Why self-custody wallets complicate CARF
CARF relies on intermediaries: tax administrations collect information from them. A self-custody wallet (self-hosted), by definition, has no intermediary — the holder controls their own private keys.
This peculiarity creates two distinct questions that family offices often confuse:
- Who reports? A self-custody wallet is not reported by its holder via CARF — the holder remains subject to their ordinary reporting obligations. CARF concerns information held by intermediaries and platforms.
- When does an intermediary come into play? As soon as a structure provides a service on these assets: management on behalf of beneficiaries, transaction execution, matching, custody. At that point, collection and reporting obligations apply to the managed scope.
Reference source: SIF.admin.ch — CARF implementation.
The typical family office case
A Swiss family office managing crypto-assets for beneficiaries meets the self-custody wallet question in at least three situations:
Situation 1 — The structure administers wallets for beneficiaries. Even self-custody, these wallets are managed by an intermediary: the corresponding information enters the CARF collection scope from activation (no earlier than 1 January 2027).
Situation 2 — Beneficiaries declare directly held wallets. The structure does not manage them, but consolidates them for the overall wealth view. Consolidation is not in itself a CARF reporting obligation — but the quality of this mapping becomes invaluable at the time of ordinary declarations and administration queries.
Situation 3 — Transfers between wallets. The OECD framework grants specific treatment to transfers between wallets of the same holder. Distinguishing them correctly from transfers to third parties requires transaction-level traceability — difficult to reconstruct without a consolidated history.
Traceability: what to document
Whether the structure falls within the CARF perimeter or consolidates for the wealth view, recommended practice converges:
- The wallet inventory: addresses, blockchains, nature (hardware, software, custodial), associated beneficiary.
- The provenance of positions: originating exchange, acquisition date, value at acquisition.
- The movement history: inflows, outflows, internal transfers, with their classification.
- Valuations at relevant dates, calculated in a reproducible manner.
Retaining this data spans years — which makes spreadsheet-based approaches not only costly but fragile: who will reconstruct the calculation chain of a 2027 valuation in 2032?
From manual inventory to consolidated infrastructure
The difference between solid preparation and a risky exercise comes down to one word: continuity.
A periodic manual inventory approach produces incomplete, non-auditable snapshots. A tracking infrastructure like CIYL inverts the logic:
- positions are aggregated continuously (wallets, exchanges, custodians) rather than reconstructed;
- every movement is timestamped and documented when it occurs;
- valuations are automatic and reproducible;
- the per-beneficiary view already exists — it does not have to be built at reporting time.
For structures preparing for 2027, the investment is the same as for daily management: a professional tracking infrastructure serves both family office governance and future compliance.
Key takeaways
- Self-custody wallets do not create CARF obligations by themselves — the perimeter activates when an intermediary provides a service.
- Switzerland will activate CARF no earlier than 01.01.2027, exchanges in 2028, with a list of 74 partner states frozen since the end of 2025.
- Documented traceability (inventory, provenance, history, valuations) is the most valuable compliance asset — and the hardest to reconstruct retrospectively.
- A distinct CRS 2.0 is already active in Switzerland since 01.01.2026 for indirect products: the two frameworks overlap and must not be confused.
Sources
Last updated: September 2026. This content is informational and does not constitute tax or legal advice.
