A bare room with daylight falling across one part of the wall and floor while the rest stays in shadow, tinted navy, beside the statement that for 2025 brokers generally report gross proceeds only — not cost basis.
Form 1099-DA tells the IRS what you sold for, not what you owe. For 2025 it generally shows gross proceeds only, without cost basis — so you still calculate gain or loss yourself, and report every taxable transaction whether or not a form arrived.

Form 1099-DA is the information return your crypto broker files with the Internal Revenue Service (IRS) reporting your digital asset sales. It first applies to transactions on or after January 1, 2025, so the forms arriving now cover last year’s trading. For 2025 it generally shows gross proceeds only, not cost basis — meaning it tells the IRS what you sold for, not what you owe. You must still calculate gain or loss yourself, and report every taxable transaction whether or not you received a form.

One distinction matters more than any other on this page: repealing a broker’s reporting rule does not repeal your reporting duty. Your DeFi trades not showing up on a 1099-DA does not mean the IRS doesn’t expect you to report them — it means nobody reported them for you.

What is Form 1099-DA?

Form 1099-DA, Digital Asset Proceeds From Broker Transactions, is the information return brokers use to report digital asset sales to both the taxpayer and the IRS, per the IRS’s About Form 1099-DA page. A broker, in the sense that matters here, is a party required to report under Internal Revenue Code section 6045 — historically stockbrokers and similar intermediaries, now extended to certain digital asset platforms as well. For the wider enforcement and compliance picture this one form sits inside, see our IRS cryptocurrency tax guidelines.

Who sends it and when

Form 1099-DA applies to digital asset transactions on or after January 1, 2025. Brokers furnish the form to taxpayers and file it with the IRS in early 2026, covering the prior year’s activity — which is why a form for 2025 trading is arriving in your mailbox or brokerage account right now.

What appears on the form

For a covered transaction, the form generally reports gross proceeds — the total amount received from a sale or exchange — along with a digital asset identifier (the specific token or coin), the date of the transaction, and the broker’s information. See the IRS’s own walkthrough on understanding your Form 1099-DA.

Why your 1099-DA shows proceeds but no cost basis

This is the single most common source of confusion this filing season, and the highest-converting question to get right.

The phase-in

The rule was phased in deliberately. For 2025 transactions, brokers generally report gross proceeds only. Cost basis reporting begins for certain transactions on or after January 1, 2026 — a distinction confirmed in the IRS’s final regulations and related guidance for broker reporting. Your 2025 form telling you what you sold for, without telling you what you paid, is not a defect in the form. It’s the rule working as designed in year one of the phase-in.

A five-station timeline of Form 1099-DA reporting — the form applies to transactions on or after January 1 2025, the DeFi broker rule TD 10021 is nullified by Public Law 119-5 on April 10 2025 and formally removed on July 11 2025, 2025 forms arrive in early 2026, and cost basis reporting begins from January 1 2026 — with notes that 2025 forms generally carry gross proceeds only and that basis reporting begins for certain transactions.
For 2025, brokers generally report gross proceeds only — no cost basis. Cost basis reporting begins for certain transactions from January 1, 2026, covered assets first; an uncovered asset may never get a broker-reported basis at all. Repealing a broker’s reporting rule does not repeal your reporting duty.

Covered vs. uncovered assets

A digital asset is a covered asset once a broker has basis information for it on file — generally, an asset acquired through that broker on or after the rule’s effective date, where the broker has a reliable acquisition record. An uncovered asset is one the broker lacks reliable basis information for, most often because you acquired it before the broker’s records began, or moved it in from elsewhere. Basis reporting rolls out for covered assets first; uncovered assets may never get a broker-reported basis at all.

Why transfers in from an outside wallet break basis

If you bought crypto on one exchange, moved it to a hardware wallet, then later moved it to a different exchange and sold it there, the selling broker has no reliable record of what you originally paid. It can report what you sold for. It generally cannot report what you paid, because it never saw that transaction. This is the single most common reason a 1099-DA arrives with proceeds but no usable basis figure — and it is a completely normal outcome of moving assets between wallets and exchanges, not an error on the form.

What Form 1099-DA does not cover

Wallet-to-wallet transfers

Moving your own crypto from one wallet or exchange to another you also control is not a taxable sale, and it is not what Form 1099-DA reports on. It does, however, break the basis chain described above — which is exactly why keeping your own transaction records matters regardless of what any broker sends you.

Staking rewards and airdrops

Staking rewards and airdrops are separate transactions with their own tax treatment (below), and they are not what Form 1099-DA is built to report. Don’t expect the form to capture them.

DeFi and decentralized exchange activity

Trades executed through decentralized exchanges and DeFi protocols generally do not generate a Form 1099-DA at all, for reasons covered in detail in the next section. Running a DeFi protocol or Web3 startup rather than filing as an individual investor? See our DeFi accounting guide instead.

“1099-DA tells the IRS what a broker saw — not what you owe.”
A split comparison of what Form 1099-DA reports — sales and exchanges on a centralized custodial exchange, gross proceeds, and the asset, date and broker details — against what it does not: wallet-to-wallet transfers between your own wallets, staking rewards and airdrops, and DeFi and decentralized exchange trades, each labelled with its own tax status.
Not on the form is not the same as not taxable. A wallet-to-wallet transfer between wallets you control is not a taxable sale, but it breaks the basis chain. Staking rewards and airdrops are ordinary income at fair market value when you gain dominion and control, per Revenue Ruling 2023-14. DeFi trades are fully taxable and reportable — no form is issued, so nobody reported them for you.

The DeFi broker rule was repealed. Here’s what that actually means.

This is the part most crypto tax content gets wrong, because most of it was written before this happened and never updated.

What TD 10021 would have required

Treasury Decision (TD) 10021 was a 2024 regulation that would have extended the digital asset broker reporting rules to certain decentralized finance platforms and front-end trading services — treating DeFi interfaces as brokers with their own Form 1099-DA filing obligations, alongside custodial exchanges.

How it was undone: H.J.Res. 25 → Public Law 119-5 (April 10, 2025) → IRS revocation (July 11, 2025)

TD 10021 never took lasting effect. Congress disapproved the rule under the Congressional Review Act through H.J.Res. 25, which became Public Law 119-5 on April 10, 2025. The IRS’s own Internal Revenue Bulletin 2025-31 states that, as a result, TD 10021 “has no legal force or effect,” and that Treasury and the IRS would remove the rule from the Code of Federal Regulations and revert the relevant text of 26 CFR back to what it was before TD 10021 took effect — a removal formally carried out on July 11, 2025.

“The DeFi broker reporting rule, Treasury Decision 10021, was nullified under the Congressional Review Act by Public Law 119-5 on April 10, 2025, and formally removed by the IRS on July 11, 2025.”

Centralized and custodial exchanges are still brokers — Form 1099-DA still applies to them

The repeal only unwound the new DeFi-specific broker definition TD 10021 would have created. It did not touch the underlying section 6045 broker rules that already applied to centralized, custodial digital asset exchanges. Those platforms remain brokers, and Form 1099-DA continues to apply to the transactions you make on them.

Your obligation did not change. No form does not mean no tax.

This is the single most important sentence in this article: repealing the DeFi broker rule removed a reporting obligation from platforms — not a reporting obligation from taxpayers. DeFi front-ends and decentralized exchanges are not brokers under the rule that survived the repeal, so they don’t issue you a Form 1099-DA. That silence is easy to misread as “nothing to report.” It means the opposite: nobody reported it for you, so the full burden of tracking, calculating and reporting every DeFi trade, swap and yield event sits with you alone. The IRS’s own reminders for taxpayers about digital assets page is direct on this point — you must report all income, gains and losses from digital asset transactions whether or not you receive a form. Transactions on decentralized exchanges remain fully taxable and reportable, form or no form.

A three-lane diagram crossing a dated marker — centralized and custodial exchanges continue as brokers under section 6045, the DeFi front-end lane is drawn as a dashed line that stops and is struck through at the April and July 2025 repeal of TD 10021, and the taxpayer's own reporting duty continues unbroken past the marker.
Repealing the DeFi broker rule removed a reporting obligation from platforms — not a reporting obligation from taxpayers. Centralized and custodial exchanges remain brokers under section 6045 and still file Form 1099-DA; DeFi front-ends do not; and you report all income, gains and losses from digital asset transactions whether or not you receive a form.

How to report digital assets on your return

The digital asset question on Form 1040

Every Form 1040 asks whether, during the year, you received (as a reward, award or payment for property or services), sold, exchanged, or otherwise disposed of a digital asset (or a financial interest in one). The IRS’s digital assets hub page confirms this question must be answered accurately regardless of whether you received any broker forms — and yes, even if you only bought and held.

Sales and exchanges: Form 8949 → Schedule D

Sales, trades and other dispositions of digital assets are reported on Form 8949, and the totals flow to Schedule D. This applies whether the sale generated a Form 1099-DA or not — the form, when you have one, is a starting point for your own records, not a substitute for them. Trading frequently and weighing which lots to sell? See our guide to cost basis methods for active traders.

Staking rewards: ordinary income at fair market value when you gain dominion and control (Revenue Ruling 2023-14)

Staking rewards are included in gross income at fair market value in the taxable year the taxpayer gains dominion and control over them — the moment you can sell, exchange or otherwise dispose of the reward — per the IRS’s Revenue Ruling 2023-14. Reported as ordinary income on Schedule 1, this is treated as income when received, separately from any later capital gain or loss when the rewards are eventually sold.

Reporting when you received no form at all

Received no Form 1099-DA — because you traded through a DeFi protocol, or because a smaller platform hasn’t caught up to the reporting rules yet? The obligation to report is the same either way. Build your own record of every disposition — date, proceeds, basis where known — and report it on Form 8949 regardless of what paperwork, if any, arrived in the mail.

Cost basis: Revenue Procedure 2024-28 and the wallet-by-wallet rule

If you traded across more than one exchange or moved assets to self-custody at any point, this section is the one worth reading twice.

What the safe harbor required and by when

Revenue Procedure 2024-28 created a transition safe harbor for taxpayers moving from older “universal” basis-tracking methods to the new wallet-by-wallet, account-by-account basis rules that took effect January 1, 2025. It let taxpayers holding digital assets across multiple wallets or accounts as of that date make a reasonable allocation of previously unattached cost basis to the specific wallets and accounts holding the remaining units — by the earlier of (a) the date of the first sale, disposition or transfer of that digital asset on or after January 1, 2025, or (b) the due date, including extensions, of the return for the year that includes January 1, 2025.

What to do if you missed it

Missing that window doesn’t erase the underlying basis you actually have, but it does mean you lose the benefit of choosing the allocation yourself. Without a reasonable allocation on file, basis is determined under the default first-in, first-out (FIFO) rule applied within each wallet or account going forward, rather than the specific-identification method you might otherwise have preferred. If this applies to you, get your records reconstructed and your position documented before your next disposition, not after.

Reconstructing basis across multiple venues

Reconstructing basis across several exchanges and self-custody wallets means pulling together every acquisition record — purchase date, price, and fees — and matching it to what actually remains in each wallet or account today. This is where the reconciliation gets genuinely difficult, and where multi-venue and DeFi activity is the hardest work we do: holders across Manhattan and Brooklyn with positions spread over several exchanges and personal wallets are exactly the reconciliations that eat an entire filing season if handled alone. Our cryptocurrency accounting service exists specifically to rebuild this basis history before the numbers on your return are wrong in a way that costs you later. If part of that history sits outside the US, see our guide on crypto held on foreign exchanges.

What to do before you file

Step 1 — Pull every Form 1099-DA you received, and confirm which figures on it are proceeds-only versus basis-included.

Step 2 — Build a full transaction log for the year, including any DeFi trades, wallet-to-wallet transfers, staking rewards and airdrops that no broker reported.

Step 3 — Confirm your cost basis allocation. If you hold assets across more than one wallet or exchange, verify whether your Revenue Procedure 2024-28 allocation was made, and by whom.

Step 4 — Match every disposition to Form 8949, with staking and airdrop income reported separately on Schedule 1.

Step 5 — Answer the digital asset question on Form 1040 accurately, based on your actual activity for the year — not on which forms happened to arrive.

Step 6 — Reconcile before you file, not after. If your own records and your 1099-DA totals don’t match, resolve the difference before submitting, not in response to an IRS notice.

We reconcile crypto tax reporting for New York clients every filing season

A 1099-DA is a starting point, not a finished return — especially once DeFi activity, staking rewards, or transfers across more than one wallet are involved. We reconcile these for clients across Manhattan, Brooklyn and the rest of New York every filing season, matching what your exchanges reported against what you actually did. If your DeFi activity is the piece with no paperwork behind it at all, our DeFi tax accounting service is built for exactly that gap. Earned staking rewards this year? See our staking rewards tax service. Book a free 30-minute call and bring your 1099-DA — we’ll tell you what it’s missing in the first ten minutes.

Frequently asked questions

What is Form 1099-DA?

Form 1099-DA is the information return crypto brokers file with the IRS reporting your digital asset sales. It first applies to transactions on or after January 1, 2025, with brokers reporting to taxpayers and the IRS in 2026.

Why doesn’t my Form 1099-DA show cost basis?

For 2025 transactions, brokers generally report gross proceeds only. Cost basis reporting begins for certain transactions on or after January 1, 2026 — this is a deliberate phase-in, not an error on your form.

Do I have to report crypto if I didn’t receive a Form 1099-DA?

Yes. The IRS requires you to report all income, gains and losses from digital asset transactions whether or not you receive a form — this applies to DeFi and decentralized exchange activity in particular.

Does Form 1099-DA cover DeFi and decentralized exchanges?

No. The DeFi broker rule was repealed in 2025, so DeFi front-ends do not issue the form — but your transactions there are still fully taxable and reportable. The repeal removed a reporting duty from platforms, not from you.

Which form do I use to report crypto sales?

Form 8949, with totals summarized on Schedule D.

How are staking rewards taxed?

As ordinary income at fair market value in the year you gain dominion and control over the reward, per Revenue Ruling 2023-14, reported on Schedule 1 — separately from any later capital gain or loss when you sell the rewards.

What is the wallet-by-wallet cost basis rule?

Since January 1, 2025, cost basis is tracked per wallet or account rather than pooled across all your holdings. Revenue Procedure 2024-28 offered a one-time safe harbor to reasonably allocate previously unattached basis to specific wallets, with a deadline tied to your first 2025 disposition or your filing due date, whichever came first.

What happens if my 1099-DA doesn’t match my own records?

Resolve the difference before you file. The form reflects only what the broker saw — transfers in from outside wallets, DeFi activity, and staking rewards it isn’t built to capture will all create gaps between the form and your actual tax position.

Do I still answer the digital asset question on Form 1040 if I only bought and held?

Yes. The question asks about receiving, selling, exchanging or otherwise disposing of digital assets during the year, and it must be answered accurately regardless of which broker forms, if any, you received.


Disclaimer: This article is general information, not personal tax advice. Cost basis reconstruction and DeFi reporting depend on your specific transaction history across every wallet and exchange you’ve used — have a CPA review your actual records before you file.