CARF arrives in Switzerland: a timeline in three stages
The OECD's Crypto-Asset Reporting Framework (CARF) introduces an automatic exchange of information on crypto-assets, following the model of what CRS did for financial accounts. For Switzerland, the timeline is now set — and it has been pushed back by one year compared with initial intentions.
The three dates to remember:
- 1 January 2027 (at the earliest): CARF enters into force in Switzerland and data collection begins.
- 2028: first automatic exchanges of information with partner states.
- End of 2025: the Swiss Parliament froze the list of 74 initial partner states — no new state will join the exchange perimeter before the next revision.
Primary source: SIF.admin.ch — CARF implementation in Switzerland.
Why the deferral from 2026 to 2027 changes the picture
The deferral decided by Parliament is not a minor calendar detail. It creates a preparation window that few structures have used so far:
- Data collection obligations (holders' identities, asset natures, transactions) will start running as soon as activation occurs — data must therefore be clean from the first day of 2027.
- The list of 74 states frozen until 2028 makes the perimeter predictable: you can map today which jurisdictions concern your clients and their structures.
- Structures that centralise and historise data before 2027 will face a far less costly reporting process than those that must reconstruct history retrospectively.
CARF and CRS 2.0: two distinct frameworks not to be confused
A common point of confusion: CRS 2.0, active in Switzerland since 1 January 2026, is not CARF. It extends the traditional CRS to electronic money and indirect crypto-asset products. CARF targets the direct reporting of crypto-assets held through intermediaries or platforms.
| Framework | Scope | Swiss status |
|---|---|---|
| CRS 2.0 | E-money, indirect crypto-asset products | Active since 01.01.2026 |
| CARF | Crypto-assets held through intermediaries or platforms | Activation no earlier than 01.01.2027, exchanges in 2028 |
| DAC8 (EU) | EU equivalent of CARF for member states | Data collection from 2026 |
For a pan-European structure, the two timelines overlap: EU-side entities fall under DAC8 from 2026, while Swiss entities prepare CARF for 2027.
Who is concerned within a family office?
CARF targets information held by intermediaries and platforms on their clients' crypto-assets. In the practice of a family office, the question arises as soon as:
- the structure manages wallets or exchange accounts on behalf of beneficiaries;
- it acts as an intermediary in crypto transactions;
- it consolidates positions held through vehicles or dedicated structures.
The exact qualification of your structure (intermediary, holder for own account, RCASP where applicable) depends on your setup and deserves review with your tax adviser. SIF publishes implementation guidance detailing these qualifications.
Concrete operational implications
Whatever qualification applies, three operational projects keep coming back:
1. Data quality from day one. CARF reporting requires accurate data on holders, assets (nature, quantity, valuation) and transactions. Fragmented data across exchanges, wallets and custodians is the main source of compliance cost.
2. Data historisation. As with CRS, data retention spans years. Information collected from activation must remain auditable for years.
3. Valuation. CARF requires valuations at precise points in time. Without automatic consolidation, reconstructing those valuations retrospectively quickly becomes a risky manual exercise.
How a family office can prepare now
- Map crypto exposure: which wallets, exchanges, custodians, for which beneficiaries, and in which jurisdictions.
- Cross-check the perimeter against the list of 74 partner states (frozen until 2028) to anticipate information exchanges.
- Centralise tracking data in a single infrastructure — rather than dispersed Excel exports — so that 2027 collection is as close as possible to a simple export.
- Validate the qualification of your structure with your tax adviser, referencing SIF publications.
This is precisely where a consolidated tracking infrastructure like CIYL simplifies preparation: centralised data, timestamped history and automated valuations — the three ingredients of manageable CARF reporting.
Sources
Last updated: September 2026. The regulatory framework keeps evolving; always refer to official sources for definitive interpretation.
