What changes for 2026 sales?
I compare your Form 1099-DA with your transaction records before calculating a gain or loss. Gross proceeds alone do not show profit.
For 2026, brokers generally report basis for covered digital assets acquired after 2025 and held continuously in the same custodial account. Earlier purchases and transferred-in assets are noncovered. Under the optional methods for qualifying stablecoins and specified NFTs, a broker may leave basis blank even for covered assets. A missing basis entry does not mean your basis was zero.
A broker may voluntarily report basis for a noncovered asset. I still check that figure against your records.
Source: IRS 2026 Form 1099-DA instructions (opens in a new tab), 2026 revision, read October 26, 2026; definitions, optional reporting methods and boxes 1g, 2 and 9.
Why might a transaction be missing?
Special reporting rules apply to certain payment processors, qualifying stablecoins and specified NFTs. They are not general tax exemptions.
Payment-processor (PDAP) sales need not be reported when a customer's total for the year is $600 or less. Under optional methods, designated stablecoin sales have a $10,000 threshold and specified NFT sales have a $600 threshold. Each rule has its own conditions and aggregation method. The broker's reporting choice does not decide whether you owe tax.
Decentralized platforms that never take possession of your assets do not issue the form. Notice 2024-57 also excludes staking, wrapping, lending and liquidity-pool transactions for now.
Source: IRS 2026 Form 1099-DA instructions (opens in a new tab), de minimis, optional reporting and exceptions sections; IRS digital assets page (opens in a new tab), broker compliance section. Both read October 26, 2026.
What should I gather?
Keep each exchange's trade history, wallet addresses, transfer records, transaction fees and prior-year basis schedules. Include closed accounts and wallets that no longer hold assets.
I look for missing purchases, transfers mistaken for sales, duplicate imports and fees counted twice. A transfer record should connect the outgoing and incoming entries. A year-end balance alone cannot establish the cost of each asset sold.
Reconcile corrections with the broker when a form is wrong. Keep the original form, corrected form and explanation together.
Does transition relief remove the tax?
No. Notice 2024-56 provides specified broker penalty and withholding relief, including good-faith penalty relief for 2025 transactions. Notice 2025-33 extends certain backup-withholding relief through 2026. Neither makes a taxable sale tax-free.
Sources: Notice 2024-56 (opens in a new tab), published 2024; Notice 2025-33 (opens in a new tab), published 2025. Both read October 26, 2026.
What about older basis records?
Revenue Procedure 2024-28 addresses the transition from unused universal basis to wallet or account allocations. It is not permission to reset basis in 2026.
Notice 2026-20 extends temporary identification relief for broker-held units through December 31, 2026, subject to its conditions. Keep timely identification records; do not assume an after-the-fact spreadsheet changes which units were sold. Units you identify in your own records under the notice control, even if the broker's 2026 form shows different basis.
Sources: Revenue Procedure 2024-28 (opens in a new tab), published 2024; Notice 2026-20 (opens in a new tab), published 2026. Read October 26, 2026.
Ask about the records you have
Related reading: 1099-DA Basis Trap | Crypto Cost Basis Methods
You can describe your exchanges, approximate transaction volume and missing records through written intake. Keep account credentials, wallet keys and tax documents out of the inquiry form.
