Crypto-Asset: What crypto investors in Germany need to know

In future, crypto exchanges and other crypto service providers will be required to report detailed information about their customers and transactions to the tax authorities. The Crypto-Asset Reporting Framework – CARF for short – is also intended to ensure that this information is exchanged internationally between tax authorities.

For German crypto investors, this means that transactions carried out on foreign crypto exchanges may also be automatically reported to the German tax authorities in future.

The following questions are particularly common:

What should you do if you have not declared crypto gains from previous years?
What crypto information will be reported to the tax authorities?
Will wallet addresses also be reported?
Which crypto exchanges are subject to the reporting requirements?
Which countries participate in the exchange of information under CARF?
From when will the tax authorities receive this information?

CARF explained: What is the Crypto-Asset Reporting Framework?

The Crypto-Asset Reporting Framework (CARF) is an international reporting standard for crypto-assets developed by the OECD.

CARF requires certain crypto service providers to:

identify their customers for tax purposes
determine their customers’ tax residence
record certain crypto-asset transactions
report this information to the relevant tax authority

The tax authorities then generally exchange this information with the country in which the user is tax resident.

As a result, a German investor may in future also appear in the records of the German tax authorities, even if their crypto transactions were carried out through a foreign exchange or platform.

Germany signed the Multilateral Competent Authority Agreement (MCAA) for CARF on 26 November 2024. The agreement itself had already been developed by the competent authorities on 8 June 2023.

What is the current status of the CARF legislative process in Germany?

On 24 March 2026, the German Federal Ministry of Finance first published a draft bill to approve the multilateral CARF agreement.

A bill approved by the German Federal Government has now been published. It was submitted to the Bundesrat (Federal Council) in May 2026 and registered as Bundesrat document 336/26. The deadline for the Bundesrat to provide its opinion expired on 10 July 2026. At that time, the legislative process had not yet been completed.

The proposed law mainly provides Germany’s domestic approval of the international agreement. It therefore creates the legal basis for Germany to exchange information collected under CARF with participating non-EU countries.

It is important to distinguish between:

the obligation of crypto-asset service providers to collect and report information, and
the subsequent international exchange of that information.

What is the difference between CARF and DAC8?

DAC8 is a European directive that expands the exchange of tax information within the European Union. It requires EU Member States to introduce reporting obligations for crypto-asset service providers.

CARF, by contrast, is the OECD’s international reporting standard. It is designed in particular to enable the exchange of information with countries and jurisdictions outside the European Union.

Germany has already introduced the corresponding domestic reporting obligations through the Crypto-Assets Tax Transparency Act (Kryptowerte-Steuertransparenz-Gesetz) of 22 December 2025. The CARF Approval Act currently under consideration is intended to provide the additional legal basis for exchanging this information with participating countries and jurisdictions outside the European Union.

In simple terms:

Crypto-Assets Tax Transparency Act (Kryptowerte-Steuertransparenz-Gesetz): domestic reporting and due diligence obligations in Germany
DAC8: exchange of information within the European Union
CARF: international exchange of information, particularly with countries and jurisdictions outside the European Union

From when will crypto-asset information be reported to the tax authorities?

Under the proposed implementation timeline, the new reporting obligations are generally expected to apply for the first time to transactions carried out from the 2026 calendar year onwards. However, this is currently still an assumption. The actual scope of the information reported will only become clear once the tax authorities begin their initial evaluations.

The first regular international exchange of this information is currently expected to take place in 2027. Numerous countries and jurisdictions have committed to implementing CARF in time for the exchange of information to begin by 2027.

This does not, however, mean that earlier tax years are of no relevance to the tax authorities.

If the information reported for 2026 indicates that accounts, wallets or trading activities have existed for a longer period, the tax authorities may also review earlier tax years and request further information.

What information must crypto exchanges report to the tax authorities?

Crypto-asset service providers do not report only account balances or portfolio values. They must also report personal identification details together with information on certain crypto-asset transactions.

Personal information about the crypto user

The following information may be reported for individual taxpayers in particular:

first and last name
residential address
country or countries of tax residence
tax identification number (TIN)
date of birth
place of birth, where applicable
other information required for unique identification

For companies and other legal entities, additional information about the beneficial owners may also be required.

This is intended to prevent crypto-asset transactions from escaping tax attribution through the use of companies or other intermediary legal entities.

Transaction information reported by crypto exchanges

The reportable transactions may include in particular:

purchases of crypto-assets using euros or other fiat currencies
sales of crypto-assets for fiat currencies
exchanges between different crypto-assets
transfers to other exchanges or wallets
transfers to self-hosted wallets
the number or quantity of tokens transferred
the total value of purchases and sales
gross proceeds from disposals
acquisition costs, where applicable
the number of individual transactions

For example, exchanging Bitcoin for Ether or one token for a stablecoin may be treated economically as a disposal of the crypto-asset given up and an acquisition of the crypto-asset received.

For reporting purposes, the amounts are generally valued in a fiat currency. The information is usually reported on an annual basis and aggregated by the respective type of crypto-asset.

Are staking, lending and airdrops also reported?

Transactions relating to the following may also be reportable:

staking
lending
airdrops
crypto loans
DeFi applications
other reward or compensation models

may also be identifiable in the reported data.

Whether and in what form a particular transaction is reported depends on how the relevant crypto-asset service provider is involved in the transaction and how the transaction is classified under the CARF rules.

The reporting itself does not determine the German tax treatment. The tax treatment must still be assessed in accordance with German tax law.

For example, staking rewards, lending income, airdrops and token swaps may each be subject to different tax treatment, even though they may initially appear in the platform data simply as incoming or outgoing transactions.

Are wallet addresses reported to the tax authorities?

Not every individual wallet address is automatically included as standard information in the annual CARF report.

CARF does, however, provide that transfers to so-called unhosted or self-hosted wallets may be reported separately. In particular, the number of units transferred and the total value of those transfers may be included in the report.

This enables the tax authorities to identify when crypto-assets have been transferred from an exchange to an external wallet.

The specific public wallet address is not necessarily included in every regular annual report under the OECD framework. However, it may:

be known to the crypto-asset service provider
be stored in the provider’s internal transaction records
be disclosed in response to a specific information request from the tax authorities

Transferring crypto-assets to a hardware wallet or another self-hosted wallet does not make the transaction invisible for tax purposes.

Can the tax authorities identify transfers between your own wallets?

A transfer between two of your own wallets does not, in itself, generally constitute a disposal for tax purposes.

From a crypto exchange’s records, it may initially only be apparent that crypto-assets have been transferred from the platform to an external wallet address. Whether the destination wallet also belongs to the investor cannot necessarily be determined from that information alone.

For crypto investors, it is therefore becoming increasingly important to maintain clear records demonstrating ownership of their wallets and documenting transfers between their own wallets.

If this documentation is missing, there is a risk that:

transfers between your own wallets cannot be clearly identified
acquisition costs can no longer be reliably traced
deposits and withdrawals cannot be matched correctly
apparent discrepancies arise between the platform reports and the tax return

Which crypto-assets are covered by CARF?

The definition of reportable crypto-assets is broad.

This may include, in particular:

Bitcoin
Ether
altcoins
stablecoins
certain utility tokens and investment tokens
tokenised assets
certain non-fungible tokens (NFTs)
crypto-assets that can be used for payment or investment purposes

Not every NFT or digital asset automatically falls within the scope of CARF. One of the key factors is whether the asset can be used for payment or investment purposes.

Central bank digital currencies (CBDCs) and certain e-money products are generally not covered by CARF. Instead, they are intended to fall within the scope of the expanded Common Reporting Standard (CRS) rules.

Which crypto-asset service providers are required to report information?

The reporting requirements do not apply only to traditional crypto exchanges.

The reporting requirements may apply in particular to:

centralised crypto exchanges
crypto brokers
providers that exchange crypto-assets on behalf of customers
certain wallet providers
operators of crypto trading platforms
other service providers that carry out reportable crypto-asset transactions for or on behalf of customers

What matters is not the name or label of the business, but the activities it actually performs.

Decentralised or internationally operating business models may also fall within the scope of the reporting requirements where a legal entity or an individual acts as a reportable crypto-asset service provider.

Which countries participate in the CARF exchange of information?

Many countries and jurisdictions have committed to implementing CARF or have already signed the Multilateral Competent Authority Agreement (MCAA).

This includes, among others:

Germany
most EU Member States
the United Kingdom
Switzerland
Liechtenstein
Norway
Iceland
Canada
Japan
South Korea
Singapore
Brazil
Chile
Costa Rica
Colombia
South Africa
the United Arab Emirates
New Zealand
the Cayman Islands
Jersey
Guernsey
the Isle of Man
Gibraltar

However, a political commitment or signature alone does not automatically result in an effective exchange of information between two countries.

An effective exchange relationship generally requires that:

both countries have implemented CARF in their domestic law
the required declarations and notifications have been submitted
both countries have activated the relevant exchange relationship

The list of countries with which Germany exchanges crypto-asset information may therefore change over time.

Does every foreign crypto exchange automatically report information to Germany?

No. A foreign crypto exchange does not automatically report information to Germany simply because German customers use the platform.

Whether information is reported depends in particular on the following factors:

the country in which the provider is subject to reporting obligations
whether that country has implemented CARF or comparable rules
whether an effective exchange relationship exists with Germany
whether the user has been identified as tax resident in Germany

Providers operating within the European Union may also be subject to reporting obligations under DAC8.

Even if a country does not yet participate in the automatic exchange of information under CARF, the German tax authorities may still be able to obtain information through other international administrative assistance mechanisms or individual requests for information.

Does the tax office automatically calculate your crypto gains based on CARF data?

No. The reported amounts do not automatically correspond to the taxable crypto gains under German tax law.

CARF primarily provides the tax authorities with verification and transaction data. This may include, for example, gross disposal proceeds, transaction volumes, deposits and withdrawals.

To calculate the taxable gain, the following factors must also be taken into account:

individual acquisition costs
acquisition dates
disposal dates
holding periods
transaction fees
transfers between your own wallets
lost or worthless tokens
the relevant category of income
whether the activities constitute private asset management or a commercial business

A reported transaction volume of, for example, one million euros does not therefore mean that a taxable gain of one million euros has been realised.

However, the tax authorities may compare the reported information with the tax return and request additional documentation if discrepancies are identified.

What discrepancies may be identified by the tax authorities?

The automatic exchange of information may, in particular, reveal indications of the following:

undeclared crypto disposals
undeclared crypto-to-crypto exchanges
undisclosed foreign crypto exchanges
unreported staking or lending income
transfers to previously undocumented wallets
discrepancies between tax reports and exchange data
high transaction volumes despite no corresponding information in the tax return
inconsistent information regarding tax residency
incomplete reporting of trading activities from previous years

Such discrepancies may lead to requests for information, enquiries by the tax authorities, tax audits or, in some cases, criminal tax investigations.

Can CARF also affect previous tax years?

The regular CARF reporting requirements are generally intended to cover only the designated reporting periods.

Nevertheless, the reported information may give the tax authorities reason to examine earlier tax years as well.

For example, the following may prompt further review:

long-standing user accounts
substantial opening balances
historical deposits
transfers from previously unknown wallets
missing acquisition cost records

These may indicate that tax-relevant transactions already took place in earlier tax years.

The tax authorities may then request additional documentation or review tax returns from earlier years.

What should crypto investors review now?

Crypto investors should not wait until they receive a letter from the tax authorities before organising their records.

In particular, the following should be reviewed:

Have all crypto exchanges, brokers and wallets been fully accounted for?
Are complete transaction histories available?
Have closed or inactive exchange accounts been taken into account?
Are transfers between your own wallets clearly identified?
Can the acquisition costs of all disposed crypto-assets be substantiated?
Have staking, lending, mining, airdrops and DeFi transactions been included?
Do the opening and closing balances reconcile?
Have all foreign crypto exchanges been taken into account?
Does the crypto tax software output match the original transaction data?
Have all tax-relevant years been reported correctly?

Crypto tax software can assist with preparing your records. However, its results are only as reliable as the imported data and the underlying tax treatment applied.

What should you do if crypto gains have not been declared for tax purposes?

Anyone who discovers that previous tax returns were incorrect or incomplete should not simply report individual gains without first obtaining a proper review of their overall tax position.

The first step is to determine whether:

there is an obligation to correct the tax return under Section 153 of the German Fiscal Code (Abgabenordnung – AO), or
a voluntary disclosure under Section 371 AO may be required because of potential intentional tax evasion.

To be effective, a voluntary disclosure must, in particular, be complete. As a general rule, it must cover all non-time-barred tax offences relating to the relevant type of tax.

A disclosure limited to individual exchanges, wallets or tax years may therefore be insufficient.

In addition, the exemption from criminal liability may no longer be available if a statutory exclusion has already taken effect. This may be the case, for example, where certain tax audit measures have begun, criminal tax proceedings have been formally initiated, or the tax offence has already been discovered.

Should you wait until CARF reporting begins before correcting your tax position?

No. If you discover errors in your tax affairs, you should not wait until the tax authorities receive the CARF data before taking action.

The sooner the matter is reviewed in full, the better the following can be addressed:

obtain missing transaction records
reconcile wallets and exchange accounts
determine taxable gains
assess whether there is an obligation to correct previous tax returns or make a voluntary disclosure
reduce potential criminal tax risks

Once a formal request for information has been received or tax or criminal tax proceedings have been initiated, the available legal options may become more limited.

How should crypto records be documented for the tax authorities?

A robust set of records should, where possible, include:

complete transaction records from all crypto exchanges
all wallet addresses and, where applicable, documentation showing wallet ownership
deposit and withdrawal records
evidence of transfers between your own wallets
acquisition and disposal dates
historical valuations and valuation methods
transaction fees
staking and lending statements
airdrop and mining records
tax reports together with the underlying calculation methodology

Providing only a summary tax report may be insufficient if the underlying transactions cannot be traced and verified.

Crypto investors should be aware of this: CARF significantly increases transparency in relation to crypto-assets.

CARF does not introduce new tax rules for Bitcoin or other crypto-assets. The applicable tax treatment continues to be determined under German tax law.

The main change is the increasing availability of standardised reporting data.

Crypto exchanges and other crypto-asset service providers are required to collect information about users and their transactions. This information is then intended to be exchanged internationally between tax authorities. As a result, foreign exchange accounts and transfers to external wallets may also become visible to the German tax authorities.

As a result, crypto investors face an increased risk that undeclared or incompletely declared tax matters may be identified by the German tax authorities.

Anyone who identifies uncertainties in previous tax returns should have their records reviewed thoroughly and at an early stage.

ACCONSIS supports you with crypto tax matters, tax corrections and voluntary disclosures

ACCONSIS advises private investors, business owners and crypto investors on the tax review and assessment of their crypto transactions.

Our advisory services include, in particular:

reviewing the completeness of exchange and wallet records
reconciling different crypto tax reports
assessing the tax treatment of trading, staking, lending, mining, DeFi and NFTs
reviewing transfers between your own wallets
calculating taxable crypto gains
correcting incomplete tax returns
preparing and submitting voluntary disclosures to seek exemption from criminal liability
assisting with requests for information from the tax authorities
representing clients during tax audits and criminal tax proceedings

Have you omitted crypto transactions from previous tax returns, or are you concerned that they may not have been reported in full? If so, you should have your tax position reviewed before the German tax authorities take action following a report under CARF or a formal request for information.