Summary:
Although Crypto‑Asset Reporting Framework (CARF) has been enacted into Swiss law, Switzerland’s government announced it will delay the automatic exchange of cryptocurrency tax data with foreign jurisdictions until at least 2027. The decision follows a suspension of final decisions on partner-countries for data sharing — meaning crypto holdings and transactions in Switzerland will remain outside the planned information-sharing regime for now.
What Changed: Law Enacted, but Data Exchange Delayed
- On January 1, 2026, Switzerland will formally adopt the amended ordinance expanding the existing international automatic exchange of financial account information (AEOI) to include crypto assets.
- Under this updated law, crypto-asset service providers (exchanges, wallet providers, custodians) will be required to register, perform due diligence, and report customer information, including crypto holdings — aligning with CARF guidelines.
- However, in a recent session, the Swiss National Council’s Economic Affairs and Taxation Committee suspended deliberations on which foreign countries will be included in the data-exchange partner list. As a result, actual cross-border crypto data sharing will not start until 2027 at the earliest.
“Crypto reporting rules will sit on the books but remain inactive until Switzerland confirms mutual participation from partner states,” a statement from the Federal Council explained.
Why the Delay Matters
- Temporary loophole for international reporting: Even though domestic providers must comply with registration and reporting duties, Swiss authorities will not share crypto-account data with foreign jurisdictions until 2027 — delaying the global transparency goals intended by CARF.
- Uncertainty for cross-border crypto users and tax authorities: Without a partner-country list, crypto users with holdings in Switzerland may avoid automatic disclosures to their home tax authorities, at least temporarily. This uncertain landscape complicates compliance strategies for international investors.
- Regulatory complexity & international coordination hurdles: The postponement highlights the practical difficulties of aligning global crypto-tax information sharing — even among countries committed to the same standards under the Organisation for Economic Cooperation and Development (OECD).
What Swiss Crypto Firms & Investors Should Watch
- Compliance requirements still apply domestically: Crypto-asset service providers must register, know their clients (KYC), and maintain records as per CARF — even if data exchange is delayed.
- Potential timeline for activation: Authorities are targeting 2027 for data exchange. Crypto holders with cross-border ties should monitor updates, especially on which partner jurisdictions are selected.
- Risks for service providers with international clients: Firms operating across borders may face regulatory divergence — e.g., clients domiciled in CARF-active countries may still be subject to reporting requirements outside Switzerland, creating compliance complexity.
- Possible changes before activation: Switzerland could revise the partner-state list or requirements. Any future amendments to CARF implementation or its timeline may affect both providers and users.
Broader Implications for Global Crypto Tax Transparency
- Slow pace compared to other jurisdictions: While many countries push ahead with crypto tax-data exchange (e.g., EU via DAC8), Switzerland’s delay introduces further fragmentation in the global regulatory patchwork.
- Signal of caution among regulators: The postponement underscores how sensitive cross-border crypto-data exchanges remain, especially concerning data privacy, security standards, and diplomatic reciprocity.
- Potential advantage for “crypto-friendly” jurisdictions: Until data begins flowing, regions with delays may continue attracting cross-border capital seeking lower reporting burdens — at least temporarily.
Bottom Line
Switzerland has formally integrated CARF into its legal system, but will not begin exchanging crypto tax data internationally until at least 2027. For now, the new law primarily creates domestic reporting obligations for crypto-asset service providers — while postponing the cross-border transparency features that global regulators envisioned. Crypto investors and service providers with international exposures should watch the evolving timeline closely, as the first data exchange under CARF remains contingent on diplomatic agreements and partner-state coordination.
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