Author: Fintax

Basic positioning of CARF

CARF is a cross-border automatic exchange framework for tax information on crypto assets. It uses crypto asset service providers as the information reporting entities and supports tax authorities in various jurisdictions to obtain information on crypto transactions related to their domestic taxpayers.

Global Implementation Schedule

According to information released by the OECD Global Forum, by the end of 2025 , 76 countries and regions had committed to implementing CARF and will promote the implementation of the system in batches.

The first batch of judicial districts , including the UK and EU member states, are scheduled to begin automatic information exchange in 2027 ; the second batch of judicial districts, including Singapore, the UAE, and Hong Kong, are scheduled to fully implement the system in 2028 .

According to the system, the collection of relevant transaction data will begin one year in advance. Starting in 2026 , cryptocurrency service providers will be required to systematically organize the transaction information that can be reported.

Figure 1: Overview of CARF Implementation Progress in Major Jurisdictions

Hong Kong, China: Clearly participating and proceeding according to the schedule.

In the above arrangements, Hong Kong has made a clear commitment to implement CARF and will advance the relevant work in accordance with the international timetable.

Hong Kong plans to launch the collection of data on crypto asset transactions starting in 2027 and to begin automatic exchange of tax-related information with other cooperating jurisdictions in 2028 .

Crypto asset service providers operating under the Hong Kong regulatory framework are required to establish corresponding data compliance and reporting mechanisms, and relevant reportable transactions will be included in the cross-border information exchange process.

Mainland China: Not yet committed and not within the scope of implementation

In contrast, mainland China has not yet made any commitment to implement CARF .

To date, mainland China has not been included in any CARF implementation batch, nor has it been listed by the OECD as a relevant jurisdiction that has not yet committed to participation.

Under the current regulatory framework, mainland China adopts a strict approach to cryptocurrency trading activities. There are no legitimate crypto asset service providers within the country that can be included in the CARF reporting system. Therefore, in the short term, the institutional conditions for participating in CARF's regular information exchange are not met.

Future Possibilities and Reality Assessment

It should be noted that China has fully implemented CRS since 2018 and has mature experience in the exchange of financial account information.

If future regulations on crypto assets are adjusted, mainland China has the institutional and technical conditions to align with CARF .

However, given the current policy environment, the likelihood of mainland China joining the CARF framework in 2027 and in the years that follow remains low.

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