Crypto Asset Reporting Framework (CARF)

Crypto Asset Reporting Framework (CARF)
Written by Alice Lithgow Last Updated: 19 March, 2026
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On 1st January 2026, the Crypto-Asset Reporting Framework (CARF) came into force in the UK.

The framework has been developed by the OECD and there are currently 75 signatories across the globe.

The purpose of the framework has been to improve the transparency of tax for crypto transactions and to set a standard for tax reporting.

In addition, the framework has been designed to enable the exchange of information across borders.  In essence, signatories have agreed to automatic exchange of information (AEOI) between tax authorities.

In practice, the obligation to comply with CARF will largely rest on crypto businesses such as crypto houses, exchanges and brokers.  There is a requirement for UK reporting crypto asset service providers (RCASPs) to provide information annually and there are penalties for non-compliance.

Any data collected will be forwarded to HMRC who can then exchange information with the tax authorities located in other signatory jurisdictions.

Yes, in short the introduction of CARF is likely to lead to an increase in litigation and some of the issues which may arise are as follows:-

  • Challenging any fines imposed by HMRC on crypto businesses;
  • Managing disputes relating to reporting failures or incorrect disclosures;
  • Contractual disputes between crypto businesses and their clients;
  • Professional negligence claims against advisers who had not advised correctly on CARF issues;
  • Class actions if there are widespread failures to comply;
  • Cross border issues and international tax litigation including enforcement of foreign tax demand.
  • Representing tax payers in HMRC enquiries;

Summit Law LLP is a niche commercial and insolvency litigation firm in Central London with specialist tax expertise and strong international connections.

If you are a crypto business or an individual and you have a dispute which relates to CARF or you have already been contacted by HMRC, then we would be pleased to discuss your position in confidence.

About the Author:

Alice Lithgow

Partner and Head of Commercial Litigation | Summit Law Alice is a Partner and supervisor of the Commercial Litigation team. She has extensive experience of resolving commercial and insolvency related disputes and she has a particular interest in cases with an international element.
About the Author:

Mala Kapacee

Solicitor (Consultant) | Summit Law Mala is a Chartered Tax Adviser and solicitor specialising in the resolution of tax disputes. She lectures regularly for professional bodies including the CIOT and the CIMA. She was a finalist for Best Rising Star in Tolley’s Taxation Awards 2020.