A regulatory outlook for anyone who thought their wallet was private business
There’s a sentence we’ve heard often enough over the past few years to notice a pattern: „My bank has no idea about my wallet, so none of this applies to me.“ Since this year, that’s true even less than before. Not because every wallet address has suddenly gone public, but because two new OECD frameworks, CRS 2.0 and CARF, close exactly the gap that used to sit between a regular bank account and a crypto exchange. If you’re structured across more than one jurisdiction, it’s worth knowing what actually gets reported now, to whom, and, more importantly, when.
Two frameworks, one goal
The Common Reporting Standard, CRS for short, has been around since 2017 and requires banks to automatically report account data on foreign tax residents to their home tax authority. What it never covered: crypto assets held outside a traditional bank, through an exchange or a broker instead. That’s the gap the two new frameworks close, each in its own way.
CRS 2.0, the revised version of the existing standard, came into force on the first of January this year and widened the definition of reportable financial products. Newly covered are e-money accounts, central bank digital currencies and, this is the part that matters most, crypto derivatives, provided they run through an already-reportable financial institution. The first reports under the amended rules fall due in 2027, so institutions still have a few months to adjust their systems.
CARF, the Crypto-Asset Reporting Framework, isn’t an update at all but an entirely new, parallel system. It obliges so-called Reporting Crypto-Asset Service Providers, exchanges, brokers and similar platforms, to collect transaction data on their users and pass it on to the relevant tax authority, regardless of whether those providers were ever classified as financial institutions under CRS in the first place. In other words: even a pure crypto exchange with no banking licence at all now becomes a reporting entity.
What actually counts as a reportable crypto asset is, incidentally, broader than most people assume. It isn’t limited to Bitcoin and the usual large-cap coins. In principle it covers any asset built on distributed ledger technology and held for investment or payment purposes, stablecoins included. The main exclusions are centrally issued digital currencies, which fall under CRS 2.0 instead, and closed-loop systems such as pure loyalty points that can’t be traded. In practice: anyone assuming a stablecoin balance sits outside the scope is usually wrong.
The timeline is anything but uniform
And here it gets genuinely relevant for our clients, because there is no single global deadline. Around 48 jurisdictions have committed to a first CARF exchange in 2027, Germany, the UK and most of the EU among them. That list keeps shifting, so it’s worth checking the current state before relying on it for any major decision.
A second wave of roughly 27 jurisdictions is targeting a first exchange in 2028, and among them, somewhat notably, sit several of the locations most relevant to our own clients: Switzerland, Singapore, Malaysia and the United Arab Emirates. Switzerland’s parliament has already passed the corresponding legislation, but has deliberately pushed the actual rollout back: data collection there starts at the earliest in 2027, with the first cross-border exchange planned for 2028. That doesn’t mean nothing happens there in the meantime, only that the first automatic data exchange arrives a year later than in, say, Germany.
Panama, for its part, doesn’t appear on either list. It simply hasn’t committed to CARF so far. Before anyone starts mentally opening a new account in Panama City, though: this isn’t a permanent loophole, it’s a state of affairs that can shift quickly once international pressure builds, much as we saw with the original CRS, where early holdouts eventually fell in line over the following years. Building a structure around one country’s current regulatory restraint alone tends to be building on sand.
What this actually means for your structure
Take an example close to one we’ve genuinely encountered. An entrepreneur resident in Germany holds Bitcoin and Ethereum through a French exchange, while the operating company’s income runs through an entity in Singapore. The French exchange is already collecting transaction data; from 2027 it flows automatically to the German tax authority. The Singaporean company accounts, by contrast, provided they hold crypto too, only enter the 2028 reporting cycle, the same cycle as accounts held with a Swiss exchange. On its own, that’s not a cause for concern if everything is taxed correctly anyway. What it does show is how differently the reporting timelines fall depending on where assets sit, and that neither „my exchange isn’t in the EU“ nor „my exchange is in Switzerland“ is a reliable way to plan around any of this.
A second point concerns high-net-worth individuals more directly than it might first appear. The EU’s DAC8 directive, which supplements both CRS 2.0 and CARF across the Union and had to be transposed into national law by the end of 2025, additionally provides for the automatic exchange of cross-border tax rulings for individuals: specifically, rulings issued, amended or renewed from 1 January 2026 onward where either the transaction value named in the ruling exceeds one and a half million euros, or the ruling determines the individual’s tax residence. The exact implementation can still differ somewhat by member state. Anyone holding such a ruling with an EU tax authority should assume it will become known to other authorities going forward.
What’s actually worth doing now, and what isn’t
„So I’ll just restructure quickly before everything gets reported in 2027“, you might be thinking. Understandable, but too thin a strategy on its own. The more useful approach isn’t to chase the reporting deadline by a year, but to set up your structure so it holds up regardless of whether or when anything gets reported, because it’s clean and defensible to begin with. Concretely: residency, company seat and the tax treatment of crypto assets should already line up before the first automatic report arrives, not as a reaction afterward.
For entrepreneurs with ties to several of the jurisdictions mentioned, it’s worth checking exactly where your crypto holdings currently sit, through which provider, and which of the two reporting cycles, 2027 or 2028, that provider falls under. That’s a manageable question to sort out with a few weeks‘ lead time. With two weeks‘ notice before the first report actually lands, considerably less so.
Three things we’re genuinely telling clients right now: first, check whether your company accounts hold e-money or CBDC-adjacent products, since those fall under CRS 2.0 and can therefore land in a different, sometimes earlier, reporting cycle than pure crypto holdings. Second, document now, thoroughly, which structure holds which assets; records you should have anyway are easier to pull together before an authority asks than after. And third: digital nomads moving between countries without a clearly documented tax residency don’t automatically become a problem case under CARF, but they do tend to attract more attention, since the reported data can go to several possible countries of residence at once until actual residency is settled.
In the end, the point that already applied under the original CRS simply extends to a new asset class: international diversification protects against concentration risk and preserves optionality; hiding was never really the point of any of it. Tax authorities have worked that out too, by the way, which is why they’ve been building this reporting system not since yesterday, but patiently, for well over a decade now.
If you’d rather think this through properly for your own setup than leave it to the tax authority to sort out for you, we’re happy to talk it through, and to advise where useful. The first reporting cycle in 2027 sounds like plenty of time. For a clean restructuring, a year is genuinely workable. For one you only start once the letter from the tax office is already sitting in your inbox, considerably less so.
This article is intended as a general overview of current regulatory developments and does not constitute individual tax, legal or investment advice. Singabiz does not provide such advice; for the tax and legal assessment of your specific situation, please consult a licensed tax advisor or lawyer. Depending on the country involved, we can refer you to suitable tax and legal advisors within the Singabiz Network.
Want to know how CRS 2.0 and CARF actually affect your structure? Book a no-obligation conversation at singabiz.com/contact.
