Author: FinTax
Basic Positioning of CARF
CARF is a cross-border tax information automatic exchange framework targeting crypto-assets, with Crypto-Asset Service Providers (CASPs) as the primary reporting entities. It is designed to support tax authorities in various jurisdictions in obtaining information related to crypto transactions of their taxpayers.
Global Implementation Progress and Timeline
According to information released by the OECD Global Forum, as of the end of 2025, 76 countries and regions have committed to implementing CARF and will advance its adoption in batches.
The first batch of jurisdictions, primarily including the UK and EU member states, plans to commence the first automatic information exchange in 2027. The second batch, including Singapore, the UAE, and Hong Kong, China, plans to fully implement the framework in 2028.
Under the framework's arrangements, the collection of relevant transaction data will commence one year in advance. Starting from 2026, Crypto-Asset Service Providers will need to systematically organize reportable transaction information.
Hong Kong, China: Clear Commitment and Progress According to Schedule
Within the aforementioned arrangements, Hong Kong, China has explicitly committed to implementing CARF and will advance related work according to the international timeline.
Hong Kong plans to initiate the collection of crypto-asset transaction data starting in 2027 and to conduct automatic exchange of tax-relevant information with other cooperating jurisdictions in 2028.
Crypto-Asset Service Providers operating under Hong Kong's regulatory framework are required to establish corresponding data compliance and reporting mechanisms. Relevant reportable transactions will be incorporated into the cross-border information exchange process.
Mainland China: No Commitment and Currently Outside the Implementation Scope
In contrast, Mainland China has not yet made a commitment to implement CARF.
As of this stage, Mainland China is not included in any implementation batch of CARF, nor has it been listed by the OECD as a jurisdiction that is relevant but has not yet committed to participation.
Under the current regulatory framework, Mainland China maintains a strict restrictive stance towards cryptocurrency trading activities. There are no legal Crypto-Asset Service Providers within the mainland that could be incorporated into the CARF reporting system. Therefore, in the short term, it lacks the institutional conditions to participate in CARF's regularized information exchange.
Future Possibilities and Realistic Assessment
It should be noted that Mainland China has fully implemented CRS since 2018 and possesses mature experience in financial account information exchange.
If future adjustments are made to crypto-asset regulatory policies, the mainland possesses the institutional and technical conditions to interface with CARF.
However, given the current policy environment, the likelihood of Mainland China joining this framework around 2027 when CARF commences or in the subsequent several years remains relatively low.
