for-crypto-platforms.html
• Taina Technology Jurisdiction Tracker: https://www.taina.tech/resources-news-and-awards/48-jurisdictions-commit-to-implement-the-crypto-asset-reporting-framework-carf-by-2027
• IRS 1099-DA Instructions: https://www.irs.gov/instructions/i1099da
• OECD Tax Administration Digital Transformation: https://www.oecd.org/en/topics/sub-issues/digital-transformation-of-tax-administration.html

Note: Specific transaction thresholds beyond the USD 50,000 retail payment threshold were not found in publicly available CARF documentation. The framework generally does not impose de minimis thresholds for exchange transactions. Wikipedia and Reddit were not used as sources.