Most of what you read online about Form 1099-DA is either a year out of date or describes rules that were proposed and then dropped. If you are trying to figure out what the IRS knows about your crypto, you need the dates that are actually in the final regulation.

The rules live in Treas. Reg. 1.6045-1, the broker reporting regulation. Treasury and the IRS published the digital asset version as T.D. 10000 in the Federal Register on July 9, 2024, at 89 FR 56480, as Notice 2025-33 recites. Here is what it requires, in the order it takes effect.

Before 2025: no required broker reporting of digital asset proceeds

Treas. Reg. 1.6045-1(d)(2)(iii)(B) says a broker is not required to report the gross proceeds from the sale of a digital asset if the sale is effected before January 1, 2025. A broker that chose to report anyway, on Form 1099-B or Form 1099-DA, is protected from information reporting penalties under IRC 6721 and 6722 for reporting it incorrectly.

So for 2024 and earlier, there was no regulatory requirement for crypto brokers to send the IRS a 1099-DA. That does not mean the IRS had nothing. It had whatever forms some platforms filed voluntarily, whatever it pulled through John Doe summonses, and whatever you put on your return. Your reporting obligation existed the whole time.

January 1, 2025: gross proceeds

The applicability paragraph, Treas. Reg. 1.6045-1(q), says that except for sales of digital assets for real property, the section “applies to sales of digital assets on or after January 1, 2025.”

For each covered sale, the broker reports on Form 1099-DA, “Digital Asset Proceeds From Broker Transactions,” information including your name, address and taxpayer identification number, the name and number of units of the digital asset sold, and the gross proceeds. See Treas. Reg. 1.6045-1(d)(2)(i)(B).

What 2025 reporting generally does not include is your basis. The 2025 Form 1040 instructions put it plainly: in 2025, a broker has the option to report your basis on Form 1099-DA but is not required to do so. If your broker did not report basis, you need your own records to determine it.

That gap is the single biggest source of 1099-DA mismatches. The IRS sees proceeds. It may not see what you paid. See what happens when the form shows zero basis.

2025 penalty relief for brokers, not for you

Notice 2024-56 gave brokers transitional relief: the IRS will not impose penalties under IRC 6721 and 6722 on brokers that fail to file or furnish correct 1099-DA forms for sales effected during calendar year 2025, provided they make good faith efforts to file accurate and timely forms.

Notice that the relief runs to the broker. It has nothing to do with your own return. A broker’s good faith mistake on a 2025 form is still a mismatch the IRS’s systems may flag against you. See how to handle a wrong 1099-DA.

January 1, 2026: basis for covered assets

Basis reporting turns on whether the asset is a “covered security.” Under Treas. Reg. 1.6045-1(a)(15)(i)(J), a digital asset is a covered security if it is acquired in a customer’s account by a broker providing custodial services on or after January 1, 2026, in exchange for cash, stored-value cards, different digital assets, or other property or services.

For sales on or after January 1, 2026 of those covered assets, held in the customer’s account, the broker must also report adjusted basis, the acquisition date, and whether the gain or loss is long-term or short-term. See Treas. Reg. 1.6045-1(d)(2)(i)(D).

Three consequences follow. First, basis reporting only applies to assets bought inside that broker’s custody on or after January 1, 2026. Second, crypto you bought before 2026 is a noncovered security, and its basis may never be reported. Third, crypto you transferred into an exchange from somewhere else is noncovered. The 2026 Instructions for Form 1099-DA list assets transferred in among noncovered securities, and box 9 is checked for noncovered sales.

January 1, 2026: digital assets used to buy real estate

Treas. Reg. 1.6045-1(q) sets a separate start date for sales of digital assets for real property: those rules apply to sales on or after January 1, 2026. Real estate reporting persons report the buyer’s disposition of digital assets in those transactions. If you used crypto to buy a house, expect a form.

Backup withholding: delayed through 2026

Brokers that do not have your certified taxpayer identification number generally must backup withhold under IRC 3406 at the fourth lowest rate under IRC 1(c), currently 24 percent, as Notice 2025-33 explains.

For digital assets, the IRS delayed that. Notice 2024-56 waived backup withholding on digital asset sales effected during 2025. Notice 2025-33 extended the waiver: backup withholding “will not be required on any digital asset sale effected by a broker during calendar year 2025 or calendar year 2026.” For 2027, brokers get limited relief for preexisting customers whose names and TINs match through the IRS TIN Matching Program. Details in the backup withholding guide.

Transactions brokers do not report yet

Notice 2024-57 lists transactions brokers are not required to report as digital asset sales until further guidance. The 2026 Instructions for Form 1099-DA summarize them:

  • Wrapping and unwrapping transactions.
  • Liquidity provider transactions.
  • Staking transactions.
  • Transactions described as lending of digital assets.
  • Transactions described as short sales of digital assets.
  • Notional principal contract transactions.

The instructions add that the exception does not cover rewards or other compensation earned in those transactions, and that rewards and staking payments should not be reported on Form 1099-DA. None of that changes whether the transaction is taxable to you. It only changes whether the IRS gets a 1099-DA about it.

The DeFi broker rule: repealed

In December 2024, Treasury published a second set of amendments that would have treated certain decentralized finance front-end services as brokers. It did not survive. The eCFR editorial note to Treas. Reg. 1.6045-1 states that at 90 FR 30825, July 11, 2025, as required by the Congressional Review Act and Public Law 119-5, the IRS removed all amendments to 1.6045-0 and 1.6045-1 published at 89 FR 106928 on December 30, 2024.

So if you read that DeFi platforms will send 1099-DAs starting in 2027, that was the repealed rule. Under the current regulation, decentralized trading is generally not reported to the IRS by a broker. It is still reportable by you.

A practical warning: many articles, tax software help pages and even some broker FAQs were written while the DeFi rule was still on the books. If a source tells you that a front-end interface will issue you a form for 2027 activity, check the date it was written. The regulation in force today does not include those amendments.

What this timeline means for enforcement

Put the dates together and you can map what the IRS sees for each year:

  • 2024 and earlier: No required 1099-DA. The IRS relies on your return, voluntary broker reporting, summonses and its own analysis.
  • 2025 sales: Gross proceeds from custodial brokers, often with no basis. Highest mismatch risk.
  • 2026 sales: Gross proceeds, plus basis for assets acquired in that broker’s custody on or after January 1, 2026. Pre-2026 and transferred-in assets still show proceeds only.
  • 2027 and later: The same reporting, with backup withholding largely in force.

The 2025 Form 1040 instructions also say you must answer the digital asset question whether or not you received a Form 1099-DA. The forms are a cross-check on you, not a substitute for your own reporting. If your 2025 return does not reconcile to your forms, fix it before the matching program does. The crypto tax page on getirshelp.com describes how the firm handles that cleanup.