Did you know … that CARF impacts all banks with a securities offering?

The Crypto-Asset Reporting Framework (CARF) will become effective in Switzerland on 1 January 2026. A common misunderstanding is that CARF is only about cryptocurrencies like Bitcoin and Ether. However, CARF also captures tokenised securities, some of which can even be acquired and custodied through traditional channels (e.g. dual-listed bonds). Thus, all banks with a securities offering will be affected by CARF and either need to implement the new rules or prevent clients from acquiring and holding in-scope instruments going forward.

CARF captures so-called “relevant crypto-assets”, which means any:

“digital representation of value that relies on a cryptographically secured distributed ledger or a similar technology to validate and secure transactions” (CARF Sec. IV.A.1)

unless such crypto-asset:

• Is a central bank digital currency (CBDC),
• Is a so-called “specified electronic money product”, which encompasses certain fiat-backed stablecoins, or
• Cannot be used for payment or investment purposes.

CARF is introduced as a response to the rapid growth of the crypto-asset market and because tax authorities claim to not have adequate visibility on when taxpayers engage in tax-relevant transactions in, or hold, crypto-assets. The latter is the result of many crypto-assets not being captured by the existing Common Reporting Standard (CRS), and even if they are, investors could also hold such assets in cold wallets or with crypto-asset exchanges that are not subject to CRS reporting.

Nevertheless, the broad “relevant crypto-asset” definition included in the CARF standard also includes certain instruments that are already in scope of CRS because they fall under the “financial asset” definition. Examples include:

• Digital bonds (such as the ones listed on the SIX Digital Exchange, SDX: https://www.sdx.com/main-register/),
• Tokenised shares in investment funds, and
• Tokenised derivatives.

It is expected that data providers (e.g. SIX Financial Information) will make available information which financial instruments fall under CARF. Where such instruments are also subject to CRS, they generally need to be considered under both regimes going forward, as neither CARF nor CRS provide for a blanket exception for assets covered under the other regime. Instead, the updated CRS (“CRS 2.0”) only provides for the possibility to not report gross proceeds from such assets, while their value and the respective income remain CRS-reportable.

As some of the affected instruments can even be acquired and custodied through traditional channels (e.g. the SDX-listed digital bonds can also be acquired and custodied through SIX SIS), all banks with a securities offering will be affected by CARF in one way or another. Thus, banks need to act even if they are not offering wallet services or investments in cryptocurrencies like Bitcoin and Ether.

Next steps

To ensure compliance with CARF, banks with a securities offering must either:

• Adhere to all CARF obligations, including registration, due diligence of clients investing in relevant crypto-assets, client notification and reporting, or
• Implement a CARF “opt-out” strategy by preventing clients from acquiring and holding any relevant crypto-assets (incl. those that simultaneously qualify as financial assets under CRS), which also requires a liquidation of existing positions before 31 December 2025.

In Switzerland, non-compliance with the CARF requirements may result in fines up to CHF 250’000. With a bit more than half a year before CARF comes into force, it is now the time to act.

How Deloitte can support

Deloitte’s FSI Tax team combines thought leadership regarding CARF interpretation and implementation with in-depth understanding of the financial and crypto industry and applicable business processes as well as long-lasting experience from the implementation of other information reporting regimes (CRS, FATCA, QI etc.). If you need any support determining how you are impacted by CARF or how to comply with CARF, please do reach out to our key contacts below.