Crypto-Asset Reporting Framework (CARF)
Registration obligations
The Crypto-Asset Reporting Framework (CARF) is the agreed standard for the Automatic Exchange of Information (AEOI) on Reporting Crypto-Asset Service Providers (RCASPs). RCASPs must register with Revenue for the CARF by 31 December in the year they become an RCASP and have one of the following nexuses in Ireland:
- They are regulated, or allowed to provide, crypto-asset services under Article 60 or Article 63 of the Markets in Crypto-Assets Regulation (MiCA) with the Central Bank of Ireland.
- They are not are not regulated, or allowed to provide, crypto-asset services under Article 60 or Article 63 of the MiCA Regulations with the Central Bank of Ireland, and meet one of the following nexus rules:
- Are resident in Ireland.
- Are incorporated in Ireland.
- Have a place of management in Ireland.
- Have a regular place of business in Ireland.
- They are effectuating Relevant Transactions through a branch in Ireland.
For example, if an RCASP becomes resident in Ireland on 5 May 2026, they must register with Revenue by 31 December 2026.
Irish-based RCASPs should use the Revenue Online Service (ROS) to register for the CARF reporting obligation.
Conditions met in one, or more, jurisdictions
Where an RCASP has multiple nexuses, it may be required to register and report in more than one jurisdiction. In order to avoid duplicate reporting, the CARF introduces a hierarchy of reporting.
Where more than one nexus applies to an RCASP, they can avoid duplicative reporting by completing all due diligence and reporting in one jurisdiction.
An RCASP should analyse which is the highest level of hierarchy that applies to it, and report for CARF purposes in that jurisdiction only. The nexus hierarchy is:
- MiCA Regulation.
- Jurisdiction of tax residence.
- Jurisdiction of incorporation or control.
- Jurisdiction of management.
- Jurisdiction where it has a regular place of business.
- Example
ABC Ltd is an RCASP and is regulated under MiCA in Ireland and incorporated in Spain.
ABC Ltd has two nexuses and is potentially subject to duplicative reporting. The highest nexus is MiCA Regulation, therefore ABC Ltd will be subject to reporting and due diligence in Ireland. ABC Ltd will complete the reporting and due diligence requirements in Ireland for all transactions it effectuates.
RCASPs that have multiple nexuses at the same level will not be required to carry out reporting in Ireland if they are reporting in:
- another Member State
- or
- a Qualified Non-Union Jurisdiction.
This is subject to certain requirements being met.
Next: Reporting obligations