Starting 1 January 2026, Gemini (along with other UK Cryptoasset Service Providers) is required to collect certain tax information from its customers and annually report certain transactions to HM Revenue & Customs (HMRC) as part of the CryptoassetReporting Framework (CARF). The CARF is a tax reporting standard that provides HMRC visibility into cryptoasset tax compliance of UK tax residents. The CARF also allows HMRC to identify users of UK cryptoasset platforms that are tax resident in countries outside of the UK. If HMRC has an international tax data sharing agreement in place with the user’s home country, they will transfer that user’s tax data to the tax authorities in their home country of tax residence.
The CARF objectives are similar to tax reporting frameworks for traditional financial products like bank accounts and fund shares under the Common Reporting Standard (CRS) which has been in place globally since 2016.
What tax data will be collected?
In order to perform annual tax reporting, Gemini is required to collect and validate the following tax identification information about our customers:
- Individuals: name, address, country(ies) of tax residence, tax identification number (TIN), and date of birth
- Institutional/Entities: name, address, country(ies) of tax residence, tax identification number (TIN)
- For certain institutional/entities we may be required to collect the information listed under “Individuals” regarding the so-called “Controlling Persons” of the organization as well as their role(s) (e.g. owner, senior managing official, trustee, etc) similar to AML/KYC identification procedures
When will tax data collection happen?
For customers that open an account on or after January 1, 2026, this information will be collected at the onboarding stage. For customers whose accounts were open prior to that date, the same information is required to be collected before 31 December 2026.
What happens if Gemini cannot collect the required customer tax data?
If a customer does not provide Gemini with the requested tax data within the time limits noted in our request, then Gemini may be required to freeze certain activities on the customer account. Customers may be prevented from making future purchases, sales, exchanges, transfers, and participating in income producing activities until the requested information is provided.
What is Gemini required to report to HMRC?
In addition to the tax identification information of reportable customers, Gemini is required to report aggregated transaction information about certain transactions and accounts such as:
- Cryptoasset transfers in to and out from Gemini, purchases, sales, exchanges between cryptoassets, and income earned
- For certain cryptoasset or account types, year-end account balances may be reportable under the CRS (such as certain regulated stable coins, fiat e-money wallets, and derivative financial instruments)
Gemini does not report any wallet addresses as part of the standard CARF reporting. However, we are required to retain this information in accordance with HMRC data retention requirements. We may be required to provide wallet address information to HMRC under special inquiries.
Customers who are tax-resident in a country outside of the UK may have their information transferred by HMRC (not Gemini) to their country of tax residence in accordance with international tax data sharing agreements. HMRC will maintain a list of these countries on their website as agreements are finalised.
Will Gemini report my pre-2026 crypto-asset transactions under CARF?
No. There are no circumstances in the CARF requirements where pre-2026 cryptoasset transactions are reported to HMRC.
When will Gemini report tax data?
Gemini will submit the first annual reports of (2026) tax data to HMRC in 2027 between 1 January and 31 May 2027. Pre-2026 transactions are not reportable. If you are a tax resident in a country outside of the UK then HMRC is expected to exchange your 2026 tax data to your country of tax residence from 2027 onwards.
What types of crypto assets are reportable?
Under the CARF, any cryptoasset that can be used for payment or investment purposes is reportable including BTC, ETH, tokenized financial instruments, wrapped tokens, and many stable coins. Certain regulated stablecoins may not be reportable under CARF but their account balance will be reportable under CRS instead along with fiat e-money wallet accounts and certain derivative financial instruments.
Are assets that are not crypto-assets reportable, like a fiat e-money wallet?
Yes. Though CARF is tax reporting for cryptoassets that rely on blockchain technology, other cryptoassets held with Gemini may also be reportable under CRS or even the Foreign Account Tax Compliance Act (FATCA) for certain US Persons. Fiat e-money wallets and derivative instruments that do not rely on blockchain technology may be reportable under CRS or FATCA.
Can I move assets to another platform that does not have to comply with CARF?
Gemini is not alone in implementing the CARF. The CARF requires Cryptoasset Service Providers like exchanges, brokers, and dealers to collect and report tax data to the tax authorities if they are doing business in a country that has adopted the CARF. This can even include certain decentralized exchanges or DeFi platforms that exert sufficient control to identify their users. You can view the list of countries adopting CARF on the website of the Organisation for Economic Co-operation and Development (OECD).