The IRS guidance list was shortened, removing Notice 2025-03 and Final regulations 2024-12-30 that previously offered transitional relief and broker reporting rules.
Before
Taxpayers could rely on Notice 2025-03 and Final regulations 2024-12-30 for temporary relief and specific broker reporting requirements.
After
Those relief provisions are no longer listed, so the previous temporary relief and reporting requirements are no longer available.
Source: IRS — Crypto Broker Reporting (Form 1099-DA)
View original source →What this means for you
Centralized Exchange
Act nowWhy this matters
As a CEX, the company is responsible for reporting obligations and acts as a broker for its users. The removal of transitional relief means the company must immediately implement full broker reporting requirements to avoid tax non-compliance and enforcement actions.
What to do
Update tax reporting systems to ensure full compliance with IRS broker reporting rules without relying on previous transitional relief.
DeFi Protocol
Doesn't applyWhy this matters
The regulatory change concerns broker reporting and transitional relief for tax reporting. As a fully decentralized protocol with no operator and no custody of user assets, there is no legal entity to act as a 'broker' or fulfill reporting obligations.
Custodian
Review soonWhy this matters
As a company holding crypto-assets for clients, the removal of transitional relief and the tightening of broker reporting rules may force the custodian to implement more rigorous tax reporting mechanisms. Failure to adhere to these reporting requirements could lead to IRS penalties for the entity or its clients.
What to do
Review current tax reporting workflows to ensure compliance with standard broker reporting rules now that transitional relief is unavailable.