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IRS finalizes rules for DeFi crypto digital asset tax reporting

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The Internal Revenue Service issued final regulations for sales and exchanges of digital assets on the new Form 1099-DA for decentralized finance brokers, along with transition relief.

The requirements for decentralized finance 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. 

The IRS and the Treasury decided to delay the initial requirements for DeFi brokers for two years until the beginning of 2027 in response to feedback on the original proposed regulations.

“Although the applicability date proposed by the proposed regulations applied to gross proceeds reporting for sales of digital assets effected on or after January 1, 2025, the Treasury Department and the IRS agree that a delay is warranted for trading frontend service providers treated as brokers (DeFi brokers) under these final regulations,” said the final regs, issued last Friday. “First, many of these DeFi brokers may not have systems in place to collect and store customer identity information or contracts with third-party service providers to do the same. Second, many of these DeFi brokers also may not have systems in place to collect, store and report customer transaction information or contracts with third-party service providers to do the same. Third, many of these DeFi brokers also do not have backup withholding systems that would enable these brokers to backup withhold and pay the backup withholding tax in cash. Based on these considerations, final §1.60451(a)(21) applies to sales of digital assets occurring on or after January 1, 2027.”

There were other changes as well from the proposed regulations, according to Jessalyn Dean, vice president of tax information reporting at Ledgible, a provider of crypto tax and accounting software, in a LinkedIn post.

“The broad definition of Digital Asset Middleman has been significantly reduced from the proposed regulations to only apply to ‘Trading Front-End Services’ with further clarity and examples provided,” she wrote. “This removes from the definition of broker blockchain application layers, blockchain protocols, internet service providers and other kinds of possible providers in decentralized sales of digital assets that are not a Trading Front-End Service (a newly defined term detailed in the blog). The IRS estimates that between 650 and 875 digital asset providers will meet the definition of being such a Digital Asset Middleman.”

The IRS said it intends to work closely with stakeholders to ensure the smooth implementation of the reporting rules, including the mitigation of penalties in the early stages of implementation for all but particularly egregious cases involving intentional disregard of these rules. To promote industry readiness to comply with the backup withholding requirements that will apply to newly required reporting required by these final regulations, the IRS is issuing Notice 2025-3 in conjunction with the final regulations to provide transitional relief from broker reporting penalties and backup withholding under section 3406 on these sales. The notice postpones the effective date for backup withholding until Jan. 1, 2028, for potential backup withholding obligations imposed under section 3406 for payments required to be reported by DeFi brokers on Forms 1099-DA, Digital Asset Proceeds from Broker Transactions, for sale transactions. 

In addition, the notice says the IRS won’t impose penalties for a DeFi broker’s failure to deduct, withhold and pay any backup withholding tax with respect to calendar year 2028 that’s caused by a decrease in the value of received digital assets between the time of the transaction giving rise to the backup withholding liability and the time the broker liquidates 24% of the received digital assets, provided the broker undertakes to effect that liquidation immediately after the transaction giving rise to the backup withholding liability. For sale transactions effected in 2028 for customers that have opened accounts with the broker prior to Jan. 1, 2028, the notice further says backup withholding won’t apply with respect to any payee that furnishes a Taxpayer Identification Number to the broker, whether or not on a Form W-9 in the manner required, provided the broker submits that payee’s TIN to the IRS’s TIN matching program and receives a response that the TIN furnished by the payee is correct.

Landmark moment

There’s no exemption from the reporting of cost basis information specifically carved out for DeFi providers, Dean noted, but in most cases these Trading Front-End Services won’t be providing custodial services, so the sales they need to report aren’t covered assets. Only gross proceeds reporting will be required in such cases, she added.

Nevertheless, she sees this as a “landmark moment for the DeFi industry,” although lawsuits have already been filed to stop the rules.

“The collection of personal data about customers, tax withholding and tax reporting to the IRS is a landmark moment for the DeFi industry which will have huge implications through its fabric of existence,” she wrote. “It is uncertain how lawsuits against the U.S. Treasury and IRS will impact these regulations, including any flaws in technical DeFi ecosystem understanding that the final regulations may have relied upon. Lawsuits have already been filed by the Blockchain Association. More lawsuits could be filed in the coming weeks.”

The overturning of the Chevron doctrine by the U.S. Supreme Court in the case of Loper Bright Enterprises v. Raimondo in June, and the change in the presidential administration, will also likely have an impact on these regulations, she noted, as well as other pending guidance, and the adoption of the crypto asset reporting framework by the U.S. 

Carveouts in the regs

There are also some carveouts in the final regulations for the definitions of who has to report. 

“The rules focus on defining the term digital asset middleman, focusing on persons that provide an effectuating service,” wrote Miles Fuller, senior director of government solutions at TaxBit, a provider of crypto tax and accounting compliance technology, in a LinkedIn post. “An effectuating service is any service that is a trading front-end service where the type of arrangement means the provider would know or is in a position to know whether the nature of the transaction involved gives rise to reportable gross proceeds from the sale of digital assets. A trading service front end means a user interface that enables a user to input order details and transmit those order details to an automated protocol that is part of a distributed ledger network. This seems to focus on persons who operate websites that enable users to connect to digital asset trading protocols.”

He noted that this turns on whether the person has control or sufficient influence — the standard set forth by the Organization for Economic Cooperation and Development back in 2019 — over the trading front end-service. That includes the ability to amend, update or otherwise affect the terms under which the services are provided; the ability to collect fees from the transaction flow, whether or not such fees are being collected; and the ability to track or receive confirmation back from the distributed ledger that the order was executed and posted to the ledger. Contractual restrictions not required by law will be disregarded when doing the analysis.

He noted that the rules expressly carve out two specific groups from the covered definition — validation services and wallet software providers.

“This aligns with Treasury’s statement to Congress in early 2022 that validators and wallet software providers would not be subjected to reporting,” said Fuller. “However, with respect to wallet software providers, Treasury does note that if a wallet software provider also provides effectuating services, it would be subject to reporting, but only with respect to the trading services. Finally, Treasury excludes from reporting any operator of a digital asset trading protocol that does not include effectuating services as defined in the rules. This last element seems to align with the Fifth Circuit’s opinion regarding Tornado Cash holding that immutable smart contracts making up blockchain protocols are generally not things that are owned or controlled by any person.”

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Mandatory ESG Reporting Standards Demand Standardized Non-Financial Audit Trails

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Mandatory ESG Reporting Standards Demand Standardized Non-Financial Audit Trails

Corporate accounting departments face an expanded regulatory mandate as mandatory sustainability and Environmental, Social, and Governance (ESG) reporting frameworks take full effect internationally. Governed by the European Union’s Corporate Sustainability Reporting Directive (CSRD) and the International Sustainability Standards Board (ISSB) IFRS S1 and S2 standards, enterprise financial controllers are now legally required to track, verify, and report non-financial data with the same internal controls and auditability as traditional financial statements.

The expansion shifts ESG compliance

This regulatory expansion shifts ESG compliance from marketing departments to corporate accounting offices. Financial managers are now responsible for gathering, consolidating, and verifying carbon emissions metrics, supply chain labor conditions, water usage, and climate risk exposures across multi-tiered corporate structures. These non-financial metrics must be integrated into standardized general ledgers to withstand rigorous third-party audit assurance processes.

To comply with these rigorous reporting mandates, accounting software providers have added dedicated ESG modules designed to aggregate data from IoT sensors, utility platforms, and vendor management systems. Controllers are implementing internal control frameworks—modeled after traditional COSO frameworks—to ensure the completeness, accuracy, and consistency of sustainability disclosures, protecting organizations against greenwashing penalties and litigation risks.

The transition requires significant cross-functional collaboration between accounting teams, legal counsel, and operational directors. Accounting professionals are expanding their technical expertise beyond financial ledgers to master carbon accounting methodologies, lifecycle assessment standards, and non-financial data governance protocols, fundamentally expanding the role of the modern corporate accountant.

Why This Information Matters
Mandatory ESG disclosures require companies to treat environmental and social metrics as audited financial records. Executives, accountants, and board members must institute formal tracking and assurance processes to satisfy legal mandates, maintain investor confidence, and mitigate regulatory non-compliance risks.

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Accounting

SEC’s Semiannual Reporting Proposal Faces Investor Pushback: What CFOs Need to Know

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U.S. Securities and Exchange Commission (SEC)

A proposal from the U.S. Securities and Exchange Commission to potentially shift some public companies away from quarterly financial reporting toward a semiannual model is drawing significant pushback from investors, even as it continues moving through the regulatory process. The debate has direct implications for corporate finance teams, auditors, and the broader transparency of U.S. capital markets.

What the SEC Proposed

According to a summary published by accounting advisory firm Cohen & Co., the SEC issued a proposed rule on May 19, 2026, aimed at simplifying financial reporting requirements for many U.S. public companies. The proposal would potentially reduce the frequency of certain mandatory disclosures from quarterly to semiannual, a structural change that has not been made to core U.S. reporting requirements in decades.

The proposal follows an extended debate within U.S. policy circles, with proponents arguing that reduced reporting frequency could lower compliance costs and free up management time for longer-term strategic planning rather than quarter-to-quarter results management.

Why Investors Are Pushing Back

Comment letters submitted in response to the proposal have been extensive, and according to Cohen & Co.’s review of the public record, investors “appear to be largely opposed” to the shift, viewing frequent interim reporting as a core benefit of U.S. capital markets relative to other jurisdictions.

Accounting and law firms have taken a more measured position, generally urging any changes to remain aligned with the Financial Accounting Standards Board (FASB), whose existing disclosure requirements and guidance are built around a quarterly reporting cadence. A shift to semiannual reporting without corresponding changes to FASB guidance could create friction between SEC filing requirements and GAAP-based disclosure expectations.

Lessons From the U.K. Experience

The debate is not without precedent. The United Kingdom moved away from mandatory quarterly reporting for listed companies in 2014, returning to a semiannual disclosure requirement. According to Cohen & Co.’s analysis, that experience offers a cautionary data point: there was no measurable increase in capital expenditure or R&D investment following the change, while analyst coverage of affected companies declined as reliable interim information became less available — a particular risk for smaller and newly public companies that rely on analyst coverage to maintain investor visibility.

Practical Implications for Finance Teams

Beyond the debate over disclosure philosophy, the proposal carries practical complications. Many companies have debt covenants and credit agreements structured around quarterly financial delivery; a shift to semiannual reporting could require renegotiating those terms. Reduced reporting frequency would also extend the “window of market silence” between disclosures, a factor that governance and investor-relations teams would need to manage carefully to avoid information asymmetry.

Separately, and unrelated to the reporting-frequency debate, the SEC and FASB have continued finalizing more routine updates this year. New Accounting Standards Updates are taking effect for December 31, 2026, fiscal year-ends covering income tax disclosures, credit loss measurement, induced debt conversions, and stock compensation, according to Eide Bailly’s review of 2026 ASU activity. Additional guidance on paid-in-kind dividends and environmental credits is also on the near-term horizon.

What to Watch Next

The semiannual reporting proposal remains in the comment and review phase, and no final rule has been adopted as of this writing. Finance leaders should monitor the SEC’s regulatory agenda for further movement, while treating the current quarterly reporting requirement as the operative standard until any final rule is issued and an effective date is set.

Given the extent of investor opposition documented in the comment file, a full shift to mandatory semiannual reporting appears more likely to result in either a scaled-back compromise or continued study rather than swift adoption — though the SEC’s ultimate direction remains uncertain.

 

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AI-Driven Automation and Continuous Accounting Frameworks

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The accounting profession is undergoing a fundamental structural transition as enterprise finance departments shift from periodic month-end closes toward automated continuous accounting models. By integrating specialized machine learning algorithms directly into enterprise resource planning (ERP) platforms, chief accounting officers are transforming financial reporting from a retrospective exercise into a real-time operational asset.

The Shift from Periodic Close to Continuous Financial Reporting
Traditional accounting workflows heavily relied on manual data reconciliation, spreadsheet calculations, and multi-week closing cycles at the end of each fiscal period. In contrast, continuous accounting frameworks utilize automated software agents to process, validate, and post transactional data in real time as business activities occur.

Automated bank reconciliation tools cross-reference incoming bank feeds, invoice records, and purchase orders automatically. By resolving transactional variances instantly throughout the month, corporate accounting teams eliminate the traditional workload spikes associated with quarterly and annual closes.

Machine Learning in Audit Trails and Anomaly Detection
Advanced natural language processing (NLP) and machine learning tools are redefining internal audit and financial control environments. Automated systems analyze 100% of general ledger entries, identifying anomalous transactions, duplicate payments, and unauthorized journal entries in real time.

Rather than relying on random statistical sampling, corporate internal auditors can focus their attention on high-risk flags automatically surfaced by algorithmic monitoring platforms. This continuous risk assessment strengthens internal controls over financial reporting (ICFR) and significantly reduces fraud risk.

Evolving Roles for Accounting Professionals
As routine data entry and manual reconciliation tasks become fully automated, the skill set required for accounting professionals is shifting toward data analysis, system design, and strategic business advisory.
– Systems Governance: Accountants are increasingly responsible for monitoring algorithmic accuracy and managing data integration pipelines.
– Business Partnership: Finance professionals leverage real-time financial dashboards to advise operational leaders on margin management and working capital allocation.
– Regulatory Compliance Management: Accounting teams utilize automated platforms to ensure compliance with dynamic tax codes and international accounting standards.

Core Implementation Recommendations
1. Deploy Automated Reconciliation Tools: Integrate continuous transaction processing modules into existing enterprise ERP architectures.
2. Establish Algorithmic Governance Controls: Implement strict internal testing protocols to ensure automated accounting rules comply with GAAP/IFRS standards.
3. Reskill Accounting Teams: Invest in training finance staff on data analytics, workflow automation, and predictive financial modeling.

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