U.S. digital-asset reporting rules began applying to 2025 transactions

A new reporting boundary

On January 1, 2025, the United States entered the first transaction year covered by final Internal Revenue Service regulations requiring certain digital-asset brokers to report customers’ gross proceeds. The information returns were not due on January 1: brokers were expected to report covered 2025 transactions on Form 1099-DA during 2026.

The same date also activated new basis-identification rules for acquisitions and dispositions of digital assets. Those rules generally required taxpayers to identify units within the particular wallet or account holding them, replacing the universal or multi-wallet approach that some taxpayers had previously inferred from IRS frequently asked questions.

This was an implementation milestone, not a new cryptocurrency tax. Treasury stated when it issued the final regulations on June 28, 2024 that owners already owed tax on taxable digital-asset sales and exchanges. The regulatory change extended an information-reporting framework familiar from conventional brokerage accounts to a defined part of the crypto market.

Who entered the regime

The June 2024 final regulations covered brokers taking possession of digital assets sold by customers. The identified categories included custodial trading platforms, certain hosted-wallet providers, digital-asset kiosks and certain processors of digital-asset payments.

That scope distinction mattered on January 1, 2025. The regulations discussed here did not impose the same reporting requirement on noncustodial participants that never possessed the assets being sold. Nor did the January 1 applicability date mean every broker already had to report customers’ cost basis: mandatory basis reporting for certain covered digital assets was scheduled for transactions beginning January 1, 2026, with those reports furnished in 2027.

For covered 2025 transactions, gross-proceeds reporting included identifying information, the asset and quantity sold, the sale date, proceeds after allocable transaction costs, and whether consideration took the form of cash, services or other property. Treasury and the IRS also provided special methods and thresholds for qualifying stablecoins, specified nonfungible tokens and payment-processor transactions.

The wallet-by-wallet transition

Revenue Procedure 2024-28 supplied a safe harbor for taxpayers who had unused basis associated with digital assets remaining across multiple wallets or accounts. It permitted a reasonable allocation of that basis to an equal number of remaining units of the same asset, using either specific-unit or global allocation methods, subject to documentation and timing conditions.

The transition was consequential because basis determines the gain or loss calculated when an asset is disposed of. Under the new approach, specific identification or the default first-in, first-out ordering operated within an individual wallet or account. Taxpayers using the safe harbor also had to account separately for relevant acquisitions or transfers occurring on or after January 1, 2025 until their allocations were completed.

The American Institute of CPAs had warned Treasury and the IRS in October 2024 that taxpayers and practitioners needed clearer explanations of the safe harbor, its documentation requirements and its deadlines. That contemporaneous request illustrates the implementation uncertainty without negating the rule’s applicability.

What January 1 did—and did not—establish

January 1, 2025 established the start of the covered transaction window and the wallet-level basis regime. It did not establish how accurately every platform would implement Form 1099-DA, reconcile transfers between services or match taxpayer records. The IRS granted transitional penalty relief for brokers making good-faith efforts to report 2025 transactions correctly and on time.

No market-price reaction is attributed to the rules because cryptocurrency trades continuously, January 1 was a U.S. market holiday, and the cited regulatory records do not establish price causation. The significance was institutional: custodial crypto activity had entered a standardized federal information-reporting cycle, while important basis reporting and operational tests still lay ahead.