Form 1099-DA — “Digital Asset Proceeds From Broker Transactions” — is the IRS’s information return for reporting the sale, exchange, or disposition of digital assets. It was mandated by the Infrastructure Investment and Jobs Act of 2021 and finalized through regulations under IRC § 6045. Novus Compliance automates the entire 1099-DA workflow, from data ingestion to IRS-compliant XML transmission through the Information Returns Intake System (IRIS).
A broker includes any person who, in the ordinary course of a trade or business, stands ready to effect sales of digital assets to be made by others. You are considered a broker if you:
Generally, only a U.S. digital asset broker is required to report on Form 1099-DA — a U.S. person (other than a foreign branch) or a U.S. branch treated as a U.S. person that effects sales of digital assets on behalf of others [citation:5].
The 1099-DA regime is being implemented in phases. Understanding where you are on this timeline is critical to compliance.
| Tax Year | Gross Proceeds | Cost Basis | Filing Deadline |
|---|---|---|---|
| 2025 (filed 2026) | Required | Not required | Recipients: Feb 17, 2026 IRS e-file: Mar 31, 2026 |
| 2026 (filed 2027) | Required | Mandatory for covered securities | Recipients: Feb 15, 2027 IRS e-file: Mar 31, 2027 |
For tax year 2025, the IRS provided a transitional basis-reporting waiver — brokers were not required to report basis information for any sales in 2025 [citation:6]. For 2026 sales, basis information is now mandatory for covered assets (digital assets acquired through your platform on or after January 1, 2025) [citation:6]. Brokers that do not check Box 9 for noncovered security sales are subject to penalties for failure to report basis correctly [citation:6].
The distinction between covered and noncovered securities determines whether you must report cost basis on Form 1099-DA.
| Category | Definition | Basis Reporting |
|---|---|---|
| Covered security | Digital asset acquired through your platform on or after January 1, 2025, and held continuously in the same account | Mandatory — Boxes 1d, 1g, 2, and 6 must be completed |
| Noncovered security | Digital asset acquired before January 1, 2025, or transferred in from an external wallet or another broker | Voluntary — Check Box 9; if checked, boxes 1d, 1g, 1h, 1i, and 6 may be left blank without penalty |
If you check Box 9 for a noncovered security and choose to complete basis fields voluntarily, you are not subject to penalties under section 6721 or 6722 for failure to report or furnish this information correctly [citation:7]. However, if you do not check Box 9, you are subject to penalties for failure to report basis correctly — even if the security is noncovered [citation:7].
The IRS has disallowed the “universal method” of aggregating cost basis across multiple wallets. Starting January 1, 2025, basis must be tracked and reported on an account-by-account basis. Revenue Procedure 2024-28 provides a safe harbor for allocating existing basis to assets held in specific wallets as of that date.
The 2026 instructions introduce de minimis rules for certain sales. The following transactions need not be reported on Form 1099-DA [citation:6]:
Starting tax year 2023, filers with 10 or more information returns must file electronically. Paper filing is only allowed if you file fewer than 10 total returns [citation:9]. Form 1099-DA is only accepted through IRIS — the legacy FIRE system does not support this form [citation:9]. IRIS validates data at submission and issues real-time acknowledgements, with accepted or rejected status typically returned within 6 hours [citation:4].
Whether you are preparing your first 1099-DA filing or scaling an existing digital asset reporting operation, Novus Compliance delivers end-to-end automation built for the IRIS platform.
Whether you’re preparing your first 1099-DA filing, managing cost basis reporting for covered securities, or scaling your digital asset reporting operations, Novus Compliance gives you the accuracy, security, and auditability you need.
Schedule a Technical Scoping Call →If you are considered a “broker” under IRC § 6045 — including exchanges, custodians, payment processors, and certain wallet providers — you likely have a filing obligation for digital asset dispositions by U.S. customers. A broker includes any person who, in the ordinary course of a trade or business, stands ready to effect sales of digital assets to be made by others [citation:5].
Gross proceeds reporting applies to all digital asset sales from 2025 onward. Cost basis reporting becomes mandatory for covered securities — assets acquired through your platform on or after January 1, 2025 — starting with the 2026 tax year [citation:6].
If you do not check Box 9, you are subject to penalties under sections 6721 and 6722 for failure to report or furnish basis information correctly — even if you are reporting the sale of a noncovered security [citation:7]. Checking Box 9 for noncovered securities protects you from these penalties.
Yes. As a registered Third-Party Transmitter with the IRS, we can sign, encrypt, and transmit your filings directly through IRIS. You retain full visibility and auditability throughout the process.
Yes. Our platform tracks the original submission identifiers (UniqueRecordId) assigned by IRIS and generates the correct correction payload without manual lookup.
Sales by a processor of digital asset payments (PDAP) of $600 or less during a year, qualifying stablecoin sales of $10,000 or less, and sales of specified NFTs of $600 or less need not be reported on Form 1099-DA [citation:6].