Form 1099-DA Reporting: Broker Scope, Box Rules and the IRIS Route

Form 1099-DA reporting rests on a two-step start date set by Treasury Decision 10000, published on 9 July 2024: US digital asset brokers report gross proceeds for sales effected on or after 1 January 2025, and adjusted basis for covered digital assets sold on or after 1 January 2026. Sales effected in 2026 are therefore the first for which a custodial broker’s return has to carry, for covered digital assets, acquisition dates, cost basis and a short-term or long-term gain classification, on top of the proceeds it already reported for 2025.

The filing channel moved at the same time. The IRS’s Publication 1220 states that its FIRE system does not accept Form 1099-DA, so a broker over the electronic filing threshold sends the return through the Information Returns Intake System (IRIS). Each calendar year runs on a fixed clock: recipient statements by 15 February, the IRS copy by 28 February on paper or 31 March electronically.

The return is built per sale and per customer, and one disposal can produce up to four separate forms. The transitional relief that eased the first year was drafted mainly around specific calendar years, and most of what remains concerns backup withholding, including three exemptions that last until further guidance is issued.

Related reading: CARF: The New Global Tax Reporting Framework for Crypto

Legal basis for Form 1099-DA: section 6045 and Treasury Decision 10000

Section 6045(a) of the Internal Revenue Code requires every person doing business as a broker to make a return to the IRS showing each customer’s name and address, gross proceeds and other information the Secretary requires by regulation. Section 80603 of the Infrastructure Investment and Jobs Act (Public Law 117-58) brought digital assets into that regime: it widened the broker definition to cover any person who, for consideration, is responsible for regularly providing any service effectuating transfers of digital assets on behalf of another person, and it extended basis reporting to all digital assets.

Treasury and the IRS implemented the reporting rules through T.D. 10000, “Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions”, published at 89 FR 56480 on 9 July 2024 and effective on 9 September 2024. The operative rules sit in Treasury Regulations section 1.6045-1, which the form instructions cite paragraph by paragraph: 1.6045-1(g)(4)(i)(A) for the US digital asset broker definition, 1.6045-1(d)(10) for the stablecoin and NFT optional methods, 1.6045-1(c)(8) for assets that are both digital assets and securities.

The form-level authority is the IRS’s annual Instructions for Form 1099-DA. The 2026 edition carries a document date of 18 February 2026, the IRS publication index records a posting date of 28 April 2026, and it tells filers to read it together with Publication 1099, the General Instructions for Certain Information Returns, which carries the common rules on who files, when and where, electronic filing, corrections, taxpayer identification numbers (TINs), backup withholding and penalties.

What the April 2025 disapproval resolution removed

Public Law 119-5, approved on 10 April 2025, disapproved the IRS rule titled “Gross Proceeds Reporting by Brokers That Regularly Provide Services Effectuating Digital Asset Sales”, published at 89 FR 106928 on 30 December 2024, and provides that the rule has no force or effect. That resolution names one rule. T.D. 10000 is a separate Treasury Decision, and both the 2025 and 2026 Form 1099-DA instructions still refer filers to it for further guidance. A compliance team that reads “the broker rule was repealed” as covering custodial platforms has the wrong instrument.

Penalties run under section 6721 (failure to file a correct information return by the due date) and section 6722 (failure to furnish a correct payee statement). Section 6721 applies per information return, with the penalty amount determined by when the correct return is filed. Section 6722 applies separately per payee statement, with the amount determined by when the correct statement is furnished. The IRS publishes penalty amounts by the year of the applicable due date. For returns due in 2026 it lists $60 per return up to 30 days late, $130 from day 31 through 1 August, $340 after 1 August or if never filed, and a $680 minimum per return for intentional disregard, for which Publication 1099 sets no maximum. Publication 1099 also sets a lower annual maximum for small businesses with average annual gross receipts of $5 million or less over the three most recent tax years.

Who must report on Form 1099-DA, and who drops out of scope

The instructions define a broker as any person who, in the ordinary course of a trade or business, stands ready to effect sales of digital assets to be made by others. Two routes lead into that definition: a person that regularly offers to redeem digital assets it created or issued, and a person that effects dispositions of customers’ digital assets as an agent, a dealer or a digital asset middleman.

The middleman route is where the perimeter widens beyond trading platforms. It covers owners or operators of one or more digital asset kiosks, processors of digital asset payments (a broker that regularly receives digital assets from one party and pays digital assets or cash to a second party) where they know or ordinarily would know the nature of the transaction and the gross proceeds from it, persons accepting digital assets as payment for broker services, and real estate reporting persons who know or ordinarily would know that the buyer paid in digital assets. It also covers persons that accept or process digital assets as payment for stock, commodities, regulated futures contracts, securities futures contracts, forward contracts, foreign currency contracts, debt instruments or options. Two activities fall outside it: providing only proof-of-work or proof-of-stake validation services, and providing only hardware or software that lets users control their own private keys.

The US digital asset broker test and branch treatment

Generally, only a US digital asset broker reports on Form 1099-DA. That is a US person other than its foreign branch or office, or a US branch described in Treasury Regulations section 1.1441-1(b)(2)(iv) that is treated as a US person, excluding a territory financial institution. A foreign branch of a US firm sits outside this definition. A US branch of a foreign firm falls within it only when it meets the specified section 1.1441-1(b)(2)(iv) treatment, excluding a territory financial institution. The instructions qualify the rule with “generally” and do not say when a non-US broker would report; that question goes back to the regulations.

The instructions set no entity-size threshold and offer no group or consolidated filing option. The return is prepared by the broker that effects the sale, for each customer and each transaction, and the account number becomes mandatory when the broker files more than one Form 1099-DA for a recipient who holds more than one account.

No general dollar floor, three narrow de minimis rules

Publication 1099’s chart lists the amount to report for Form 1099-DA as “See form instructions”, and the instructions start from “report all amounts attributable to a sale”. In place of a general dollar floor, three narrow de minimis rules apply, each tied to a specific activity:

• Processor of digital asset payments (PDAP) sales: no report where a customer’s PDAP sales for the year total $600 or less; above that, all of that customer’s sales are reported.
• Qualifying stablecoins under the optional method: no report of designated sales where the customer’s aggregate gross proceeds, after allocable transaction costs, do not exceed $10,000 for the year.
• Specified NFTs under the optional method: no report where the customer’s aggregate gross proceeds, after allocable transaction costs, do not exceed $600 for the year.

Customer-side exemptions and excluded transactions

Brokers may, but are not required to, file for exempt recipients, which include charitable organisations, IRAs, Archer MSAs and HSAs, the United States and its states and political subdivisions, corporations and other US digital asset brokers. Two carve-backs matter: a covered digital asset sold by an S corporation that acquired it after 2012 is still reported, and for covered securities acquired after 2011 a broker cannot rely on Treasury Regulations section 1.6049-4(c)(1)(ii)(A) to decide whether a customer is a corporation. The instructions give four alternative tests, such as a Form W-9 exemption certificate showing the customer is not an S corporation. Sales for exempt foreign persons, documented for example on Form W-8BEN, also need no return.

Notice 2024-57 removes six transaction types from reporting until Treasury and the IRS issue further guidance: wrapping and unwrapping, liquidity provider transactions, staking transactions, transactions market participants describe as lending of digital assets, transactions they describe as short sales, and notional principal contracts. That exception does not reach rewards or other compensation earned in those transactions, and the instructions separately say that rewards and staking payments are not reported on Form 1099-DA. Which return, if any, carries that income is a question the 1099-DA instructions leave open.

One non-example from the IRS’s own broker reporting FAQs: a custodian that only transfers a customer’s digital assets at the customer’s direction has not effected a sale, so the transfer creates no Form 1099-DA.

What the report contains: Form 1099-DA boxes, lots and identifiers

The default unit is one transaction per form. The instructions allow one combination: where a customer pays a broker fee using the same digital asset disposed of in the underlying trade, the fee disposal can be reported with the trade. Their example is a sale of 1 unit of Digital Asset A for ten units of Digital Asset B with a 0.1-unit fee in Digital Asset A, reported as one sale of 1.1 units. A fee paid in a different digital asset generally requires separate reporting. However, no separate Form 1099-DA is required for units the broker withholds from digital assets received in the underlying sale to pay the customer’s digital asset transaction costs, under Regulations section 1.6045-1(c)(3)(ii)(C).

Up to four forms for one disposal

A single sale is split across separate forms when it contains more than one of these categories:

• covered securities with short-term gain or loss;
• covered securities with long-term gain or loss;
• noncovered securities, where the broker checks box 9;
• first sales by a creator or minter, where specified NFTs are reported under the optional method.

The instructions work this through with a customer who bought units of the same digital asset in April 2022, April 2026 and August 2026 and sells all of them in one transaction in June 2027. The broker files three 2027 forms: short-term covered (August 2026 lot), long-term covered (April 2026 lot) and noncovered (April 2022 lot). A broker that voluntarily reports basis for the 2022 lot may fold it into the long-term covered form, but then it cannot check box 9 and becomes subject to section 6721 and 6722 penalties on that basis.

Covered versus noncovered: the status is fixed at acquisition

A digital asset is a covered security only if it was acquired after 2025, for cash, stored-value cards, different digital assets or other property or services, in an account for which the broker provided custodial services, and was held in that account until the broker effected the disposition. Everything else is noncovered, including any digital asset acquired before 2026, anything the broker did not hold in custody when it was acquired, and any digital asset transferred in to the broker. A token a customer bought on another platform in March 2026 and moved across in May 2026 is noncovered on the receiving platform.

Where a customer sells part of a position, the broker reports according to the customer’s adequate and timely identification of the units sold; absent identification at or before the sale, the earliest units acquired generally go first. Customer-provided acquisition information can be used to establish when units were bought for lot selection, but under current law it cannot be used to report basis or acquisition dates. Box 8 is checked whenever the broker received such information to identify which units were sold, even if it was not used for the lot on that form, until the customer has disposed of all the units that information covered.

Box-by-box rules for the numbered fields

Two unnumbered fields need separate attention. The account number is the number the broker assigns to the customer, and the instructions say expressly that it is not the customer’s wallet address. The “Applicable checkbox on Form 8949” field takes a one-letter code: G or J for short-term or long-term with basis reported to the IRS, H or K where basis is not reported, and Y where the holding period is unknown.

Currency, sign and rounding conventions

Amounts are reported in US dollars. Proceeds or purchase amounts paid in foreign currency are translated at the spot rate on the date the broker receives, credits or makes the payment, or under a reasonable spot rate convention such as a month-end or monthly average rate; for a digital asset traded on an established securities market in a foreign currency, the settlement date governs. Transactions denominated in a currency other than the US dollar also require the “Ordinary” box in box 6, alongside the short-term or long-term box, because they may be section 988 transactions for the customer. The instructions say nothing on rounding of dollar amounts; Publication 1099’s paper-form rules require dollars and cents with a decimal point.

Optional methods for qualifying stablecoins and specified NFTs

Qualifying-stablecoin eligibility must hold throughout the calendar year. The asset must target parity with one government- or central-bank-issued convertible currency, be accepted for payment beyond its issuer, and satisfy either prescribed stabilisation test. The first limits divergence from the reference currency to 3% over every consecutive 10-day period measured using UTC. The alternative requires regulation to oblige the issuer to redeem each unit at par, at any time, in that reference currency. The tax definition stands on its own. A token supervised under the federal stablecoin framework described in our note on Federal Reserve FR UU reporting for GENIUS Act stablecoin issuers qualifies for the 1099-DA optional method only if it passes these three tests.

Under the stablecoin method, only designated sales are reported (every sale of a qualifying stablecoin except a sale for different digital assets that are not qualifying stablecoins), aggregated per stablecoin type on a separate form once the customer passes the $10,000 threshold, with the total in box 1f. Specified NFTs reported under the NFT method go on a single form per customer once the $600 threshold is passed, with first sales by a creator or minter reported in box 11c on their own form. Either method removes the duty to report acquisition dates and basis even for covered units, and lets the broker leave boxes 1d, 1e, 1g, 1h, 1i, 2, 3a, 3b, 5, 6, 8, 9, 12a and 12b blank.

Deadlines for Form 1099-DA: the calendar-year cycle and its first dates

Form 1099-DA reports sales by calendar year. The due dates come from Publication 1099’s Guide to Information Returns and are the same every year:

When a due date falls on a Saturday, Sunday or legal holiday in the District of Columbia (or where the return is filed), the return or statement is timely on the next business day; the IRS publishes the actual dates for each year on its tax calendar. Brokers may furnish Form 1099-DA at any time up to the due date.

Form 1099-DA follows the Form 1099-B statement date. The general recipient date for Forms 1099 in the due-date tables is 31 January; Form 1099-DA sits with Forms 1099-B and 1099-S on 15 February, a difference a calendar copied from a generic 1099 template misses.

First and next reporting years

• Sales effected in 2025: first reporting year. Gross proceeds were mandatory; basis was voluntary, with no section 6721 or 6722 penalty for voluntarily reported basis, and code Y in the Form 8949 field where basis was not reported. Statements were due in February 2026 and electronic returns by 31 March 2026.
• Sales effected in 2026: first year of mandatory basis reporting for covered digital assets. 15 February 2027 is Washington’s Birthday, a federal holiday, so under the next-business-day rule statements fall due on 16 February 2027; electronic returns are due through IRIS on 31 March 2027.
• Sales effected in 2027: the last calendar year named in the current relief notices (see the caveats section below).

Submission through IRIS: the only electronic route for Form 1099-DA

Electronic filing is mandatory for any filer with 10 or more information returns in a calendar year, counted across all form types under T.D. 9972: four Forms 1099-NEC, two Forms 1042-S, two Forms 1095-B and two Forms W-2 already make ten in Publication 1220’s own example. Corrections do not count toward the threshold, but a return filed electronically has to be corrected electronically in the same system. A filer that cannot meet the requirement can ask for a waiver on Form 8508, filed at least 45 days before the due date.

The electronic Form 1099-DA filing specifications are maintained in IRS Publication 5718 for application-to-application (A2A) transmissions, Publication 5717 for the IRIS Taxpayer Portal, and the applicable IRIS XML schemas and business rules. Filers must use the specifications and schema versions applicable to their filing channel and processing year. Publication 1220 (Rev. 5-2026, for tax year 2025) specifies files for the FIRE system; it states that FIRE does not support electronic filing of Form 1099-DA and carries no 1099-DA record layout.

Both IRIS channels require an IRIS TCC. Publication 1099 says a typical TCC application is processed within 45 business days, so the application has to be in well before the March filing date. An A2A transmission consists of a manifest, one or more submissions and the records inside them. Each submission holds a single form type for a single tax year, and a transmission is flagged as original, correction or replacement (“O”, “C” or “R”) and cannot mix the three. Neither Publication 1220 nor the 1099-DA instructions set a file-naming convention for 1099-DA, and IRIS tracks each transmission by its Unique Transmission ID and the Receipt ID returned on receipt.

FIRE retirement and the state copy

Brokers that still file Forms 1099-B, 1099-INT or 1099-DIV through FIRE have to move those returns to IRIS as well. The IRS’s subsequent FIRE retirement notice sets earlier operational cut-offs: 1 November 2026 for test filings, 9 November 2026 for changes to FIRE Information Returns Applications for TCCs, and 19 November 2026 at 3 p.m. Eastern Time for filing information returns through FIRE. IRIS replaces FIRE for current-year, prior-year and corrected returns from January 2027. These dates come from the IRS FIRE retirement notice and IR-2026-99 (24 August 2026) and are earlier than the December 2026 window for updating TCC applications in the 7 May 2026 QuickAlert recorded in Publication 1220.

The IRS announced that Form 1099-DA is excluded from the Combined Federal/State Filing (CF/SF) Program for tax year 2025. Returns filed with the IRS are not forwarded to participating states, filers still have to meet each state’s digital asset reporting requirements directly, and the instructions for state boxes 14 to 16 do not apply until the form joins the program. Form 1099-DA is absent from the CF/SF lists in both Publication 1220 and Publication 5718, and the IRS has said only that it will announce future changes.

Recipient statements follow Publication 1099 and Publication 1179. A broker may be able to combine Forms 1099-DA, 1099-B, 1099-INT, 1099-OID and 1099-DIV on one substitute statement for the year, and may send one set of instructions covering all Form 1099-DA statements furnished to a recipient in a calendar year. For electronic furnishing, Publication 1099 sets general affirmative-consent rules; for statements required to be furnished on or after 1 January 2027, IR-2026-29 also permits brokers to follow the alternative proposed electronic-furnishing rules, which are not yet final.

Validation rules and rejection causes for Form 1099-DA filings

IRIS validates in layers. A transmission with a missing manifest or no submissions is rejected before a Receipt ID is issued; one that fails XML schema validation receives a Receipt ID and is then rejected; business rules then run at manifest, submission-header and form level, each family carrying its own prefix (Publication 5718 lists F1099BXXX among its examples of form-level rule IDs). Rules with the severity “Report Error and Reject if Over Threshold” can reject a whole submission when they fire too often. Publication 5718 also requires the submission header’s record count to match the records in the submission, rejects a submission whose header carries the wrong tax year, and rejects returns composed on a schema version superseded by a major schema change.

A status request returns one of six values: Accepted, Rejected, Processing, Partially Accepted, Accepted with Errors or Not Found. Accepted with Errors is still an acceptance: the transmission is on file, and the error list identifies the records to review for correction.

Replacements and corrections are different procedures

Rejected records are not kept in IRS data stores. For an eligible business-rule rejection of an original transmission or submission, resend the complete rejected unit as a replacement. Reference OriginalReceiptId for a transmission, or OriginalUniqueSubmissionId, comprising Receipt ID and submission ID separated by a pipe, for a submission.

An original rejected with an XML Schema Validation Error cannot be replaced: correct it and resend it as an original. Pre-receipt rejections require resubmission using the same transmission type. A rejected correction transmission follows the correction procedure and is not resubmitted as a replacement transmission. Publication 5718 gives a 60-day window: an acceptable replacement received within 60 days of the rejected status becoming available is treated as filed on the original receipt date, and one received later counts as filed when it arrives, which is the date late-filing penalties are measured against.

Corrections apply only to records that were Accepted or Accepted with Errors. Each corrected record is resent in full with CorrectedInd set to “1” and the UniqueRecordId of the original (Receipt ID, submission ID and record ID joined by pipes). Wrong amounts, codes, names or TINs take a one-step correction; a return that should not have been filed is corrected to zero. A return filed on the wrong form type needs two steps: a correction that zeroes the original, then a new original on the right form once the correction is accepted. An original is corrected once; a later correction references the most recently accepted one.

Content errors the instructions themselves rule out

Neither the instructions nor Publication 5718 publish a list of 1099-DA-specific business rule IDs; those arrive in the schema package. The instructions themselves fix several content rules, which apply whether or not an IRIS business rule tests them:

• box 9 checked on a covered security, or short-term and long-term results on the same form;
• box 2 checked on a return filed under an optional stablecoin or NFT method;
• -0- entered in box 1g for an asset whose basis was simply unknown;
• a truncated TIN on the IRS copy (truncation is allowed on payee statements only, and never for the filer’s own TIN).

Publication 1099 offers two safe harbors that limit exposure on small errors. A dollar amount within $100 of the correct figure, or withholding within $25, needs no correction unless the recipient elects a corrected statement. A broker that filed on time and files its corrections by 1 August avoids the incorrect-return penalty on the greater of 10 returns or 0.5% of the returns it was required to file for the year.

Caveats and interactions: relief notices, Form 1099-B overlap and other returns

Transitional relief comes from two notices. Most of it is tied to named calendar years, but three backup withholding exemptions in Notice 2024-56 have no end date. Notice 2024-56 (2024-29 I.R.B. 64) waived section 6721 and 6722 penalties for 2025 sales where a broker made good-faith efforts to file accurate and timely Forms 1099-DA, and waived backup withholding for 2025. Under its sections 3.03 to 3.05, backup withholding is also not required, until further guidance is issued, on any sale where the reportable proceeds are a specified NFT, on any digital asset for real property sale effected by a real estate reporting person, or on any PDAP sale effected by a processor of digital asset payments. Notice 2025-33 (2025-27 I.R.B. 4) extends sections 3.01, 3.02 and 3.06 of Notice 2024-56 by one year and adds relief for certain preexisting customers:

• no backup withholding on any digital asset sale effected in calendar year 2025 or 2026;
• for 2027 sales, brokers may rely on uncertified TINs of preexisting customers (accounts opened before 1 January 2026) if the name and TIN combination is confirmed through the IRS TIN Matching Program before the sale;
• for 2027 sales, no section 6721 or 6722 penalties and no backup withholding for preexisting customers the broker has not classified as US persons and whose file shows a non-US residence address;
• for 2027 sales of digital assets for different digital assets, other than specified NFTs, backup withholding is limited to what the broker receives on immediately liquidating 24% of the received digital assets, with penalty relief for any fall in value before liquidation.

Under section 3.01 of Notice 2025-33, as read here, the 2026 extension covers backup withholding only. The good-faith penalty relief in Notice 2024-56 is written for 2025 sales, and neither notice restates it for 2026, so returns for 2026 sales carry the ordinary penalty regime. Backup withholding, where it applies, is at the fourth-lowest rate under section 1(c), currently 24%, reported on Form 945 and in box 4.

Form 1099-B or Form 1099-DA for dual classification assets

A digital asset that is also a security reportable on Form 1099-B (a dual classification asset) generally goes on Form 1099-DA. Three exceptions send it elsewhere: section 1256 contracts on digital assets are reported on an aggregate basis on Form 1099-B (though a delivery of the underlying digital asset is a 1099-DA sale), assets that are digital assets solely because they clear or settle on a limited-access regulated network stay on Form 1099-B, and money market fund shares need no Form 1099-DA (Form 1099-B is optional). Tokenized securities, as defined in Treasury Regulations section 1.6045-1(c)(8)(i)(D), go on Form 1099-DA with the applicable identifying number and wash-sale adjustments where required. Average basis is available only for eligible securities, not every tokenized security. A broker’s average-basis default applies only in the absence of contrary customer instructions. For 2025 only, tokenized assets sold for cash could go on either form.

Other returns that touch the same transaction

For real estate transactions closing on or after 1 January 2026, the reporting person generally reports the buyer’s disposal of digital assets on Form 1099-DA and the seller’s real estate proceeds, including digital assets received, on Form 1099-S. These concern different parties rather than a choice between forms for the same report. Apply the relevant knowledge conditions, recipient exemptions and multiple-broker rules.

Form 8308 is not required where a broker is required under section 6045 to file Form 1099-DA for the transfer of a digital asset representing the partnership interest. For a reportable section 367(a) corporate action involving digital assets that are also stock, report the aggregate consideration in box 1f and the name of the exchanged digital asset in box 1b. Leave the other numbered boxes and the CUSIP box blank unless combining reporting under Regulations sections 1.6045-1 and 1.6045-3. Box 1g is completed where the broker combines reporting under sections 1.6045-1 and 1.6045-3 on one Form 1099-DA; in that case, its amount must not exceed box 1f.

T.D. 10000 discusses coordination with the OECD Crypto-Asset Reporting Framework, but Form 1099-DA and CARF remain distinct reporting regimes. EU entities must separately assess whether DAC8 reporting applies under the relevant national implementing legislation; our guide to CARF and DAC8 crypto reporting in Luxembourg covers the European filing. Anti-money-laundering rules for convertible virtual currency come from FinCEN, on a separate track from section 6045; our note on FinCEN’s withdrawn CVC mixing proposals covers that withdrawal.

Changes to Form 1099-DA reporting since 2024, and the dates ahead

The January 2026 corrections matter for anyone who built logic from the original 2025 instructions. The IRS added the de minimis section for PDAP, stablecoin and NFT sales and reworded the optional methods, including the rule that a broker using the stablecoin method does not report non-designated stablecoin sales. The broker reporting FAQs also flag that the 2025 box 11c text was wrong and will be corrected in future versions.

Three items remain open on the IRS’s own terms. The six transaction types in Notice 2024-57 stay outside reporting “until the Treasury Department and IRS issue further guidance”, the backup withholding exemptions in sections 3.03 to 3.05 of Notice 2024-56 last “until further guidance is issued”, and CF/SF participation for Form 1099-DA awaits a future announcement. The IRS keeps developments after publication at IRS.gov/Form1099DA.

Frequently Asked Questions

A customer moved tokens bought on another exchange in 2026 to our platform and sold them here. Do we report basis?

Basis is voluntary for those units. Units transferred in are noncovered even when acquired after 2025, because they were not acquired in an account the receiving broker held in custody. The return shows the units transferred in (box 12a) and the transfer-in date (box 12b). The broker may check box 9, and basis it then reports voluntarily carries no section 6721 or 6722 penalty.

A customer sells one position made up of lots bought on several dates. What goes in box 1d?

Leave box 1d blank when the units sold were acquired on a variety of dates, and leave box 12b blank when they were transferred in on a variety of dates. The IRS broker reporting FAQs confirm that a single sale of several transferred-in lots may be reported on one form. Under the instructions’ separate-form rules, lots in different categories (covered short-term, covered long-term, noncovered) still go on separate forms.

We charged the trading fee in a different token from the one the customer sold. Can it go on the same form?

A reportable fee paid in the same digital asset disposed of in the underlying trade may be combined with that trade. A fee paid in another asset generally requires separate reporting. However, Regulations section 1.6045-1(c)(3)(ii)(C) exempts a fee disposal where the broker withholds the fee units from digital assets received in the underlying sale.

We process customer payments in stablecoins and other tokens. In what order do the de minimis tests run?

The instructions let a processor of digital asset payments apply the optional stablecoin and NFT methods first, and then test whether the remaining PDAP sales exceed $600 for the year. Sales excluded under the optional methods do not count toward the $600 PDAP threshold.

We reported basis voluntarily for 2025 sales and some of it was wrong. Are we exposed?

For 2025 sales, the 2025 instructions say voluntarily reported basis on covered or noncovered units attracts no section 6721 or 6722 penalty, and box 9 did not have to be checked. From 2026 sales onward, that protection for noncovered units depends on checking box 9; basis reported on a covered security, or on a noncovered lot combined with covered units, is subject to sections 6721 and 6722 like any other required information.

Can we deliver Form 1099-DA statements only through our app?

Publication 1099 allows electronic furnishing where the recipient has affirmatively consented, electronically, in a way that shows they can access the format used, and has not withdrawn that consent; a recipient who does not consent gets paper. For statements required to be furnished on or after 1 January 2027, IRS release IR-2026-29 states that brokers may follow the alternative proposed electronic-furnishing rules. Those rules permit different paper-choice and consent-withdrawal arrangements, subject to their disclosure, delivery, notification and access conditions. App-only availability does not by itself satisfy those conditions; the proposal remains distinct from a final binding regulation.

We filed a tokenized security on Form 1099-B instead of Form 1099-DA. How is that fixed in IRIS?

Publication 5718 treats a wrong form type as a two-step correction: first a correction to the accepted 1099-B record with every amount set to zero, then, once that correction is accepted, a new original transmission on Form 1099-DA. FIRE-filed originals follow the FIRE correction procedure while that system remains available, with its final filing cut-off on 19 November 2026 at 3 p.m. Eastern Time. IRIS takes over those corrections from January 2027. Under the 2026 instructions, tokenized securities belong on Form 1099-DA. The cash-sale choice between the two forms existed for 2025 only.

Related Articles

• CARF: The New Global Tax Reporting Framework for Crypto: the OECD Crypto-Asset Reporting Framework, its due diligence duties and the EU’s DAC8 implementation.
• CARF Reporting in Luxembourg: DAC8 Crypto Filing by 30 June: how a crypto-asset service provider files the DAC8 return in Luxembourg.
• FR UU Reporting: The Fed’s New Stablecoin Collection and FR Q Changes: the Federal Reserve’s proposed reporting for stablecoin issuers under the GENIUS Act framework.
• FinCEN CVC Mixing Withdrawal: Mixer and Wallet Proposals Dropped: FinCEN’s withdrawal of its convertible virtual currency mixing and wallet proposals.
• Form PF Reporting: Thresholds, Deadlines and the July 2027 Form Switch: another US filing explained end to end, for private fund advisers reporting to the SEC.

Key Takeaways

• Tag every customer lot at acquisition as covered or noncovered; a transfer-in can never become covered on the receiving platform.
• Build the four-way form split (covered short-term, covered long-term, noncovered with box 9, NFT first sales) into the disposal engine before processing 2026 sales.
• Arrange the appropriate IRIS TCC well before filing; the IRS quotes a typical processing period of 45 business days, but processing times vary. Arrange SOR schema access where the implementation requires direct access to those packages. FIRE is not a fallback for Form 1099-DA.
• Before relying on uncertified TINs for 2027 sales, run each preexisting customer through IRS TIN Matching ahead of the trade.
• Set the order of tests for payment processing: optional stablecoin and NFT methods first, then the $600 PDAP threshold.
• Keep the full transmission package retrievable. To preserve the original receipt date, an acceptable replacement must reach IRIS within 60 days after the original rejection status becomes available.
• File state copies directly while Form 1099-DA sits outside the CF/SF Program.

Sources and References

• IRS, Instructions for Form 1099-DA (2026), document date 18 February 2026, posted 28 April 2026: irs.gov
• IRS, Instructions for Form 1099-DA (2025), dated 30 May 2025: irs.gov
• IRS, About Form 1099-DA (recent developments): irs.gov
• IRS, Form 1099-DA excluded from Combined Federal/State Filing Program for tax year 2025: irs.gov
• IRS, Corrections to the 2025 Instructions for Form 1099-DA, de minimis rules and optional reporting methods: irs.gov
• IRS, Frequently asked questions about broker reporting: irs.gov
• IRS, Publication 1099 (2026), General Instructions for Certain Information Returns, dated 19 March 2026: irs.gov
• IRS, Publication 1220 (Rev. 5-2026), Specifications for Electronic Filing of Forms 1097, 1098, 1099, 3921, 3922, 5498 and W-2G, tax year 2025: irs.gov
• IRS, Publication 5718, IRIS Electronic Filing Application to Application (A2A) Specifications, processing year 2026: irs.gov
• IRS, E-file information returns with IRIS: irs.gov
• IRS, IRIS schemas and business rules: irs.gov
• IRS, Information return penalties: irs.gov
• Treasury Decision 10000, Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions, 89 FR 56480 (9 July 2024): govinfo.gov
• Internal Revenue Bulletin 2024-29 (15 July 2024), Notices 2024-56 and 2024-57: irs.gov
• Notice 2025-33, Extension and Modification of Transitional Relief with Respect to the Reporting of Information and Backup Withholding on Digital Assets by Brokers: irs.gov (Internal Revenue Bulletin 2025-27: irs.gov)
• Public Law 119-5 (H.J. Res. 25), approved 10 April 2025: govinfo.gov
• Treasury Regulations section 1.6045-1 (26 CFR 1.6045-1), Returns of information of brokers and barter exchanges: ecfr.gov
• IRS, FIRE system retirement and key dates: irs.gov
• IRS, IR-2026-99, IRS reminder: information return e-file system transitioning to a new platform (24 August 2026): irs.gov
• IRS, IR-2026-29, Treasury and IRS issue proposed regulations to make it easier for digital asset brokers to provide Form 1099-DA statements electronically (5 March 2026): irs.gov

The Form 1099-DA file each broker needs for a calendar year

For each calendar year the working file has four parts: a lot register that fixes covered or noncovered status at acquisition, a disposal engine that splits each sale into the required forms and fills the DTIF code, units and dates, an IRIS transmission log holding Receipt IDs, UniqueRecordIds and every replacement, and a relief map recording which notice applies to which customer for that year. Recipient statements leave by 15 February and the IRIS transmission by 31 March, and the 60-day window applies only to eligible replacements, not every rejection.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.