OECD's new FAQs and User Guide provide roadmap for reporting cryptoassets

Executive summary: OECD publishes guidance for reporting under CARF

The Organisation for Economic Co-operation and Development (OECD) has released new guidance including FAQs, xml schemas, and user guides to assist governments and businesses implementing the Crypto Asset Reporting Framework and the amended Common Reporting Standard.

OECD Releases Additional Guidance for CARF and CRS

On Oct. 2, 2024, the OECD released guidance on the required format of data along with answers to frequently asked questions to support the transmission of information between taxing authorities pursuant to the Crypto-Asset Reporting Framework (CARF) and the amended Common Reporting Standard (CRS). The new CARF XML Schema and User Guide and the CRS XML Schema and User Guide outline the reporting requirements for CARF and the amended CRS that were approved by the OECD in 2023 and subsequently endorsed by the G20 and the Global Forum as international standards. First exchanges under both CARF and the amended CRS are expected to commence in 2027 for the 2026 reporting year. Companies and governments affected by these rules must be prepared to exchange and report data as required under the rules or they could be subject to penalties.

While the XML Schemas and User Guides are primarily designed to support the automatic exchange of information between taxing authorities, jurisdictions can also mandate the use of the XML Schemas for domestic reporting by Reporting Crypto-Asset Service Providers and Reporting Financial Institutions, respectively, as defined under CARF and CRS.

The OECD also issued a first set of FAQs aiming to provide interpretative guidance to ensure consistency in the implementation of the CARF. Specifically, the guidance clarifies that providers of non-custodial services in respect of Crypto-Assets, including in a decentralized manner, can generally meet the definition of Reporting Crypto-Asset Service Provider. Given the general interest expressed by both governments looking at implementing CARF, and businesses that will be subject to the rules, the OECD is looking to release additional guidance on relevant aspects surrounding the application of the CARF to non-custodial and decentralized services.

For an in-depth look at CARF and the CRS amendments please refer to RSM’s article Crypto-Asset Reporting Framework: Answers to fundamental questions and OECD publishes Crypto-Asset reporting framework and amendment to CRS.