Does Form 1099-DA cover DeFi and self-custody wallets?
No. DeFi front-ends and self-custody wallet software do not issue Form 1099-DA: the regulations that would have required it were repealed in April 2025 under the Congressional Review Act. Custodial brokers still report the sales they effect. The tax obligation is unchanged either way: DeFi activity is taxable with no form arriving, so the records have to come from wallet history.
Key takeaways
- The DeFi broker regulations (T.D. 10021) were disapproved by Congress under the Congressional Review Act and signed out of existence in April 2025; a substantially similar rule cannot return without new legislation.
- Custodial brokers still report under the separate final regulations (T.D. 10000): gross proceeds from 2025, basis for covered assets acquired from 2026.
- Under Notice 2024-57, brokers do not currently report wrapping, liquidity, staking, lending, short-sale, or notional-principal-contract transactions; all remain taxable.
- DeFi disposals go on Form 8949 with box I or L checked (no 1099-DA received), built from your own classified wallet history.
What the repeal actually changed
In December 2024 a second set of broker regulations (T.D. 10021) extended Form 1099-DA reporting to certain DeFi participants -- trading front-ends that let users reach protocol contracts -- with reporting to begin in 2027. Congress disapproved the rule under the Congressional Review Act, and the disapproval (H.J.Res. 25) was signed on April 10, 2025. The regulations were formally removed in July 2025, and the CRA bars an agency from reissuing a rule in substantially the same form without new statutory authority. The practical result: connecting a self-custody wallet to a DEX creates no reporting relationship, no collection of your identity by the protocol, and no form in the mail.
What custodial brokers still report
The repeal did not touch the original final regulations (T.D. 10000). Custodial brokers -- exchanges, hosted wallet providers, digital-asset kiosks, certain payment processors -- report gross proceeds on Form 1099-DA for sales they effect starting January 1, 2025, and basis for covered assets acquired in custody on or after January 1, 2026. The two regimes meet at the moment you move DeFi proceeds onto an exchange and sell: that sale is reported, and because the asset was transferred in, it arrives noncovered, which is exactly the proceeds-only row covered in Why does my 1099-DA show no cost basis?
Six transaction types brokers do not report
Notice 2024-57 carves out transaction types that require further study, so even custodial brokers do not currently file information returns on them: wrapping and unwrapping, liquidity-provider transactions, staking, transactions described by market participants as lending of digital assets, short sales of digital assets, and notional principal contracts. The carve-out is about reporting, not taxability -- a liquidity exit or an unwrap carries whatever treatment the law gives it, with no form either way. Grey-area shapes in that list (wrapping, liquidity, liquid staking) are precisely where a documented position matters most, because no third-party paper will ever frame the row for you.
What no form means for your records
Self-reported activity is only as good as the classification behind it. Each hash has to be typed for what it economically was -- a swap that disposes, a reward that is income at receipt, a transfer that carries basis, a liquidity event under your firm's documented position -- and since January 1, 2025, basis tracking runs wallet by wallet. On Form 8949, DeFi disposals check box I (short-term) or box L (long-term): no 1099-DA received, amounts from your records. The engine's job in this workflow is the typing: category, treatment, confidence, and an honest needs_review where the evidence does not settle the answer.
Frequently asked questions
Will a DEX or my self-custody wallet send me a 1099-DA?
No. After the April 2025 repeal of the DeFi broker rule, decentralized exchanges, protocol front-ends, and self-custody wallet software are outside the 1099-DA regime. No identity collection and no information return attach to using them. Only custodial brokers, which take possession of the assets they sell for you, issue the form.
Is DeFi still taxable if no form arrives?
Yes. The reporting repeal changed who mails paperwork, not what is taxable. Swaps are still disposals, rewards are still income at dominion and control, and liquidity events still carry whichever documented position applies. The absence of a form moves the whole recordkeeping burden onto wallet history, which is the opposite of relief.
Are staking or lending rewards reported on Form 1099-DA?
Form 1099-DA reports dispositions, not income, and under Notice 2024-57 brokers do not currently report staking or lending transactions even as dispositions. Staking rewards remain ordinary income under Rev. Rul. 2023-14 whether or not any form arrives; custodial platforms may report reward income on other information returns.
Which Form 8949 box do DeFi trades go in?
Box I for short-term and box L for long-term: digital-asset transactions for which no Form 1099-DA was received. Proceeds, basis, and dates all come from your own records, which is why the classification of each underlying transaction has to hold up on its own.
Could DeFi reporting come back later?
Not by regulation alone. The Congressional Review Act bars an agency from reissuing a disapproved rule in substantially the same form, so extending broker reporting to DeFi again would take new legislation from Congress, not a new rulemaking.
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This is informational only, not tax advice; verify with a qualified tax professional before filing.