The IRS final regulations on digital asset broker reporting set two separate start dates, and the second one is already running. Brokers had to begin reporting gross proceeds on transactions from 1 January 2025. They must report cost basis on certain transactions effected on or after 1 January 2026. That second date passed nine months ago, and the forms it produces land on client doormats early next year.
Your clients who hold crypto are about to receive a Form 1099-DA that tells the IRS what they paid, not just what they sold for. For the first time, there is a matching problem. The client's own spreadsheet, the exchange's number and the IRS copy all have to agree, and in a great many cases they will not.
That is a compliance headache. It is also the clearest advisory opening a CPA firm has had in this area, because the people affected do not yet know they have a problem.
What changed on 1 January 2026 for digital asset reporting?
Custodial brokers must now report cost basis, not only gross proceeds, on covered digital asset transactions. A covered asset is one acquired on or after 1 January 2026 in a custodial account and held continuously at the same broker until disposal. The IRS therefore receives both sides of the trade and can match them against the return.
Before this, the IRS received a sale figure with no purchase figure. A client could report a gain of almost any size and nothing on the IRS side contradicted it. That asymmetry is now closing, and it closes on the 2026 tax year, which is the return your firm prepares in the first half of next year.
Which transactions does Form 1099-DA actually cover?
The final regulations apply to brokers that take possession of the digital assets their customers sell. That means custodial trading platforms, hosted wallet providers, kiosks and certain digital asset payment processors. Decentralised and non-custodial arrangements are excluded from these requirements.
The exclusion matters more than the inclusion. A client who trades on a custodial exchange will get a form. A client who uses a self-custody wallet, swaps on a decentralised protocol, stakes, mines or moves assets between wallets they own will not. Those activities are still taxable. They simply arrive with no paperwork.
Why the gap between covered and uncovered is the advisory job
The reporting rules create a two-tier client. One tier has a form that mostly agrees with reality. The other tier has taxable activity with no third-party record at all, and now sits next to a neighbour whose exchange reported everything.
The rules also produce a transitional problem inside a single client. Assets bought in 2024 and sold in 2026 are not covered, because they were not acquired after 2025 in that account. Assets bought in February 2026 and sold in November 2026 are covered. The same client, the same exchange, the same tax year, two different evidence standards.
Anyone who has watched a client try to reconstruct a basis for an asset bought three years ago on an exchange that has since changed hands knows how that conversation goes. It is slow, it is billable, and it is far cheaper when it happens in October than in April.
What should a CPA firm do about it before filing season?
Identify which clients hold digital assets, tell them a basis-reporting form is coming, and ask them to export their transaction history now while the exchange still has it. The work is small in September and large in March. Doing it early also produces the record that supports the return if the reported basis and the client's own figure disagree.
Most firms already know, informally, which of their clients trade. The step that gets skipped is writing to them before the form arrives rather than after.
Why this belongs on your website, not only in a client email
A client email reaches people who are already clients. The people searching for help with a basis mismatch they do not understand are not on your list yet. They are typing the form number into Google in February, finding a national chain or a crypto tax software vendor, and never seeing your firm at all.
Digital asset work is one of the few remaining areas where a small firm can rank. The search volume is real, the competing pages are mostly thin software marketing, and the topic is specific enough that a genuinely useful page from a credentialled preparer outranks generic content. That is the same pattern we set out in our guide to digital marketing for accounting firms, and it is why a narrow technical page often outperforms a broad services page.
A page that explains what the form is, who gets one, what it will not include and what a client should bring to a first meeting does two jobs at once. It answers a live question, and it demonstrates that your firm has handled this before.
What does a page like this need to contain?
It needs the form number in the title, a plain answer to who receives one, an explicit statement of what is not reported, and a clear next step. Pages that rank for tax questions are the ones that answer the question in the opening lines rather than building to it, because both search engines and AI assistants quote the answer, not the introduction.
It also needs to be findable on a phone in under three seconds. A large share of the people searching a tax form number are doing it on mobile while looking at the form. A firm site that takes six seconds to render loses them before the answer appears, which is why page performance sits inside the search problem rather than beside it. Our website design and development work treats load time as part of the content, not a technical afterthought.
What the transitional year does to a single client account
Consider a client who has used the same custodial exchange since 2023. They bought in 2023, added more in 2024, added again in March 2026, and sold a portion of the whole holding in December 2026. The broker reports proceeds on all of it. The broker reports basis only on the portion acquired in 2026 and held continuously in that account.
The return therefore needs two different evidentiary approaches for one line of activity. Part of it is supported by a third-party document the IRS also holds. Part of it rests entirely on whatever records the client kept, which is frequently a partial CSV and a memory.
This is where the advisory value sits, and it is worth being blunt with clients about it. The question is not whether the older holdings are taxable. They are. The question is whether the client can evidence what they paid, and the answer is much more often yes in September than in April, because exchanges routinely prune downloadable history, change export formats after acquisitions, and throttle support queues once filing season starts.
A firm that tells its clients this in the autumn looks prescient in the spring. A firm that discovers it in the spring is explaining why the bill went up.
How fast does this window close?
Faster than most technical topics, because the trigger is a dated form rather than a general trend. Interest will build through January, spike as forms arrive, and peak in the filing weeks. A page published in the autumn has time to be crawled, indexed and to accumulate the engagement signals that decide whether it ranks when the volume arrives.
A page published in February is competing from a standing start against pages that have been indexed for months. The work is the same. The timing is what separates a page that earns enquiries from one that earns nothing.
Does local visibility matter for a national topic?
More than firms expect. A person searching a form number usually adds a location once they decide they want a human rather than software, and the second search is the one with intent behind it. Firms that appear in local results for tax help in their metro, with a current profile and recent reviews, capture that second search. Firms with a neglected listing do not appear in it at all.
The two searches are connected. The technical page earns the first visit and establishes competence. The local presence converts the follow-up. Treating them as separate projects is the most common reason a firm publishes good technical content and still gets no calls from it.
The wider point for US firms
Every year the IRS creates a handful of these moments, where a specific, dated, searchable change produces a burst of people looking for an answer. Most firms treat them as compliance events to be absorbed. A smaller number treat them as the only reliable way a firm without a marketing budget can appear above firms that have one.
The digital asset basis rules are a better than usual example because the affected population skews younger, searches rather than asks for a referral, and has almost no existing relationship with an accountant. That is close to the definition of a reachable prospect. Firms building visibility in the United States market tend to find that this kind of narrow, timely page compounds, while a general services page does not.
The reporting change has already happened. The forms have not arrived yet. That interval is the whole opportunity, and it runs out in January.
FAQs
When does Form 1099-DA cost basis reporting begin?
Brokers must report cost basis on certain digital asset transactions effected on or after 1 January 2026, under the IRS final regulations on broker reporting. Gross proceeds reporting began a year earlier, on 1 January 2025. The basis figures therefore appear on forms issued for the 2026 tax year, which clients receive in early 2027.
Which brokers have to file Form 1099-DA?
The final regulations apply to brokers that take possession of the digital assets their customers sell. That includes custodial trading platforms, hosted wallet providers, kiosks and certain digital asset payment processors. Decentralised and non-custodial brokers are excluded from these requirements, so activity conducted through self-custody wallets produces no form.
What is a covered digital asset?
A covered asset is one acquired on or after 1 January 2026 in a custodial account and held continuously at the same broker until it is disposed of. Assets bought before 2026, or transferred in from elsewhere, are not covered, so the broker is not required to report a basis figure for them even though the sale is still reportable.
What does Form 1099-DA not report?
It does not capture decentralised exchange swaps, most self-custody activity, staking rewards, mining income or transfers between wallets the client owns. Those items remain taxable and remain the client's responsibility to document. The absence of a form is often mistaken by clients for an absence of a filing obligation.
What should a CPA firm do before the forms arrive?
Identify clients who hold digital assets, warn them that a basis-reporting form is coming, and ask them to export full transaction histories now while their exchange still holds the records. Reconstructing a basis after the fact is slow and expensive, and the export is far easier to obtain before filing season demand builds.
Why publish a page about a tax form on a firm website?
Because people searching a form number are looking for an answer, not a firm, and the firm that answers first is the one they contact. Narrow, dated, technical pages face far less competition than general accounting services pages, and they reach prospects who have no existing accountant relationship.