Ireland Publishes Updated Guidance on Crypto-Asset Reporting

On August 24, Irish Revenue published a Brief No. 121/26 on updated rules for cryto-asset reporting by service providers. The Crypto-Asset Reporting Framework (CARF), developed by the Organisation for Economic Co-operation and Development (OECD), is the agreed standard for the collection and automatic exchange of information on crypto-asset transactions between tax administrations.

CARF introduces new reporting obligations for Reporting Crypto-Asset Service Providers (RCASPs), together with the automatic exchange of that information between participating jurisdictions.

With effect from  January 1, 2026, an RCASP must collect information on reportable users and their transactions. The first reporting of data is in respect of the period  January 1, 2026 to December 31, 2026 and is required to take place by May 31, 2027.

Examples of crypto-assets include (but are not limited to):

– Cryptocurrencies (e.g. Bitcoin, Ethereum),

– Utility Tokens (tokens used for specific services),

– Security Tokens (tokens that represent ownership in an asset),

-Stablecoins (tokens that are tied to real-world money),

– Fungible tokens (tokens that are interchangeable with one another),

– Non-Fungible Tokens (unique digital items),

– Derivatives (contracts that can be exchanged for real money or other cryptoassets).

Under CARF, a reporting crypto-asset service provider (RCASP) is any individual or entity that, as a business, provides a service effectuating relevant transactions for or on behalf of customers, including by acting as a counterparty, or as an intermediary, to such exchange transactions, or by making available a trading platform.

For the purposes of DAC8, an RCASP includes:

– any crypto-asset service provider regulated by and authorised in Ireland under the MiCAR, and

– any crypto-asset operator conducting one or more crypto-asset services for or on behalf of a reportable user which has a nexus (connection) to a Member State.

For entities, the the following order of nexuses applies:

– jurisdiction of tax residence,

– jurisdiction of incorporation or organisation, where the entity has legal personality or the obligation to file taxes,

– jurisdiction of place of management, and

– jurisdiction of a regular place of business, including a branch.

For individuals, the relevant nexus tests are:

– jurisdiction of tax residence, and

– jurisdiction of a regular place of business.

RCASPs must obtain self-certifications from their users to determine their tax residency and reportable status, using the following information:

– first and last name;

– residence address;

– jurisdiction or Member State(s) of residence for tax purposes;

– TIN of each reportable person in respect of each jurisdiction or Member State;

– date of birth.

Guidance on Reporting obligations of Reporting Crypto-Asset Service Providers