Form 1099-DA – Guide 2025 to 2026 for CPA Firms and Brokers

You know that uneasy feeling when the calendar turns to January and your team is already stretched, then a wave of crypto transactions hits the queue. Last year a partner told me, “We did not lose clients, we lost our grip on delivery.” If you are a CPA firm or a digital asset broker, Form 1099-DA is the new pressure point. The form itself is not hard, the delivery system behind it is. This guide gives you the plain‑English rules, the 2025 to 2026 changes, and the operational playbook so you can keep quality high without burning out your team.

Quick note, this is general information, not tax advice. Confirm details with your tax advisor and review the official IRS guidance linked throughout.

Key Takeaways

• First required year. Brokers must report digital asset sales on Form 1099-DA for transactions effected on or after January 1, 2025, with forms furnished and filed in early 2026.
• 2025 content. For 2025 sales, brokers report gross proceeds per sale. Basis reporting is permitted but not required, with transitional penalty relief if you make a good faith effort.
• 2026 shift. Beginning January 1, 2026, brokers must report both gross proceeds and basis for covered digital assets, generally those acquired after 2025 and held in custody.
• Who is a broker. In scope are custodial exchanges, certain hosted wallet providers, certain processors of digital asset payments, and kiosk operators, among others. The IRS did not finalize rules that would have treated non‑custodial DeFi participants as brokers.
• Extra relief. The IRS issued transitional relief for 2025 reporting, and later extended parts of the backup withholding relief into 2026 and 2027. Build processes now, then refine as guidance evolves.

What Is Form 1099-DA and Why It Matters

Form 1099-DA is the IRS information return that standardizes reporting for digital asset sales and certain exchanges. It parallels parts of Form 1099‑B, bringing crypto, stablecoins, and certain NFTs into a familiar reporting framework so taxpayers can compute gains and losses and the IRS can match data. In 2025 you focus on gross proceeds, and in 2026 you add basis for covered assets, which tightens accuracy, reduces reconciliation drama, and clarifies audits.

The final regulations implement the Infrastructure Investment and Jobs Act changes to section 6045. They apply first to brokers that actually take possession of customers’ digital assets or otherwise meet specific in‑scope roles. That design limits scope to entities that typically have the data to report, while setting a clear path for phased adoption across 2025 and 2026.

Why this matters for delivery. Once recipient statements start going out, your clients and the IRS will compare numbers. Missing basis, inconsistent asset descriptions, or late forms create support tickets and rework at the worst possible time. When we help firms prepare, we focus less on “what is the box” and more on “how do we never touch this file twice.” That mindset is what turns 1099‑DA into routine work instead of a fire drill.

Who Must File and Who Receives Form 1099-DA

If you are a U.S. digital asset broker, you file a Form 1099‑DA for each sale you effect starting with transactions on or after January 1, 2025, and you furnish copies to customers in early 2026. “Sale” includes dispositions for cash, different digital assets, certain broker services, and, beginning in 2026, specified real estate transactions handled by a real estate reporting person.

Which Entities Are Brokers

You are generally a broker if, in the ordinary course of business, you stand ready to effect sales of digital assets for others and you have or can know the required information. In scope are operators of custodial trading platforms, certain hosted wallet providers, certain processors of digital asset payments, and digital asset kiosk owners. The IRS did not finalize the portions that would have treated certain non‑custodial DeFi participants as brokers.

Practical translation. If you hold customer assets, process their sell orders, or execute redemptions in a way that gives you transaction details and identities, you likely have a filing obligation. If you are a miner, node operator, or pure software developer with no customer relationship or identity data, you generally are not a broker under the finalized rules.

Required Filers for 2025

For 2025 transactions, brokers file Form 1099‑DA that shows gross proceeds per sale. Basis reporting can be provided voluntarily. The IRS has offered transitional penalty relief for brokers that make a good faith effort on 2025 reporting, which recognizes that many teams are still building systems and SOPs.

Who Receives the Form

Customers who sell through a broker receive a recipient statement. There is no de minimis gross proceeds threshold in the general rule set, and, as with other information returns, brokers must retain records and apply backup withholding if required, subject to transitional relief discussed later in this guide.

Reporting Rules For 2025

Here is the clean version of what you must do for 2025 sales. If you effect a sale of a digital asset for a customer in 2025, you file Form 1099‑DA and you furnish a recipient copy to that customer on the standard early‑season timetable in 2026. The headline is simple, you report gross proceeds per sale. Basis reporting is optional in 2025, and there is transitional penalty relief for good faith efforts. That relief does not excuse poor processes, it buys you time to build them.

What this means in practice:

• Capture every sale your platform or desk effects in 2025, no de minimis threshold.
• Standardize asset descriptions so reviewers do not guess which token or NFT is in scope.
• Store transaction IDs, trade timestamps, gross proceeds, fees if applicable, and the wallet or subaccount that initiated the sale.
• If you choose to provide optional basis in 2025, label it clearly and track how you computed it so you can explain variances later.

We have seen firms struggle when gross proceeds are correct but the naming is inconsistent. One client had “ETH,” “Ether,” and “Ethereum” across different files. Reviews slowed, customers asked questions, and the help desk lit up. A simple naming table and a locked list solved it. Your reviewers will thank you.

Filing, Furnishing, And Withholding

• File 1099‑DA with the IRS and furnish recipient copies to sellers who disposed of digital assets through you in 2025.
• Maintain TIN validation processes and backup withholding procedures. Transitional relief applies in 2025, but you still need a plan for missing or invalid TINs so you are ready when relief ends.
• Keep retention copies and a correction workflow ready. Corrections are inevitable the first year, and a clear path reduces support tickets.

Tip, for 2025, draft your correction playbook before forms go out. Define who checks the ledger, who reissues corrected statements, and how you notify customers. Document once, reuse for peak season.

Changes Coming In 2026 And Beyond

Starting with sales on or after January 1, 2026, you move from proceeds‑only to proceeds plus cost basis for covered digital assets. Covered usually means assets you custody that were acquired after 2025. Noncovered assets do not require basis, though you may choose to show it. Expect indicators for covered versus noncovered status, along with flags for qualifying stablecoins and specified NFTs. The intent is to give taxpayers a complete picture of gain or loss without manual spreadsheets.

Here is a quick side by side.

Requirement	2025 Sales	2026 Sales And After
Gross proceeds	Required per sale	Required per sale
Cost basis	Optional, penalty relief for good faith	Required for covered digital assets
Covered status	Not applicable	Must indicate covered or noncovered
Stablecoins and specified NFTs	Optional methods may apply in setup, basis may be excluded	Optional methods continue, follow instructions
Backup withholding	Transitional relief applies	Relief narrows, be prepared to apply rules
Furnish and file timing	Early 2026	Early following year, ongoing

Why this matters. Basis without clean acquisition data is guesswork. In 2025, build the data trails you will rely on in 2026. That means acquisition date capture, custody status at time of acquisition, corporate actions history, and fee treatment. If you do not create that spine now, next year becomes a scramble.

Covered Versus Noncovered In Plain English

• Covered, you custodied the asset, the customer acquired it after 2025, you have the information needed to compute basis, and you report basis.
• Noncovered, the asset is outside those parameters, often because it was acquired before 2026, moved in without basis detail, or you did not custody at acquisition. You generally report proceeds, and you may optionally show basis with a noncovered indicator.

What Information Gets Reported On 1099‑DA

The form tracks the details of each sale you effect. Expect fields for:

• Asset description, for example ETH, USDC, an identified NFT collection and token ID where required.
• Acquisition date and disposition date.
• Gross proceeds per sale.
• Cost basis for covered assets starting in 2026.
• Indicators for covered versus noncovered, plus any special categories such as qualifying stablecoin or specified NFT.
• Customer and broker identifiers required under the general instructions.
• Any adjustments or relevant codes described in the instructions.

Common Pitfalls To Avoid

• Mixing wallets and accounts in descriptions, which confuses reviewers.
• Using inconsistent date formats, which breaks imports into tax software.
• Omitting documentation of corporate actions, such as token redenominations or chain migrations, which creates basis disputes the following year.
• Forgetting to lock naming conventions, which leads to near‑duplicate assets that look different to your team.

If a detail can alter proceeds, basis, or holding period, write down how you capture it today. Then verify your team can reproduce the same result two weeks from now under deadline pressure.

Broker Definition, Who Is In Scope, And Who Is Not

You are a digital asset broker if, in the ordinary course of business, you stand ready to effect sales of digital assets for your customers. In scope are custodial exchanges, hosted wallet providers that facilitate customer dispositions, digital asset payment processors that convert customer assets to cash for settlement, and kiosk operators that buy or sell digital assets for the public. If you hold customer assets and execute their sell orders, you likely have the data and the duty.

Who is generally out of scope. Miners, node operators, and software developers that do not have customer relationships or identity data are typically not brokers under the current rules. Sales from unhosted wallets usually do not generate a 1099‑DA because no broker is standing ready to effect the sale for that wallet.

Quick Reference Table

Role	Typical Status For 1099‑DA
Custodial exchange	In scope, files 1099‑DA
Hosted wallet provider that effects customer sales	In scope, files 1099‑DA
Digital asset payment processor converting to cash	In scope, files 1099‑DA
Kiosk operator buying or selling for the public	In scope, files 1099‑DA
Real estate reporting person	Separate rules, watch 2026 crossover treatment
Miner, validator, node operator with no customer identity data	Generally not in scope
Pure software developer, open source tool maintainer	Generally not in scope
Unhosted wallet user selling peer to peer	No broker, no 1099‑DA generated

Operations Playbook, How To Deliver 1099‑DA Without Chaos

The form is new, the delivery problems are not. Firms get stuck in review loops, documentation gaps, and seasonal capacity hits. Use this playbook to stay in control.

• Standard operating procedures Write SOPs for intake, classification, preparation, review, corrections, and customer communications. Keep them short, step based, and visible in your workflow tool.
• Structured workpapers Create a standardized folder tree and file naming rules. Include a naming table for assets, chain tickers, and collections. Lock it. Place a “read me” index in each engagement folder that points to source data and decision logs.
• Multi‑layer review Use a preparer, then a senior, then a quality reviewer for the first cycle. After the first 50 returns, analyze error types and collapse steps where risk is low.
• Turnaround SLAs Define time boxes for intake to prep, prep to review, review to furnish. Publish them to your team and to internal stakeholders. A timer focuses the work and signals when to escalate.
• Workflow visibility Use a kanban or list view that shows status, owner, countdown to deadline, and blockers. Color code items that need data from customers.
• Escalation control When a blocker hits, move it to an escalation lane with a named owner, a timestamp, and the next action. Do not let stalled items sit in the main queue.
• Capacity planning Model peak weeks and allocate people by utilization, not gut feel. If you need extra hands, add them early so they train on your SOPs before the wave hits.
• Continuity plans Assume one key person will be out during peak. Cross train now and document the handoff steps.

Where An Offshore Team Makes Sense

If your internal team is buried in prep, bring in a trained offshore unit that works inside your systems and templates. The key is structure. Candidates should arrive with U.S. accounting training, understand 1099 workflows, follow your SOPs, and respect your review notes. At Accountably, we focus on controlled delivery rather than resume farming, which keeps partner time out of rework and inside client strategy. Mention us only when it helps your reader, the point is to protect your delivery, not to sell staffing.

The short test, can a new team member open the folder, follow the index, and produce the same answer as your senior? If yes, you are ready for peak season. If not, tighten the SOPs and the naming rules.

Data And Security Checklist

• Central asset naming list, version controlled.
• Customer identity records with TIN validation steps.
• Trade capture with timestamps, asset, quantity, gross proceeds, wallet, and fees.
• Acquisition history and transfer in logic for basis starting in 2026.
• Corporate actions ledger, for redenominations, chain migrations, and token swaps.
• Ticketed correction workflow, who requests, who fixes, who approves.
• Role based access, secure VPN, zero local storage, encrypted file exchange, audit logs.

A little discipline here prevents most review issues later. This is the quiet work that saves you hours.

Resources And Latest IRS Updates

Use these official resources as your first stop. Keep them bookmarked and update your internal SOPs when instructions change.

• IRS Form 1099‑DA page, form, fillable Copies B, 1, and 2, and instructions.
• General Instructions for Certain Information Returns.
• Treasury decision and final regulations implementing digital asset broker reporting.
• Notice 2024‑56 and related transitional relief for 2025.
• Any subsequent notices on backup withholding timing and scope.

When rules change, note the effective date in your SOP header. For example, “Updated November 5, 2025, to reflect basis requirements for covered assets effective for 2026 sales.” That one line helps reviewers know which logic to apply.

Frequently Asked Questions

What is Form 1099‑DA?

It is an IRS information return that reports sales and certain dispositions of digital assets. Brokers file it with the IRS and furnish copies to customers, which supports accurate gain or loss reporting on tax returns.

Who will receive a 1099‑DA?

You receive a 1099‑DA if you sold digital assets through a broker in 2025 or later. Sales from unhosted wallets usually do not produce a form because there is no broker in the middle. Mining income, staking rewards, and airdrops are reported elsewhere or self reported.

Are DeFi platforms brokers?

Under current finalized rules, many noncustodial DeFi participants are not treated as brokers. If a platform does not hold customer assets and does not have customer identity information, it is generally out of scope. Watch for future guidance if that changes.

What about stablecoins and NFTs?

There are special categories for qualifying stablecoins and specified NFTs. The rules can allow different basis handling or indicators, especially starting in 2026. Your SOP should include how you classify these assets so reviewers apply the same logic every time.

Do I need to provide basis in 2025?

No, basis is optional in 2025 with transitional relief on penalties for good faith efforts. You will need basis for covered assets starting with 2026 sales, so build the data capture now.

What if I get a wrong form?

Ask your broker for a corrected 1099‑DA. Keep your own records of trades, deposits, withdrawals, and fees. If you are a CPA firm preparing a return, reconcile the form to the ledger and document any differences for your files.

Quick Internal Checklist For Teams

• Confirm whether you are a broker under the current definition.
• Map data sources for proceeds, basis, and identity.
• Draft and publish SOPs that match the 2025 to 2026 rules.
• Build a correction workflow and a customer communication template.
• Test your process on a sample of tricky trades, for example transfers in with missing basis, redenominations, and cross chain moves.
• Train your preparers and reviewers on naming, timing, and escalation.

Conclusion, Make 1099‑DA Boring

You now have the blueprint, who files, who receives, what data goes on the form, and exactly how 2025 differs from 2026. Treat this like any high volume process. Standardize the inputs, control the handoffs, and measure the outputs. If you build the structure in 2025, 2026 basis reporting becomes routine rather than a sprint.

If your firm needs a disciplined offshore unit that works inside your systems, with standardized workpapers and multi layer review, our team at Accountably can help you create capacity without chaos. Whether you work with us or not, put the SOPs in place, name your files the same way every time, and protect your reviewers. That is how you meet deadlines without burning out your team.