Form 1099-DA and the End of Plausible Deniability

Custodial brokers — centralized exchanges and hosted-wallet providers — must report gross proceeds on Form 1099-DA for dispositions on or after January 1, 2025, with the first forms furnished in early 2026; cost-basis reporting phases in for covered assets acquired on or after January 1, 2026. The matching is automatic. The IRS sees your proceeds whether or not you file a Schedule D, exactly as with equities, and an unreported 1099-DA triggers the same automated underpayment notice as an unreported stock sale.

One gap remains, and it is not one worth exploiting. The separate “DeFi broker” regulations, which would have forced decentralized exchanges to issue 1099-DAs, were repealed by Congress in 2025. Non-custodial and on-chain activity therefore generates no third-party form — but the tax is owed all the same, the ledger is public and permanent, and chain analytics make reconstruction a question of when, not whether. Treat the absence of a form as the absence of a reminder, not the absence of a liability.