OECD's Crypto-Asset Reporting Framework: What does this mean for Cayman Islands entities with activities relating to crypto-assets?

The Cayman Islands has committed to implementing the OECD's Crypto Asset Reporting Framework (CARF). CARF is being implemented in the Cayman Islands by the Tax Information Authority (International Tax Compliance) (Crypto-Asset Reporting Framework) Regulations, 2025, as gazetted on 27 November 2025 following industry consultation, which come into force on 1 January 2026. 

As implemented in the Cayman Islands, CARF applies to entities which are incorporated, registered, established or regulated in the Cayman Islands, or have a place of effective management in the Cayman Islands, which as a business, provide a service effectuating exchange transactions for or on behalf of customers (Users), including by acting as a counterparty or intermediary or by making available a trading platform (Cayman Reporting Crypto-Asset Services Providers). This definition applies regardless of where Users are based and is likely to apply more widely than that of 'virtual asset service provider' under the Cayman Islands Virtual Asset (Service Providers) Act (as amended). Conversely, some CIMA regulated virtual asset service providers will not be in-scope of CARF.

Existing entities that fall within the Cayman Reporting Crypto-Asset Service Providers definition before 1 January 2026 will have to register with the Department of International Tax Cooperation (DITC) on or before 30 April 2026. Entities which become Cayman Reporting Crypto-Asset Service Providers on or after 1 January 2026 must register on or before 31 January of the following year. All Cayman Reporting Crypto-Asset Service Providers will also need to provide details of a principal point of contact in the Cayman Islands (which may be an agent) and a person authorised to give change notices on their behalf. 

Cayman Reporting Crypto-Asset Services Providers must obtain self-certification forms from each of their Users in order to determine each User's tax residence and conduct due diligence to identify Users which are, or have controlling persons which are, tax resident in other CARF jurisdictions (with 75 jurisdictions committed to implement CARF as at 24 November 2025). Self-certification forms need to be obtained from new Users starting from 1 January 2026, with a grace period until 31 December 2026 to obtain forms from pre-existing Users. Cayman Reporting Crypto-Asset Services Providers must then report detailed information annually to the DITC with respect to such Users, and their exchanges and transfers of crypto-assets, with penalties for non-compliance. 

Annual reporting is due on or before 30 June each year. Therefore, Cayman Reporting Crypto-Asset Services Providers will need to make their first reports on or before 30 June 2027 in respect of the reporting period from 1 January 2026 to 31 December 2026. This means starting to collect the information that will need to be reported from 1 January 2026.

Alongside CARF, the OECD has also introduced a set of amendments to the Common Reporting Standard (CRS), including to expand the definition of 'Financial Assets' to include crypto-assets and to bring certain electronic money products and central bank digital currencies into scope of the CRS. Thus, for example, crypto-custodians may not be in-scope of CARF but may be Financial Institutions in scope of amended CRS. Our advisory regarding these amendments to the CRS can be accessed here: Amendments to the Common Reporting Standard.

We recommend that Cayman entities engaging in crypto-asset related activities complete a readiness assessment as soon as possible to determine whether they are in-scope of Cayman CARF or the amended CRS and ensure that all data and due diligence arrangements are in place, including implementing required written policies and procedures to manage the process and to mitigate any risks of penalties.

Timeline

By way of reminder of some relevant dates, please see the table below.