Automatic exchange of information on crypto-assets

The OECD Crypto-Asset Reporting Framework

The tax transparency regime that Switzerland accepted after the end of banking secrecy, described in Part G, rested on the Common Reporting Standard of the OECD. It had a gap: crypto-assets held directly on a blockchain or through a crypto exchange were not financial accounts within the meaning of the standard. The OECD closed this gap in 2022 with the Crypto-Asset Reporting Framework (CARF), which requires crypto-asset service providers to collect information on their customers and transactions and to report it to the tax authorities of their state of residence for exchange with the states of residence of the customers. Switzerland signed the multilateral competent authority agreement on the CARF on 8 June 2023.¹ The Federal Council presented the implementation as a means to close gaps in tax transparency and to ensure the equal treatment of the crypto sector with the traditional financial sector.²

Swiss implementation and the postponement

On 6 June 2025 the Federal Council adopted a dispatch approving a list of 74 partner states for the automatic exchange of information on crypto-assets. The list comprised all Member States of the European Union, the United Kingdom and most G20 states, but not the United States, China or Saudi Arabia. An exchange was to take place only with partner states that are interested in exchanging information with Switzerland and fulfil the requirements of the OECD framework.³ Parliament approved the multilateral agreement and the implementing amendments in the final vote on 26 September 2025. The deliberations on the partner states were, however, not concluded in 2025. The Federal Council therefore decided that the legal basis for the automatic exchange on crypto-assets would not apply in 2026 and that Switzerland would implement the CARF from 1 January 2027 at the earliest. The amendments to the Common Reporting Standard, including new rules on e-money products and central bank digital currencies, came into force as planned on 1 January 2026.⁴

The postponement has concrete consequences. The first calendar year for which data on crypto-assets will be collected is 2027 at the earliest, which means that no data will be exchanged for 2026. The due diligence obligations of reporting crypto-asset service providers and the deadlines for the documentation of pre-existing customers are also postponed until the framework is activated.⁵ As at September 2026, reporting crypto-asset service providers in Zurich were preparing their systems for a start in 2027 while the list of partner states remained before Parliament.⁶

Consequences for private clients

For the private client practice of Zurich, the CARF completes the transformation of the financial centre from a place of discretion to a place of transparency. Foreign clients who hold crypto-assets through a Swiss exchange, broker or bank will be reported to their home tax authorities in the same way as holders of bank accounts have been since 2017 and 2018. Clients who expected crypto-assets and Digital Assets to offer a new form of privacy will find that the regulated Swiss market offers none in tax matters. The pressure to regularise undeclared crypto holdings will therefore increase in the years after 2027, and voluntary disclosures in the home countries of clients are likely to follow the pattern observed after the introduction of the Common Reporting Standard. For Swiss residents the position is simpler, since the wealth tax already requires them to declare their holdings every year.

Notes

1. State Secretariat for International Finance (SIF), “Implementation of the Crypto-Asset Reporting Framework: FAQ”, https://www.sif.admin.ch/dam/en/sd-web/3DLzoBB6uMYz/MM%20E-AIAV%20FAQ%20EN.pdf. ↩
2. State Secretariat for International Finance (SIF), “Framework for the automatic exchange of information (AEOI) on crypto assets”, https://www.sif.admin.ch/en/framework-for-the-automatic-exchange-of-information-aeoi-on-crypto-assets. ↩
3. Swiss Federal Council, “Federal Council adopts dispatch approving the list of 74 partner states for the automatic exchange of information concerning cryptoassets”, media release, 6 June 2025, https://www.admin.ch/de/newnsb/1QknKQ4iBGdl3Q7I4CL7b. The existing review mechanism for the AEOI on financial accounts was to be extended to the exchange on crypto-assets. ↩
4. SIF, “Implementation of the Crypto-Asset Reporting Framework: FAQ”, https://www.sif.admin.ch/dam/en/sd-web/3DLzoBB6uMYz/MM%20E-AIAV%20FAQ%20EN.pdf (on the final vote of 26 September 2025, the postponement and the entry into force of the CRS amendments). ↩
5. SIF, “Framework for the automatic exchange of information (AEOI) on crypto assets”, https://www.sif.admin.ch/en/framework-for-the-automatic-exchange-of-information-aeoi-on-crypto-assets. The page states that parliamentary deliberations on the partner states were expected to conclude in 2026 at the earliest. ↩
6. State Secretariat for International Finance, “CARF FAQ” (update of 18 May 2026), https://www.sif.admin.ch/dam/en/sd-web/3DLzoBB6uMYz/CARF%20FAQ%20Update%20EN.pdf, which states that the framework will apply at the earliest from 1 January 2027, that Parliament determines the activation date and must approve the partner states, and that there are no reporting duties for 2026. Status assessed as at September 2026. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.