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DeFi companies win reprieve on tax reporting

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Decentralized finance companies are breathing a sigh of relief after the Treasury Department and the Internal Revenue Service gave them a two-year delay on reporting their customers’ digital assets to the tax authorities.

In late December, the Treasury and the IRS issued final regulations on sales and exchanges of digital assets on the new Form 1099-DA for decentralized finance brokers, along with transition relief. The requirements for DeFi companies start on or after Jan. 1, 2027, two years later than the rules for centralized exchanges and platforms. The new rules are expected to generate a deluge of Form 1099-DA information reporting to the IRS from cryptocurrency brokers, traders, banks, wallet hubs and taxpayers starting on Jan. 1, 2025. But the DeFi companies may escape unscathed, expecially with the crypto friendly Trump administration already scaling back regulation and enforcement at the Securities and Exchange Commission.

“They’ve kind of carved back on the requirements on DeFi probably about as far as they could,” said Jonathan Jackel, managing director in EY’s information reporting and withholding practice. “Virtually the only part of DeFi that has any obligations at all under these regs are front-end service providers. So everybody in the other layers of the DeFi stack doesn’t need to worry about anything. It’s not nothing. It’s definitely a pretty significant concession. We only expect a very limited set of businesses to be doing this reporting.”

He pointed out that front-end DeFi service providers are not set up in a way that would make it easy for them to file the reports. “Their argument is we’re not doing enough in contributing to the sale of the crypto to make us do the tax report,” said Jackel. “The argument is you can’t call us a broker because we don’t actually make the sale happen. We’re only kind of assisting or helping or providing information or a coded instruction. But it’s not up to us to pass that instruction along or execute it. And the government basically said, but you are the guys in the position to know. Particularly if you’re in a position to make sure you get paid, you probably have a lot of control over other aspects of the transaction. You would know basically what the transaction is, and so we expect you to do this reporting. It’s certainly not going to be easy for front-end service providers to implement these rules.”

Three crypto industry groups — the Blockchain Association, the Texas Blockchain Council and the DeFi Education Fund — have filed a lawsuit against the IRS over the new regulations, claiming they violate the Administrative Procedure Act.

“There’s at least one lawsuit out there that I know about to enjoin the rules from going into effect,” said Jackel. “I guess we’ll see how the court feels about it.”

The additional two years may give the court time to sort out the matter, and the DeFi companies will also have more time to adjust. Crypto companies did not get as much leeway.

“They provided a similar phase-in on the regs that came out in July with respect to custodial wallet providers, and it certainly seems appropriate, given the nature of the industry, that there will be some time for implementation,” said Jackel. “They did not provide a ton of time to the custodial service providers. The regs came out in July, and they’re already in effect. Transactions happening right now are subject to reporting next year. So I think if there’s one thing that the industry needs more of, it’s time, and at least for DeFi, they do have a bit more time than everybody else, but it’s still a pretty heavy lift.”

It’s unclear whether the Trump administration might relax the regulations, which have been hashed out between the crypto industry and the Treasury and the IRS over the years since passage of the Infrastructure Investment and Jobs Act in 2021, which mandated the reporting.

“When the new regime takes over, is this going to turn around and get reversed?” said Thomas Shea, EY Americas financial services crypto tax leader. “It’s tough to think that would happen, given all of the time and energy spent in getting to this point. But you really never know.”

There may be some benefits to the reporting for the crypto industry, which has been calling for clearer rules. “It’s not so obvious,” said Jackel. “There’s clearly an expense, and a certain amount of effort that the industry has to go through. But there is the argument that having this kind of tax reporting is consistent with just a good customer experience. And if you want to legitimize crypto, then you’re going to have to do things like help people figure out what they should put on their tax return. It’s not so obvious that these regs are necessarily bad for crypto. There are certain folks in the crypto world who just want it to be another investment, like stocks or bonds or something like that. The fact that there’s going to be a clear way to deal with it on a tax return makes it easier for customers to deal with. And maybe that’s sort of pro industry to some extent. I don’t want to make it sound like it’s the easiest thing to comply with. There will be some significant expense and effort involved in implementing, but it’s not clear it’s entirely negative for the industry either.”

Even though the DeFi companies have an extra two years, crypto exchanges will need to start sending the Form 1099-DA this year.  

“I would certainly expect centralized exchanges to be ready to go because transactions occurring in 2025 are going to be reportable,” said Jackel. “Failing to comply is not really an option that’s available. With DeFi, it’s obviously a little bit less clear. There won’t really be the issue of complying until 2027, and then there’s the lawsuit. It’s conceivable that the court would say these rules don’t work and they’re not enforceable. And if that were the case, I wouldn’t expect anybody in the DeFi world to be doing reporting.”

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Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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Accounting

Automated Tax Compliance and Global Regulatory Harmonization in 2026

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Corporate tax accounting departments are navigating an era of unprecedented regulatory complexity as global tax harmonization frameworks take full effect alongside real-time digital tax reporting mandates. Tax directors and accounting teams are adopting cloud-based tax compliance automation tools to manage multi-jurisdictional tax liabilities and satisfy stringent reporting rules across international jurisdictions.

Implementation of Global Minimum Tax Provisions
The implementation of international tax reform agreements—notably the Pillar Two global minimum tax framework—has reshaped multinational corporate tax planning. Multinational enterprises with consolidated revenues exceeding established thresholds must ensure an effective tax rate of at least 15% across every jurisdiction in which they operate.

Accounting teams are implementing specialized tax calculation modules integrated directly into enterprise resource planning (ERP) platforms. These automated tools calculate effective tax rates per country, identify top-up tax liabilities, and generate standardized compliance documentation required by national tax authorities.

Real-Time Digital Invoicing and E-Reporting Mandates
Tax authorities across Europe, Latin America, and Asia-Pacific have enacted mandatory electronic invoicing (e-invoicing) and continuous transaction controls (CTC). Under these systems, corporate transaction data must be submitted electronically to government portals in real time at the point of sale or invoice issuance.

This shift toward continuous digital tax reporting eliminates traditional annual tax audits in favor of ongoing automated compliance monitoring. Accounting departments are upgrading invoicing software to ensure seamless XML data formatting, digital signature authentication, and real-time validation against tax authority databases.

Automation and Data Analytics in Corporate Tax Strategy
To keep pace with dynamic tax legislation, tax departments are transitioning from reactive compliance teams to proactive strategic advisors. Machine learning algorithms analyze corporate transactional data to identify tax credits, research and development (R&D) incentives, and cross-border transfer pricing adjustments.

By automating routine tax return filings and calculations, corporate tax directors can focus on long-term capital structuring, evaluating the tax implications of corporate mergers, and optimizing international supply chain networks.

Strategic Priorities for Tax Executives
1. ERP System Upgrades: Ensure enterprise software is capable of generating real-time, granular tax data required for global minimum tax compliance.
2. E-Invoicing Integration: Implement scalable e-invoicing platforms to satisfy regional continuous transaction control regulations.
3. Strategic Tax Analytics: Utilize predictive tax modeling tools to evaluate structural changes in corporate operations and cross-border trade.

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