Form 1099-DA for Web3 Projects and DAOs: 2025–2026 Readiness

2025 broker reporting now appears in the 2026 filing process

For sales and dispositions effected during 2025, U.S. brokers generally began reporting gross proceeds on Form 1099-DA. Most statements for 2025 transactions generally did not include basis. Taxpayers must therefore use their own records to determine basis, holding period, gain, and loss.

A Web3 company or founder may also have self-custodied, foreign-venue, contract, treasury, or peer-to-peer activity that does not appear on a U.S. broker form. The absence of a form does not remove the obligation to report taxable activity.

The 2026 framework introduces more basis reporting—but not for everything

For sales after 2025, Form 1099-DA reporting generally includes mandatory basis information for digital assets that meet the covered-security requirements. Assets can remain noncovered, and optional methods apply to some stablecoin and NFT reporting. Even a form containing basis should be reconciled to the organization’s own acquisition and transfer records.

This makes account-level recordkeeping operationally important. Moving assets between venues without carrying the acquisition history forward can leave a later disposition with incomplete support.

Entity and wallet ownership should be documented before tax season

• Maintain a current inventory of legal entities, wallets, accounts, custodians, signers, and operating purpose.
• Separate founder, employee, investor, treasury, grant, customer, and protocol-controlled activity where the facts require different treatment.
• Connect material payments and transfers to agreements, invoices, proposals, approvals, or other business evidence.
• Preserve records for token grants, vesting, airdrops, rewards, liquidity, staking, lending, bridge activity, and migrations.
• Reconcile controlled-account transfers so movement is not mislabeled as revenue, expense, or a third-party disposition.

A 2026 readiness sequence for founders and finance teams

• Collect all 2025 broker statements and corrected versions, then tie them to the transaction ledger.
• Inventory sources and activity that may not be fully reflected on those forms, including self-custodied and non-U.S. activity.
• Resolve missing basis and opening positions at the account or wallet level before preparing gain-and-loss output.
• Create an exceptions list for uncertain ownership, valuation, classification, or missing documentation.
• Coordinate the data format and open questions with the return preparer and other responsible professionals early.
• Preserve the final exports, reconciliations, assumptions, and approvals used for the filed position.

What this guide does not determine

Whether an event is taxable, which taxpayer reports it, the character and timing of income, and the treatment of a particular token or protocol depend on the facts and applicable law. This operational framework is designed to improve the records available to the qualified professionals making those determinations; it is not a substitute for their advice.