CARF puts intermediaries at the heart of the system
The Crypto-Asset Reporting Framework relies on a simple principle: information on crypto-assets is collected by intermediaries — exchanges, brokers, custodians, and broadly any structure providing services on crypto-assets on behalf of clients — and then automatically exchanged between tax administrations.
In Switzerland, CARF activation is scheduled no earlier than 1 January 2027, with first exchanges in 2028. The list of 74 initial partner states was frozen by Parliament at the end of 2025, making the perimeter predictable.
Who falls within scope?
The categories of actors targeted by the OECD framework include primarily:
- Exchange platforms facilitating crypto transactions for clients.
- Brokers and intermediaries that execute or transmit orders.
- Custodians holding private keys or managing wallets on behalf of third parties.
- Structures providing management services on crypto-assets on behalf of clients — the question notably arises for some family offices and asset managers depending on their setup.
The precise qualification depends on the role performed (private key custody, order execution, matching, management on behalf). The guidelines published by SIF detail these qualifications — and for pan-European structures, the MiCA regulation and the DAC8 directive add their own terminology on the EU side.
What data must be collected?
Without anticipating implementation details to be specified by ordinance, the OECD framework structures reporting into four blocks:
- Holder identification: individuals and entities, with their tax identification elements.
- Nature of crypto-assets: classification by category according to the framework taxonomy (native tokens, stablecoins, others).
- Balances and valuations on reference dates.
- Transactions: acquisitions, disposals, transfers — including transfers between a holder's own wallets, which receive specific treatment.
The operational friction point: data quality
The CRS experience shows where compliance programmes fail: source data collection. For crypto-assets, the difficulty is amplified by the natural fragmentation of positions — a single beneficiary may hold positions across several exchanges, several self-custody wallets and a custodian, with no unified view.
Concretely, structures entering 2027 with:
- manual exports per exchange, in heterogeneous formats;
- valuations reconstructed manually;
- a history scattered across non-auditable files;
…will pay a high compliance price, with an error risk proportional to the effort. Conversely, an infrastructure that centralises positions, timestamps history and automates valuations turns reporting into an export exercise.
Structuring preparation: four projects
1. Map the scope. Which clients, which assets, which jurisdictions — cross-referenced with the list of 74 partner states frozen until 2028.
2. Qualify the structure's role. Intermediary, custodian, management on behalf: qualification determines obligations. To be validated with tax counsel based on SIF publications.
3. Industrialise data collection. Centralisation of positions, systematic historisation, automated valuations — 2027 data must be clean from day one.
4. Document processes. Reporting is a long-term exercise: collection processes must be documented and auditable from their inception.
The role of a consolidated tracking infrastructure
A tracking platform like CIYL does not replace tax counsel or the declaration itself — but it processes the raw material of compliance:
- Multi-source consolidation: wallets, exchange accounts and custodians aggregated in a single interface.
- Timestamped history: every transaction and valuation documented, exportable.
- Client view: multi-client segmentation matching the logic of reporting.
This is the missing link between dispersed raw data and CARF collection requirements.
Sources
- SIF.admin.ch — CARF implementation in Switzerland
- OECD — Crypto-Asset Reporting Framework
- European Commission — DAC8
Last updated: September 2026. This content is informational and does not constitute tax or legal advice.
