1099-DA Compliance: A Strategic Guide for Crypto Businesses

Don't Let the IRS
Reconcile for You.

2026 is the first real year of digital asset broker reporting. The gap between what brokers report and what you report is where audits start. Form 1099-DA is live, the rules are still settling, and the IRS is paying attention.
Live Filing Year

2026 is the first year brokers are reporting your customers' transactions directly to the IRS

The IRS already has the broker's number. If yours doesn't match — and it probably won't without reconciliation — that's where the questions start.

Gross proceeds reported, not net gain
Default cost basis may not match yours
Mismatches without documentation trigger reviews

What 1099-DA Actually Requires

For Crypto Brokers and Exchanges

You Have a Reporting Obligation

Each customer transaction that triggers a reportable event needs to be captured, classified, and reported on Form 1099-DA with correct gross proceeds figures. This includes swap transactions, conversions, and any exchange of digital assets that constitutes a reportable event.

Getting this wrong exposes you to IRS penalties and creates reconciliation problems for your customers that trace directly back to you.

For Businesses That Received a 1099-DA

The Number on Your Form Is Not Your Tax Bill

The figure on your 1099-DA is gross proceeds — not gain, not income, not taxable profit. Filing with that number without reconciling it against your actual cost basis and transaction history means you will overpay. Significantly.

We reconcile what the broker reported against what actually happened and make sure your return reflects reality.

Where Most Businesses Get It Wrong

1099-DA introduced a mismatch problem that didn't exist before broker reporting.

RWA tokenization accounting is one of the more nuanced areas of digital asset finance. The product is real, the demand is real, and the current accounting standards still don’t have clean answers for most of what you’ve built. GAAP wasn’t designed for tokenized assets. That’s not a dead end — it means the accounting requires more judgment, more documentation, and more experience with emerging guidance than most firms have. We’ve been working through these structures with clients well before it became a trend.

THE GAP

Brokers report gross proceeds using default cost basis methods that may not match your actual acquisition history. If you’ve moved assets between wallets, used HIFO or specific identification, executed swaps across platforms, or hold assets acquired across multiple exchanges — the broker’s number and your number will be different.

THE FIX

That difference is not a problem if it’s documented and defensible. It becomes a problem when it isn’t. We build the reconciliation that explains the gap, supports your cost basis methodology, and holds up if the IRS asks questions.

What We Handle

End-to-end 1099-DA compliance coverage.

From broker reporting setup through amended return support — we handle every part of the 1099-DA compliance chain.

01

Broker Reporting Setup and Compliance

For exchanges with 1099-DA obligations — we build the reporting infrastructure and ensure every reportable event is captured and classified correctly before it goes to the IRS.

02

Swap Transaction Reporting

All digital asset exchanges — swaps, conversions, cross-platform transfers — properly captured and classified so your 1099-DA filings match your transaction history.

03

Cost Basis Reconciliation

We reconcile the figures on your 1099-DA against your actual transaction history across wallets, exchanges, and DeFi activity so your return reflects what you actually owe.

04

HIFO and Specific Identification Documentation

If you're using a non-default cost basis method, the IRS will want documentation that supports it. We build and maintain that documentation so your methodology is defensible.

05

Multi-Platform Reconciliation

Across exchanges, wallets, and DeFi activity — we pull the full transaction picture together so nothing is missing and nothing conflicts.

06

Amended Return Support and Ongoing Compliance

For businesses that filed before getting 1099-DA reconciliation right — and for making sure every future filing starts from a clean, documented baseline.

Who We Work With

If your 1099-DA and your records don't match, that's where we start.

We work with businesses across the full 1099-DA compliance picture — from brokers building reporting infrastructure to founders assessing prior filing exposure.
🏦Crypto exchanges building 1099-DA reporting infrastructure
📊Brokers with reportable transaction volumes
🔄Businesses reconciling 1099-DAs from multiple platforms
⚡High-volume traders with complex cost basis histories
🌐DeFi participants with cross-platform activity
👤Founders and CFOs assessing prior filing exposure
🔁Businesses switching from a non-specialist tax preparer

Get Your 1099-DA Right Before It Gets Complicated

The IRS has the broker’s number. Make sure yours tells the complete story.