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No 1099-DA? You Still Have to Report Crypto

Short answer: Yes. The IRS says that whether or not you receive a Form 1099-DA, you must report all income, gains and losses from digital asset transactions on your federal return. Not receiving a form is not a reason to skip reporting.

What the IRS says

• Understanding your Form 1099-DA (updated June 28, 2026): "Whether or not you receive a Form 1099-DA, you must report all income, gains and losses from digital asset transactions on your federal income tax return."
• IRS Tax Tip 2026-07 (Jan. 28, 2026): "Every taxpayer must report any related income, gains, or losses, whether they receive a Form 1099-DA or not."
• The same Tax Tip says most statements for 2025 transactions would not include basis, so taxpayers have to calculate basis to determine gain or loss.

Why you may not get a form

1. Foreign exchanges. The IRS says that for 2025 the Form 1099-DA filing requirements generally apply to U.S. brokers, so taxpayers using foreign brokers "may not receive a Form 1099-DA". Taxable transactions with foreign brokers must still be reported.
2. Not a broker transaction. The IRS lists transactions that trigger a form when a broker effects them. Activity outside a broker, such as some on-chain or peer-to-peer activity, is not something we can tell you a form will cover; the reporting duty is yours either way. (We did not find IRS text specifically about DeFi in the pages read; see below.)
3. Rewards, staking and similar income. Our reading of the Form 1099-DA instructions is that these are not reported on a 1099-DA as proceeds. You may still have income to report (the IRS digital assets page lists receiving digital assets as payment, rewards, mining, staking and similar activities as "Yes" transactions).
4. Broker de minimis rules. The instructions let brokers skip reporting in narrow cases (for example certain stablecoin, specified NFT and payment-processor sales under thresholds). These rules are about the broker's reporting duty. They do not create a de minimis exemption for you.

The digital asset question on your return

Federal income tax returns, including Form 1040, ask you to answer "Yes" or "No": at any time during the year, did you (a) receive a digital asset as a reward, award or payment for property or services; or (b) sell, exchange, or otherwise dispose of a digital asset or a financial interest in one?

Per the IRS digital assets page:

• "No" if you only held digital assets, only bought with real currency without selling, or only moved assets between wallets or accounts you own (unless you paid a transfer fee with digital assets, which is a transaction).
• "Yes" if you received digital assets as payment, a reward, mining/staking and similar activity, or an airdrop related to a hard fork, or disposed of assets for other digital assets, dollars, goods or services, or by paying a fee in digital assets.

The IRS provides a questionnaire to help answer it. A "Yes" answer means you must report the transactions whether or not they result in a taxable gain or loss.

Records to gather

Per the IRS: records documenting purchase, receipt, sale, exchange or other disposition; and the U.S. dollar fair market value of assets received as income or payment in a business. For each disposal: type of asset, date and time, units, fair market value in U.S. dollars at the time, and basis.

Practical list: CSV exports from every exchange (including foreign ones); wallet addresses and on-chain transaction IDs; bank/card statements for purchases; prior-year returns; any Forms 1099 (DA, B, MISC, NEC) you did receive.

Where it goes

Capital gains and losses go on Form 8949 and Schedule D; see 1099-DA vs Form 8949. If you have no 1099-DA, the IRS Form 8949 boxes for digital assets are I (short term) and L (long term), per the 2025 Form 8949 instructions as read. Income received as payment or rewards is reported differently (not covered here).

FAQ

I only sold a little. Do I report? The IRS pages we read set no minimum for you.

I got a 1099-DA from one exchange but used three. Report all three? Yes; the duty covers all transactions.

I lost money. Do I report? The IRS says to report transactions whether or not they result in a gain or loss. The exchange is outside the U.S. You still report; you may not get a form.

What we could not verify

• IRS text specifically about DeFi, wallet-to-wallet swaps without a broker, or foreign-exchange reporting beyond FBAR-type rules (not covered here).
• Penalties for non-reporting (not read).
• Whether a given exchange is a "broker" for 1099-DA purposes.

Sources (IRS)

• IRS, Understanding your Form 1099-DA — https://www.irs.gov/businesses/understanding-your-form-1099-da (page updated June 28, 2026; read October 17, 2026)
• IRS, Instructions for Form 1099-DA (2026) — https://www.irs.gov/instructions/i1099da (read October 17, 2026)
• IRS, Instructions for Form 8949 (2025 revision) — https://www.irs.gov/instructions/i8949 (read October 17, 2026)
• IRS, Reminders for taxpayers about digital assets (IRS Tax Tip 2026-07, Jan. 28, 2026) — https://www.irs.gov/newsroom/reminders-for-taxpayers-about-digital-assets (read October 17, 2026)
• IRS, Digital assets — https://www.irs.gov/filing/digital-assets (read October 17, 2026)

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Not tax advice. Examples use made-up figures. Nothing here has been reviewed by a tax professional. We may earn commissions from affiliate links where marked; see the disclosure.