The HMRC crypto reporting changes announced on 2 November 2026 have altered the timetable for its Cryptoasset Reporting Framework (CARF). HMRC confirmed that the reporting portal will not open on 1 January 2027 as previously expected.
The change affects exchanges and other businesses that must report customer transactions. It also affects investors and companies whose crypto activity may be reported to HMRC, including through overseas platforms.
Cryptoasset Reporting Framework: At a Glance
| CARF record-keeping and due diligence obligations began on 1 January 2026. |
| HMRC's reporting portal will not be available from 1 January 2027. |
| The previously published 31 January 2027 registration deadline does not apply in the first year. |
| The first report is still due by 31 May 2027 and covers the 2026 calendar year. |
| CARF reporting does not replace Self Assessment or Corporation Tax obligations. |
What Have HMRC’s Crypto Reporting Changes Actually Altered?
HMRC’s updated guidance removes the anticipated 1 January 2027 start date for uploading CARF reports. The service is not yet live. HMRC says it will update its guidance when the portal becomes available.
HMRC has also removed its earlier reference to a 31 January 2027 first-year registration deadline. Regulation 10 of the Reporting Cryptoasset Service Providers Regulations 2025 provides a 31 May 2027 deadline for providers within scope in 2026. Later entrants may have a different deadline.
However, the first reporting deadline has not been postponed. Reports covering transactions from 1 January to 31 December 2026 remain due by 31 May 2027. The time available for submissions will depend on when HMRC opens the portal.
The position at 6 November 2026 is as follows:
| Requirement | Earlier published position | Current position |
|---|---|---|
| Collect 2026 data | From 1 January 2026 | Unchanged |
| Online submissions | Expected from 1 January 2027 | Portal delayed; opening date not yet announced |
| First-year registration | Guidance previously referred to 31 January 2027 | That date removed; regulation 10 provides 31 May 2027 for first-year providers |
| First report | 31 May 2027 | Unchanged: calendar year 2026 |
| Report format | XML reporting | OECD XML schema plus HMRC validation requirements |
Which Crypto Businesses Fall Within CARF Reporting Rules?
CARF applies to reporting cryptoasset service providers. These can include exchanges, brokers and dealers that transact for customers or enable customers to transact in relevant cryptoassets. The statutory definition is wider than businesses describing themselves as exchanges.
A UK-incorporated platform may be within scope even if most customers are overseas. An overseas group with a UK branch or UK management may also need to assess its position. Where several jurisdictions are involved, the reporting hierarchy and exemptions require careful review.
A business that merely holds Bitcoin or USDC as an investment, or accepts crypto as payment for its own goods or services, is not automatically a reporting provider. Its activities determine whether it falls within the rules.
Are DeFi Protocols and Web3 Platforms Subject to CARF Reporting?
Executing transactions through smart contracts does not automatically exempt a platform. The question is whether an identifiable person or entity carries on a business that effects relevant transactions for users or makes a trading platform available. The applicable UK connection must also be assessed.
A protocol with no identifiable operator is different from a business running a customer-facing exchange. Equally, calling a platform “decentralised” does not settle its position. Its operator’s role, fees, control over interfaces and involvement in transactions need examining.
What Information Must Crypto Businesses Collect Under CARF in 2026?
Reporting providers must carry out due diligence and retain information about users and relevant transactions. For entity customers, this may include details of controlling persons.
CARF reports generally contain prescribed customer details and aggregated transaction information. They do not calculate each customer’s UK taxable gain. UK-resident customers may also be reportable because the UK has extended the rules to domestic users.
Providers therefore need to establish tax residence and obtain valid self-certifications where required. They should review their onboarding and transaction records now. Missing information from early 2026 may be difficult to reconstruct next year.
What Do HMRC’s Crypto Reporting Changes Mean for Investors?
The HMRC crypto reporting changes do not alter how individual investors are taxed. Selling tokens, swapping one cryptoasset for another or spending crypto can still trigger a disposal. Staking, employment receipts and trading income require separate consideration.
CARF is an information-reporting system, not a tax calculator. An exchange may report disposal proceeds without knowing the original acquisition cost of tokens transferred from another platform or wallet.
Example: When an Exchange Reports a Sale but Not the Original Cost
An investor buys 2 BTC for £40,000 through Exchange A, transfers them to a private wallet and later sells them through Exchange B for £120,000.
Exchange B may report the £120,000 proceeds without knowing what the investor paid. Assuming no other Bitcoin transactions affect the calculation, the illustrative gain is £80,000 before other allowable costs.
Other Bitcoin acquisitions or disposals could change that figure under the UK matching and pooling rules. Exchange-reported proceeds are therefore not necessarily the amount subject to tax.
Investors using several exchanges, wallets or DeFi protocols should reconcile their own records. They should not assume an exchange report will reproduce the figures in their tax return
Why CARF Reports May Differ from UK Tax Returns
CARF uses calendar years, while Self Assessment uses tax years ending on 5 April. The 2026 CARF report therefore covers transactions falling within two UK tax years.
A disposal on 20 February 2026 belongs to 2025/26. One on 20 October 2026 belongs to 2026/27. Both appear in the 2026 CARF reporting period.
CARF also groups transactions into prescribed reporting categories rather than calculating UK capital gains. As a result, its figures may differ from a correct Self Assessment return. Investors must still apply same-day and 30-day matching, Section 104 pooling and sterling valuations at transaction dates.
CARF Reporting, Overseas Exchanges and Self-Custody
HMRC crypto reporting changes also increase the information HMRC may receive from participating overseas tax authorities. Using an overseas exchange does not necessarily prevent HMRC from obtaining transaction details.
Moving crypto into self-custody does not erase an exchange’s records. A private wallet does not itself make its owner a reporting provider. Later transactions through reporting intermediaries may nevertheless reveal further movements of those assets.
CARF will not provide HMRC with every investor’s complete transaction history. Direct wallet-to-wallet transfers and some decentralised arrangements may fall outside its scope. HMRC can still seek information through other statutory powers.
CARF involves collecting and sharing personal and financial information internationally. Investors should verify requests for tax-residence or identity information through official platform channels.
How Does CARF Affect UK Companies Holding or Trading Crypto?
Companies using reporting exchanges may need to provide their tax residence, entity classification and, where applicable, controlling-person information. Exchanges use these details to assess whether transactions must be reported.
Ownership can be difficult to establish where founders use personal exchange accounts or wallets for company transactions. Companies should retain evidence of ownership and ensure that their accounting records reflect the actual arrangements.
CARF does not determine Corporation Tax treatment. A company might invest in tokens, trade them, receive crypto for services or use DeFi protocols. The tax and accounting treatment depends on the assets and activity, not the exchange’s reporting category.
Reported figures may therefore differ from the company’s accounts or Corporation Tax return. Companies should reconcile exchange data to their ledgers and wallet records, particularly where personal and company-controlled wallets interact.
How Should Crypto Businesses Prepare for CARF Reporting?
Businesses within scope should identify the legal entity responsible for reporting and the jurisdiction in which its obligations arise. A group operating through several companies or branches may have different requirements for each entity.
Next, providers should review customer identification, tax residence, self-certifications and transaction records collected since 1 January 2026. Any missing information should be addressed while source records remain available.
HMRC requires the OECD XML schema alongside its own validation requirements. An uncompressed file may contain up to 250MB of data; larger submissions must be divided. Providers should test their extraction and validation processes before the reporting deadline.
What Happens if HMRC's Reporting Portal Remains Unavailable?
The HMRC crypto reporting changes have not altered the statutory deadlines. Regulation 6 sets 31 May 2027 for the first report covering 2026. Regulation 10 sets the same first-year registration deadline for providers already within scope in 2026.
A late opening could leave little time to register, upload reports and resolve validation errors. Regulation 20 provides a reasonable-excuse defence in appropriate circumstances, but a delayed portal does not automatically excuse late filing.
Businesses should retain evidence of technical problems and demonstrate that their due diligence, data extraction and file preparation were completed in good time.
What Are the Penalties for Failing to Comply with CARF?
The Reporting Cryptoasset Service Providers Regulations 2025 contain separate penalties for failures involving due diligence, record-keeping, registration and reporting.
Under regulation 14, a late report can attract up to £5,000. Further penalties of up to £600 per day may apply if the failure continues after a penalty assessment notice.
Regulation 15 provides for penalties of up to £100 per affected reportable user for certain inaccurate or incomplete reports. Failure to obtain a valid self-certification can attract up to £300 per affected person under regulation 11.
Other penalties apply to registration and record-keeping failures. These figures are statutory maxima, not automatic charges. Regulation 20 also provides a reasonable-excuse defence where its conditions are met.
Businesses should prioritise complete and accurate 2026 records rather than assume HMRC will extend the deadline.
Our Assessment of HMRC’s Crypto Reporting Changes
HMRC crypto reporting changes concern the administration of CARF, not the taxation of cryptoassets. The portal will open later than expected, but the statutory reporting obligations remain. Unless the law changes, providers must still meet the 31 May 2027 deadline.
In our view, the delay creates a potential compliance bottleneck. HMRC has retained the deadline without confirming when registration and submissions can begin. A late launch could leave businesses little time to resolve rejected files.
For investors, the larger development is HMRC’s access to more transaction information, including overseas data. Yet CARF reports may not show an investor’s full history or establish the correct UK tax liability.
We expect apparent differences between CARF reports and Self Assessment returns to feature in future HMRC enquiries. Some will reflect omissions. Others may arise from calendar-year reporting, missing acquisition costs or transactions correctly treated under UK tax rules.
HMRC could identify a discrepancy before obtaining enough information to decide whether a tax error exists. Investors who retain a clear transaction trail will be better placed to explain the figures.
Specialist Crypto Tax Advice
The Friendly Accountants have advised on UK crypto taxation since 2016
We advise individuals and businesses on cryptoasset taxation, DeFi, historic disclosures and HMRC enquiries, including the tax issues facing Web3 businesses
For further analysis, see our guides to the UK tax treatment of Polymarket profits and tax issues for crypto and Web3 gaming businesses, alongside our wider guidance on crypto taxation for UK companies.
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