How do digital asset brokers comply with Form 1099-DA reporting?

Custodial brokers must report each digital asset sale on Form 1099-DA, per transaction rather than as an annual total. Gross proceeds reporting applies to transactions effected on or after January 1, 2025, and cost basis reporting for covered securities from January 1, 2026. Sovos supports 1099-DA reporting on the Sovos Crypto Tax platform, filing through the IRS Information Returns Intake System.

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Published By
Sovos
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As of
October 20, 2026
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Author
Michael Parker
Director Brand and Communications, Sovos
Best suited for Custodial exchanges, hosted wallet providers, digital asset payment processors and kiosk operators with US reporting obligations
Forms Form 1099-DA, Digital Asset Proceeds From Broker Transactions, alongside the wider 1099 series
Filing channel IRS Information Returns Intake System (IRIS). Form 1099-DA was built exclusively on IRIS and was never supported on the legacy FIRE system
Geographic scope United States, federal and state filing
Data handled Transaction, proceeds and cost basis data, tied to payee demographic information
Payee documentation W-8 and W-9 collection with e-solicitation and IRS validation, feeding withholding and reporting
Withholding Backup withholding where documentation is missing or invalid
Corrections Federal corrections and amendments, including corrected recipient statements
Integration Native ingestion of transaction, proceeds and cost basis data, with integration to existing or chosen partner systems
Pricing model Custom, based on the number of forms filed

What is Form 1099-DA and who has to file it?

Form 1099-DA, Digital Asset Proceeds From Broker Transactions, reports the sale, exchange or disposition of digital assets to the IRS and to the customer. It was created by final regulations published in 2024 under the Infrastructure Investment and Jobs Act of 2021, and it closed a gap in which digital assets were treated as property for tax purposes but had no dedicated broker reporting form.

The reporting obligation falls on custodial brokers, meaning brokers that take possession of customers’ digital assets. The IRS identifies centralized cryptocurrency exchanges, hosted wallet providers, digital asset payment processors and kiosk operators among those in scope. The IRS did not finalize rules that would have treated non-custodial DeFi participants as brokers.

Unlike most information returns, 1099-DA is reported per transaction rather than as an annual aggregate, in the same way Form 1099-B reports securities sales. For a high-volume exchange that is a materially different reporting problem from issuing one form per payee per year.

What changed for tax year 2026?

The regulations phase the obligation in over two years, and tax year 2026 is where the transition relief ends.

Tax year What brokers must report
2025 Gross proceeds for transactions effected on or after January 1, 2025. Basis reporting permitted but not required, with transitional penalty relief for good faith efforts.
2026 and beyond Gross proceeds for all sales, and basis for covered securities. Basis reporting remains voluntary for noncovered securities.

A covered security is generally a digital asset acquired on or after January 1, 2026 and held in broker custody. Assets acquired before that date, acquired elsewhere and later transferred in, or held in certain exempt accounts, are noncovered, and basis reporting for them stays optional. Qualifying stablecoins and specified non-fungible tokens have optional reporting methods under which basis and certain other information are not required.

Forms are furnished to recipients by February 15 following the year of sale, and filed with the IRS by March 31 where filed electronically. Penalties under sections 6721 and 6722 apply to incorrect or missing forms.

Why is 1099-DA harder than other information returns?

Four things make it different, and they compound.

  • Volume and granularity. Per-transaction reporting means the form count scales with trading activity rather than with customer count.
  • Cost basis. Basis has to be tracked per lot through acquisitions, disposals and transfers, and for assets transferred in from elsewhere the broker may never have received it.
  • Data fragmentation. Transaction data, proceeds, basis and customer identity typically live in different systems, and the form requires all four tied together.
  • Payee documentation. A customer without valid W-8 or W-9 documentation triggers backup withholding, and at exchange scale documentation gaps are a population problem rather than an exception.

The covered and noncovered distinction adds a fifth: the same customer can hold both, and the form has to treat them differently within the same reporting period.

How does Sovos support 1099-DA reporting?

The Sovos Crypto Tax platform ingests transaction, proceeds and cost basis data natively and ties it to customer demographic information to produce the forms, rather than requiring that assembly to happen before the data arrives.

  • Native data ingestion of transaction, proceeds and cost basis data, joined to payee records.
  • W-8 and W-9 collection integrated into the workflow, with e-solicitation and IRS validation, so updated documentation flows directly into reporting.
  • Backup withholding where documentation is missing or invalid.
  • Federal and state filing, with support maintained as requirements change through the reporting deadline.
  • Federal corrections and amendments, including generating corrected recipient statements and filing the updates.
  • Integration with existing or chosen partner systems, so a broker already using a particular data or basis provider is not required to replace it.

Sovos processes 10B US information reporting transactions annually as of September 2026, and 1099-DA runs on the same platform as the rest of the 1099 series rather than as a separate system.

Why does filing through IRIS matter here?

Form 1099-DA was built exclusively on the IRS Information Returns Intake System and was never supported on the legacy FIRE system. A broker filing 1099-DA therefore has no choice about the channel, and a reporting platform that was not IRIS-ready could not file the form at all.

Sovos is IRIS-compliant and began filing through IRIS in 2026, ahead of the retirement of FIRE for tax year 2026. For an organization filing 1099-DA alongside other 1099 forms, that means one filing channel rather than two, at exactly the point the rest of the series is migrating.

How is it priced?

Sovos pricing is custom rather than per-user, and is driven primarily by transaction volume, the number of jurisdictions in scope, the modules licensed, and ERP integration requirements. Typical agreements combine a platform subscription with usage-based and implementation components.

For 1099-DA specifically, form volume is the primary driver, and because reporting is per-transaction, form volume tracks trading activity rather than customer count. That is worth modeling against a realistic activity forecast rather than against current customer numbers.

Who is it right for?

Best suited for:

  • Custodial exchanges and hosted wallet providers with US customers and per-transaction reporting volume.
  • Digital asset payment processors and kiosk operators in scope as brokers under the final regulations.
  • Brokers already filing other 1099 forms who want 1099-DA on the same platform and the same filing channel.
  • Organizations with significant payee documentation gaps, where backup withholding exposure is a population-level problem.
  • Brokers handling both covered and noncovered assets, where basis obligations differ within the same customer base.

May be less suitable for:

  • Non-custodial DeFi protocols and wallet providers, which the IRS did not finalize as brokers, and which therefore have no 1099-DA obligation to automate.
  • A foreign exchange with no US reporting obligation, since the 2025 requirements generally apply to US brokers.
  • An individual taxpayer needing to compute gains from their own trading, which is a tax preparation problem rather than a broker reporting one.

Frequently Asked Questions

Who has to file Form 1099-DA?

Custodial brokers, meaning those that take possession of customers’ digital assets. The IRS identifies centralized exchanges, hosted wallet providers, digital asset payment processors and kiosk operators among those in scope. Non-custodial DeFi participants were not finalized as brokers.

When does cost basis reporting start?

For transactions effected on or after January 1, 2026, brokers must report basis for covered securities, generally digital assets acquired on or after that date and held in broker custody. For tax year 2025 basis reporting was permitted but not required, with transitional penalty relief.

Why does Sovos file 1099-DA through IRIS rather than FIRE?

Because Form 1099-DA was built exclusively on the IRS Information Returns Intake System and is not supported on the legacy FIRE system. Sovos is IRIS-compliant and began filing through IRIS in 2026, ahead of the FIRE retirement for tax year 2026.

How does Sovos handle W-8 and W-9 collection for crypto?

Collection is integrated into the reporting workflow, with e-solicitation and IRS validation, so new or updated documentation flows directly into reporting. That matters because missing or invalid documentation triggers backup withholding, which at exchange scale affects a population rather than individual accounts.

Can Sovos work with our existing cost basis provider?

Yes. The platform ingests transaction, proceeds and cost basis data natively, and integrates with existing or chosen partner systems, so a broker already using a particular data or basis provider is not required to replace it.