From the journal

British Virgin Islands Confirms OECD CARF Adoption with First Crypto-Asset Information Exchanges in 2028

The British Virgin Islands has committed to the OECD's Crypto-Asset Reporting Framework (CARF), with the first exchanges of crypto-asset information scheduled for 2028. BVI-based reporting Crypto-Asset Service Providers will collect transaction, identity, and tax residence data from 2027 onward. The BVI International Tax Authority is the competent authority. CRS 2.0 entered force in the BVI on 1 January 2026 and now includes crypto-assets and CBDCs within scope.

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The British Virgin Islands has committed to the OECD's Crypto-Asset Reporting Framework (CARF) under the CARF Multilateral Competent Authority Agreement. The OECD lists the BVI in its 2024 commitment statement on first CARF exchanges in 2028. The BVI implemented CRS 2.0 with effect from 1 January 2026 through amendments to the Mutual Legal Assistance (Tax Matters) Act, 2003. CRS 2.0 brings crypto-assets and central bank digital currencies within the existing exchange-of-information regime. CARF imposes a separate reporting layer on Crypto-Asset Service Providers (CASPs). Implementing legislation for CARF in the BVI is expected ahead of the first reporting cycle.

The OECD CARF model rules require reporting CASPs to collect customer self-certifications, verify tax residence, and report annual transactions to the local competent authority. CARF defines three Relevant Transactions: exchanges between relevant crypto-assets and fiat currency, exchanges between relevant crypto-assets, and transfers of relevant crypto-assets including reportable retail payment transactions. CRS 2.0 expands the definition of financial account to capture accounts holding Specified Electronic Money Products and central bank digital currencies. CRS 2.0 expands the definition of financial asset to include relevant crypto-assets. In the BVI, the International Tax Authority administers exchange-of-information reporting through the BVIFARS portal under the Mutual Legal Assistance (Tax Matters) Act, 2003 as amended.

The rules reach BVI-incorporated exchanges, brokers, custodians, payment processors, and certain wallet operators that fall within the CASP definition. Reporting CASPs must build customer due diligence systems that capture tax identification numbers, jurisdictions of residence, and controlling-person data. CASPs must classify each transaction against the CARF taxonomy and aggregate annual reports per customer. Existing CRS-registered BVI financial institutions face a dual compliance burden during 2026: reporting 2025 data under CRS by 31 May 2026 and collecting 2026 data under CRS 2.0. Fund administrators serving BVI crypto funds must update onboarding forms and account classification logic.

The BVI has not yet published a final CARF regulation. The first reporting cycle is expected to cover the 2027 calendar year, with information exchanged in 2028. The interaction between BVI CARF and FATF Recommendation 16 travel rule data is not yet defined. Several CARF jurisdictions, including the United Kingdom and Germany, are preparing domestic CARF reporting in 2027. Reporting CASPs with cross-jurisdictional footprints should map overlapping obligations before drafting customer onboarding logic.

Licentium advises BVI and offshore CASPs on tax information reporting, CRS and CARF readiness, and cross-border customer due diligence through a partner network across Caribbean and EU jurisdictions. Contact us to discuss CARF gap analyses, BVIFARS registration, or self-certification form design. Work we undertake includes CARF policy drafting, CRS 2.0 remediation, customer due diligence procedures, tax residency classification, BSA and AML alignment, and travel rule compliance.

Source: OECD, "Jurisdictions Committed to Implement the Crypto-Asset Reporting Framework," 2024, https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/commitments-carf.pdf

The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

Crypto Regulatory

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