Sources checked 9 November 2026. Dates are taken from IRS instructions, notices and Treasury Decision 10000 as published on IRS.gov; the 2026 Form 1099-DA instructions were current on that date. This page is general education for a UK or US company that holds bitcoin. It is not legal, tax, accounting or investment advice, and it does not say whether to buy, hold or sell. If anything here conflicts with the linked source, the source wins.
Short answer
Form 1099-DA is the information return US custodial brokers use to report digital asset sales. Gross proceeds are reported for sales on or after 1 January 2025. For sales on or after 1 January 2026, basis is also reported, but only for "covered" units: bitcoin bought after 2025 in a custodial account and held there until sold. Brokers are not required to file for exempt recipients, which include most C corporations, so many companies will not receive one. Whatever arrives, the company reports every disposal from its own records.
The United States and the United Kingdom take different routes to the same goal of third party reporting. Choose your country.
US: the effective dates
| Date | What happens | Source |
|---|---|---|
| Sales on or after 1 January 2025 | Custodial brokers report gross proceeds on Form 1099-DA. For 2025 sales, the IRS will not impose penalties where a broker makes a good faith effort to file and furnish correctly and on time. | Treasury Decision 10000; Notice 2024-56 |
| Early 2026 | First Forms 1099-DA (for 2025 sales). Statements to customers were due by 17 February 2026. Brokers must file with the IRS electronically through IRIS, not FIRE. | 2025 General Instructions for Certain Information Returns |
| Sales on or after 1 January 2026 | Basis, acquisition date and gain or loss are reported for covered securities: units acquired after 2025 in an account where the broker provided custody and held there until sold. Real estate reporting persons also report digital assets used in closings from this date. | Instructions for Form 1099-DA (2026); IRS digital assets page |
| Calendar years 2025 and 2026 | No backup withholding is required on digital asset sales. | Notice 2025-33 |
| Calendar year 2027 | Relief narrows: for example, a broker may rely on an uncertified TIN from a customer whose account opened before 2026 if the name and TIN match through the IRS TIN Matching Program. | Notice 2025-33 |
Source: IRS: Digital assets: broker compliance and transition relief (page reviewed or updated 2 September 2026), IRS: Notice 2024-56: transitional relief for digital asset broker reporting (PDF), IRS: Notice 2025-33: extension of backup withholding and penalty relief for digital asset brokers (PDF), IRS: General Instructions for Certain Information Returns (2025): due dates for Form 1099-DA statements, IRS: Instructions for Form 1099-DA (2026).
A separate December 2024 rule that would have treated certain decentralised finance front ends as brokers was disapproved by Congress and has no force or effect (Public Law 119-5, 10 April 2025). The custodial broker rules above were not affected.
US: will your company receive one?
Brokers "are not required to, but may" file Form 1099-DA for exempt recipients. The 2026 instructions list corporations among them, with conditions:
- C corporation: generally exempt. A broker may treat a customer as a corporation if, for example, it holds a properly completed Form W-9 exemption certificate showing the customer is not an S corporation. Without that, the broker may treat the company as not exempt and send a form anyway.
- S corporation: brokers must file for sales of covered securities by an S corporation. Because only units acquired after 2025 can be covered, expect forms for 2026 and later purchases sold through the same custodial account.
- LLC: it depends on how the LLC is classified for tax and what its Form W-9 shows. A single member LLC that is disregarded is reported under its owner.
- Self custody: bitcoin held in the company's own multisig and sold peer to peer, without a broker, produces no Form 1099-DA at all.
Source: IRS: Instructions for Form 1099-DA (2026).
US: what the form shows
| Box | What it holds | What to check |
|---|---|---|
| 1a, 1b, 1c | Digital token identifier, the asset name and units to 18 decimal places | Units match your ledger for that account. |
| 1e, 1f | Date sold and gross proceeds, reduced by transaction costs | Proceeds net of fees; the same date as your records. |
| 1d, 1g, 2, 6 | Date acquired, cost or other basis, a check box if basis was reported to the IRS, gain or loss | Expect these for covered units; compare with your own lot. |
| 9 | Checked if the units are noncovered | Expect this for bitcoin bought before 2026 or transferred in. |
| 12a, 12b | Units transferred in and the transfer date | Transfers from your multisig: the broker has no basis for them. |
| 4 | Federal income tax withheld (backup withholding) | Should be blank for 2025 and 2026 sales. |
Source: IRS: Instructions for Form 1099-DA (2026).
For a one line definition, see the glossary entry for Form 1099-DA.
Staking, lending, wrapping and similar transactions are not reported on Form 1099-DA until further guidance, and rewards and staking payments are never reported on it. Those amounts can still be taxable.
Source: IRS: Notice 2024-57: transactions brokers need not report until further guidance (PDF), IRS: Instructions for Form 1099-DA (2026).
US: what a company should do
- Check the Form W-9 each broker holds for the company: legal name, EIN, tax classification and any exemption entered. Ask your adviser which exemption, if any, applies.
- Keep your own basis for every lot, wallet by wallet and account by account. Units transferred into a broker arrive with no basis on the broker's side.
- Reconcile any form you receive to your ledger before filing. Differences are common where bitcoin moved between self custody and an exchange.
- Report all disposals on Form 8949 and Schedule D, whether or not a form arrives.
- Watch 2027. Backup withholding relief narrows; a missing or mismatched TIN could mean 24% withheld from proceeds.
Source: IRS: About Form 8949, Sales and Other Dispositions of Capital Assets, IRS: Notice 2025-33: extension of backup withholding and penalty relief for digital asset brokers (PDF), IRS: Revenue Procedure 2024-28: allocating unused basis to wallets and accounts as of 1 January 2025 (PDF).
US: pending legislation
H.R.10357, the Digital Asset Tax Certainty Act, was introduced on 14 September 2026 and ordered reported by the Ways and Means Committee on 16 September 2026. As at 9 November 2026 it has not had a House floor vote and is not law. As described by the Joint Committee on Taxation, its broker provisions would narrow basis reporting (for example by excluding certain US dollar stablecoins) and would apply to returns and statements due after 31 December 2027 if enacted. Check its status before relying on it.
Source: Congress.gov: H.R.10357, Digital Asset Tax Certainty Act: all actions (ordered reported 16 September 2026, not law), Joint Committee on Taxation: Description of H.R. 10357, September 2026: broker requirements (PDF).
UK: no Form 1099-DA, but providers now report
The UK has no equivalent form sent to the company. Instead, under the Cryptoasset Reporting Framework, UK reporting cryptoasset service providers have carried out due diligence on customers since 1 January 2026 and report transaction information to HMRC each year. For a company customer, the provider must also collect information about controlling persons. Failing to provide what is asked for can lead to a penalty, and the provider may refuse further service. Reports for 2026 are due to HMRC by 31 May 2027.
Source: HMRC: CRYPTO49000: Cryptoasset Reporting Framework, including business customers of a provider, HMRC: Check if you need to report cryptoasset data to HMRC (Cryptoasset Reporting Framework).
- Answer your exchange's self-certification requests promptly and keep a copy of what you sent.
- Expect HMRC to be able to compare provider data with your CT600. Your own chargeable gains computation, built from your records, is what you file.
- Bitcoin held in your own multisig is not reported by anyone; your records are the only evidence.
See the UK year-end page for the CT600 boxes and records.
Open points
- Exactly how a given broker documents exempt corporate customers, and whether it files for them anyway, varies by broker.
- The 2026 General Instructions for Certain Information Returns will confirm the furnishing date for 2026 forms.
- Pending US legislation could change basis reporting from 2028 returns onwards.
Read next
- Year-end checklist (UK and US), the full year-end pack.
- Company tax on bitcoin (US), basis, rates and losses.
- Peer to peer buying and selling, where no broker reports.
- US and UK rules compared, reporting side by side.
Sources
Primary sources only. Each link was checked on 9 November 2026. Rules change, so confirm the current version with your adviser.
- IRSDigital assets: broker compliance and transition relief (page reviewed or updated 2 September 2026)
- IRSNotice 2024-56: transitional relief for digital asset broker reporting (PDF)
- IRSNotice 2025-33: extension of backup withholding and penalty relief for digital asset brokers (PDF)
- IRSGeneral Instructions for Certain Information Returns (2025): due dates for Form 1099-DA statements
- IRSInstructions for Form 1099-DA (2026)
- Congress.govPublic Law 119-5 (H.J.Res.25): disapproval of the December 2024 DeFi broker rule, 10 April 2025
- IRSNotice 2024-57: transactions brokers need not report until further guidance (PDF)
- IRSAbout Form 8949, Sales and Other Dispositions of Capital Assets
- IRSRevenue Procedure 2024-28: allocating unused basis to wallets and accounts as of 1 January 2025 (PDF)
- Congress.govH.R.10357, Digital Asset Tax Certainty Act: all actions (ordered reported 16 September 2026, not law)
- Joint Committee on TaxationDescription of H.R. 10357, September 2026: broker requirements (PDF)
- HMRCCRYPTO49000: Cryptoasset Reporting Framework, including business customers of a provider
- HMRCCheck if you need to report cryptoasset data to HMRC (Cryptoasset Reporting Framework)
- IRSAbout Form 1099-DA, Digital Asset Proceeds From Broker Transactions
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This is general information and education only. It is not financial, investment, tax, accounting, legal or regulatory advice, and it is not a recommendation to buy, sell or hold bitcoin or any other asset. It does not take account of your circumstances or those of your company. You must obtain your own official professional advice to confirm this information is correct before acting on it.
Rules change. This information is correct to our understanding at the last-reviewed date, but it may be incomplete or out of date, and official sources take precedence. Bitcoin is volatile. A company that buys it could lose some or all of the money it puts in.
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