CARF's Basic Role

CARF is a cross-border framework for the automatic exchange of tax information on crypto-assets. It designates crypto-asset service providers (CASPs) as the primary reporting entities, with the aim of enabling tax authorities in participating jurisdictions to obtain crypto-transaction data relevant to their domestic taxpayers.

Global Progress and Timeline

 According to data from the OECD Global Forum, 76 countries and regions have committed to implementing CARF by the end of 2025, with the system being rolled out in batches.

The first wave of jurisdictions plans to conduct their first automatic information exchange in 2027. This group mainly includes the UK and EU member states. The second wave plans for full implementation in 2028, which includes Singapore, the UAE, and Hong Kong, China.

Under these rules, data collection typically begins one year in advance. From 2026, crypto-asset service providers are expected to start collecting, organizing, and retaining reportable transaction information in preparation for reporting and exchange.

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‍Hong Kong, China: Clearly Signed Up and on Schedule

 Under the Global Forum’s CARF commitment process, Hong Kong (China) has committed to implement CARF and is progressing in line with the expected timeline.

 Hong Kong’s current plan is for reporting crypto-asset service providers to begin collecting CARF-required information from 2027, with the Inland Revenue Department commencing exchanges with partner jurisdictions from 2028.

 Crypto-asset service providers within Hong Kong’s regulatory perimeter will therefore need to establish the necessary data governance, due-diligence, and reporting processes so that reportable transactions can be included in the cross-border exchange framework.

Mainland China: Not Committed and Outside the Current Scope

 By contrast, Mainland China has not publicly committed to implement CARF under the Global Forum’s CARF commitment process.

 As of this stage, Mainland China is not listed in any of the CARF implementation batches, nor has it been flagged by the OECD as a jurisdiction that is relevant but has yet to commit.

 Given the current regulatory environment for crypto-asset activities in the Mainland, the near-term operational basis for CARF-style reporting and exchange appears limited.

Future Possibilities and Reality Check

 It is worth noting that Mainland China has been fully implementing the CRS since 2018 and has solid experience in exchanging financial account information.

 If crypto-asset regulatory policies change in the future, the Mainland technically and institutionally has the foundation to connect with CARF.

 However, given the current policy environment, the likelihood of Mainland China joining this framework remains low for the 2027 CARF launch and the years immediately following it.