Nelson Tan
Executive Director, Tax
Be CARF ready before deadlines hit. CARF is the OECD’s global standard for the automatic exchange of tax relevant information on crypto assets. Singapore signed the CARF Multilateral Competent Authority Agreement (MCAA) in November 2024 and expects to commence exchanges in 2028, meaning data collection must begin by 2027.
What Is CARF and Why It Matters Now?
The OECD’s Crypto Asset Reporting Framework (CARF) introduces model rules, due diligence procedures, and technical XML schemas for reporting crypto asset transactions across jurisdictions. It complements the updated Common Reporting Standard (CRS 2.0) to ensure comprehensive coverage of digital instruments without duplication.
Under CARF, Reporting Crypto Asset Service Providers (RCASPs) - including exchanges, brokers, custodial wallets, NFT marketplaces, and DeFi front-end operators with sufficient control must:
- Collect user self-certifications.
- Perform due diligence on individuals, entities, and controlling persons.
- Report transaction-level data (crypto-to-fiat, crypto-to-crypto, transfers and payments) annually to their domestic tax authority for onward exchange.
Singapore’s CARF Timeline at a Glance
- Nov 2024: Singapore signed the CARF MCAA.
- 2027: Systems and processes must be operational for CARF data collection.
- 2028: First reporting and exchange window begins.
Implication: Build and test CARF data pipelines by 2026 to avoid costly remediation risks.
Our CARF Services
1. CARF Readiness Assessment
We identify gaps across governance, data, due diligence, reporting, and technology. Benchmark your operating model against OECD rules and Singapore guidance to design a clear compliance roadmap.
Deliverables:
- Gap analysis: Review your current processes against OECD CARF rules and guidance to identify any gaps.
- Design and map the flow of data to produce accurate CARF XML output for reporting.
- Compliance risk tracker and action roadmap with milestones to 2027/2028.
2. Self Certification & Due Diligence Design
Implement CARF/CRS aligned self certification capture and control frameworks for onboarding and change in circumstances.
Deliverables:
Deliverables:
- Customer tax self certification forms and workflow.
- Stand operating procedures for due diligence on individuals, entities, and controlling persons.
- Integration guidance for KYC/AML systems.
3. Registration & IRAS Engagement (Singapore)
We guide you through the steps to register with IRAS, meet notification requirements, and stay aligned with Singapore’s CARF and CRS 2.0 rules as they roll out. Our team keeps you updated on IRAS guidelines and industry best practices ahead of the 2028 reporting start date.
Deliverables:
Deliverables:
- Clear mapping of your reporting obligations.
- Support for IRAS submissions and communication with regulators.
- Training for your team on Singapore-specific CARF requirements.
4. Annual CARF Reporting & XML Build
From data extraction to CARF XML creation, we ensure accurate, regulator-ready reporting.
Deliverables:
Deliverables:
- Organised CARF data model showing all key details like transactions, wallets, and asset values.
- Creation and validation of CARF XML files following OECD/IRAS guidelines.
- Documentation for audits and regulator reviews.
5. Advisory for Complex Digital Asset Scenarios
We help you navigate challenging areas such as DeFi, NFTs, and tokenisation platforms, including non-custodial services. Our guidance incorporates the latest OECD and IRAS regulatory updates, ensuring your positions remain compliant and defensible.
Who Needs CARF Compliance?
They include:
- Centralised exchanges & brokers (account/custody, matching engines).
- Custodial wallet providers & crypto ATMs (user identification, transfers).
- NFT marketplaces & tokenisation platforms (if used for investment/payment).
- DeFi front end operators with control/sufficient influence over transactions.
- Traditional Financial Institutions offering digital asset products (CRS 2.0 overlap).
Why Choose BDO for CARF Services?
BDO is one of Singapore’s leading accounting and advisory firms, trusted by fund managers and financial institutions for CRS compliance under incentive schemes such as Section 13O, 13U, and 13D. Our CARF team is led by a former IRAS Senior Investigation Officer with experience at a Big Four accounting firm, bringing deep regulatory knowledge and practical expertise. Backed by BDO’s global network across more than 160 countries, we combine international best practices with local compliance knowledge. Most importantly, we have a deep understanding of crypto assets and digital finance, enabling us to deliver practical, future-ready solutions for CARF compliance. When you partner with BDO, you gain a team that understands both the complexity of tax transparency and the fast-evolving world of digital assets.
