Form 1099-DA: What the IRS Sees, Box by Box, and What It Misses (2026)

Form 1099-DA is the information return your custodial crypto exchange now files with the IRS for every digital asset sale it effects on your behalf. It arrived for the first time this year, covering 2025 transactions, and the version covering 2026 changes one thing that matters more than anything else on the form: basis reporting stopped being optional.

If you trade on Solana, a second thing matters more. Nothing you do on-chain appears on a Form 1099-DA, and that is not an oversight — it is the result of a rule Congress repealed in April 2025 and Treasury struck from the Code of Federal Regulations three months later. This is a box-by-box reading of the form, the instructions dated 18 February 2026, and the regulatory record in the Federal Register. Every claim below is sourced to a document you can open yourself.

We are a trading tool, not your accountant. Nothing here is tax advice, and a US return with a few thousand swaps on it is a job for a professional. What we can do is tell you what the government is being told about you, and what it is not.

Start with the search result, because it explains why the guidance you have read so far is thin. We queried Google for "1099-DA" on 8 October 2026. The organic top seven were a law firm explainer, a Medium post, a tax-software vendor blog, two near-identical CPA-firm tax alerts, a crypto accounting vendor, and a filing-service knowledge base article.

No irs.gov page on page one. No page that opens the instructions. And no page that answers the question most Solana traders actually have, which is why a year of on-chain activity produced no form at all. So everything below is read out of four primary sources: the 2026 revision of Form 1099-DA, its instructions, Treasury Decision 10000 at 89 FR 56480, and the Congressional Review Act revocation at 90 FR 30825.

Form 1099-DA, "Digital Asset Proceeds From Broker Transactions", is a third-party information return — not a tax return. A broker files a copy with the IRS and furnishes a copy to you. It carries OMB number 1545-2330, and the current revision on the form face is marked 2026.

The legal machinery is older than the form. Section 80603 of the Infrastructure Investment and Jobs Act, Public Law 117-58, expanded "specified security" to include digital assets with an applicable date of 1 January 2023. Treasury published the implementing regulations as Treasury Decision 10000 at 89 FR 56480 on 9 July 2024, requiring brokers to report gross proceeds for sales effected on or after 1 January 2025 and adjusted basis for sales effected on or after 1 January 2026.

The definition of a broker is short and worth reading literally: "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." Generally only a US digital asset broker has to file. One structural fact surprises people: brokers "report each transaction on a separate Form 1099-DA." There is no annual summary line. A thousand sales is a thousand forms.

The form face barely moved. The instructions moved a great deal. Here is the comparison, read from both revisions side by side.

The 2025 instructions say, in one sentence: "Brokers are not required to report basis information with respect to sales effected in 2025." That is why the first 1099-DA you received was, for many people, a single large proceeds number with box 1g empty.

The 2026 instructions open with a heading instead: "2026 and beyond — Mandatory reporting of gross proceeds for all digital assets, mandatory reporting of basis information for digital assets that are covered securities, and voluntary reporting of basis information for digital assets that are noncovered securities."

There is a second change nobody is writing about, and it is greppable. The phrase "de minimis" appears zero times in the 2025 instructions and fifteen times in the 2026 instructions. Three reporting floors arrived with this revision:

• $600 for payment processor sales. A processor of digital asset payments need not report a customer whose PDAP sales are $600 or less for the year. Cross it and all of that customer's sales must be reported.
• $10,000 for qualifying stablecoins. Under the optional stablecoin method, designated sales go unreported unless aggregate gross proceeds, after allocable transaction costs, exceed $10,000.
• $600 for specified NFTs. Same structure, aggregated onto a single form rather than one form per sale.

A "qualifying stablecoin" must meet three tests: it tracks a single government-issued currency one-to-one, uses an effective stabilization mechanism, and is generally accepted as payment by persons other than the issuer. That matters on Solana, where most routed swaps touch USDC somewhere in the path.

This table is the 2026 form face, box by box, with the rule from the instructions beside it. The boxes that cause the most confusion are 1a, 1g, 9 and 12a.

Box	Label	What the instructions actually require
1a	Code for digital asset	The nine-character Digital Token Identifier from the DTIF registry. If the asset is not registered, enter 999999999.
1b, 1c	Name, number of units	Full asset name matching the DTIF registration; units to 18 decimal places.
1d, 1e	Date acquired, date sold	1e is always required. 1d is left blank if acquisition dates vary, or if box 9 is checked and the broker does not know the date.
1f	Proceeds	Gross proceeds, which the broker must reduce by digital asset transaction costs including fees, commissions and transfer taxes related to the sale.
1g	Cost or other basis	Adjusted basis, unless box 9 is checked. Enter zero only if the basis is genuinely zero — a blank and a zero are not the same thing.
1h, 1i	Accrued market discount, wash sale loss disallowed	Both apply to tokenized securities and debt instruments. Wash sale reporting is required only for tokenized securities.
2	Basis reported to IRS	Checked when box 9 is not checked, or when box 9 is checked but basis is reported anyway.
3a, 3b	Gross or net proceeds, QOF	Net proceeds is checked only if the broker reduced proceeds by option premiums.
4	Federal income tax withheld	Backup withholding, currently 24 percent. See the section on 2027 below — this box should read zero on your 2025 and 2026 forms.
6	Gain or loss	Short-term, long-term or ordinary. A single form may not carry both short-term and long-term.
8	Broker relied on customer-provided acquisition information	Checked if the broker ever received that information from you, even if it was not used for the lot on this form.
9	Digital asset is a noncovered security	The single most important checkbox for anyone who moves assets between a wallet and an exchange. Explained below.
11a-11c	Optional method aggregates	Qualifying stablecoins or specified NFTs, the transaction count behind the aggregate, and creator first-sale proceeds.
12a, 12b	Units transferred in, transfer-in date	Populated when the units sold had been transferred into the custodial account. This is the box that flags self-custody activity.
10, 13	Reserved	Reserved for future use. Both are blank on the 2026 revision.

Two of those deserve their own paragraph.

Box 1a is an identity crisis waiting to happen. The instructions require "the nine alphanumeric characters of the digital token identifier issued by the Digital Token Identifier Foundation (DTIF)" and point at the DTIF registry — then add: "If the digital asset is not registered with DTIF, enter 999999999." A token minted last Tuesday on a Solana launchpad is not in an ISO token identifier registry. On the form it is 999999999 and whatever name the broker typed into box 1b. Identifying a memecoin position still takes the mint address, and the place to read that is a block explorer, not a 1099.

Box 1c wants 18 decimal places, which is not a Solana number. Eighteen decimals is the Ethereum convention. We checked four mainnet mints with a getTokenSupply call on 8 October 2026: USDC has 6 decimals, wrapped SOL has 9, BONK has 5, WIF has 6. Native SOL is denominated in lamports, which is 9. The form carries far more precision than any of these assets, so a trailing-zero mismatch between a broker statement and your own records is a formatting artefact, not a discrepancy.

Everything about whether your 1099-DA is useful comes down to one definition. From the instructions: a covered security is a digital asset "acquired after 2025 for cash, stored-value cards, different digital assets, or any property or services ... in an account for which the broker provided custodial services", and it is covered "only if it was acquired in an account for which the broker provided custodial services and was held in that account until the broker effects the disposition."

Read the second half again. Acquired in the custodial account, and held in that account until sale. Move it out and back, and it is no longer covered.

The instructions then list five noncovered categories. The first three catch almost every active Solana trader: any asset the broker did not provide custodial services for when it was acquired, any asset acquired before 2026, and any asset transferred in to the custodial broker. (The remaining two cover exempt recipients and foreign intermediaries.)

When an asset is noncovered, the broker may check box 9 — and if it does, it does not have to complete boxes 1d, 1g, 1h, 1i or 6, and does not have to check box 2. In plain terms: no acquisition date, no cost basis, no holding period, no gain or loss. Proceeds only.

The incentive structure makes this the default, not the exception. If a broker checks box 9 and fills in basis anyway, it "will not be subject to penalties under sections 6721 and 6722 for failure to report or furnish the information correctly." If it does not check box 9, it is exposed to those penalties on basis accuracy even for a noncovered security. Given a choice between a number it cannot verify and a box that removes its penalty exposure, a broker ticks the box.

The instructions' own example is worth internalising. A customer bought the same asset through the same broker in April 2022, April 2026 and August 2026, then sold the whole position in one transaction in June 2027. That single sale produces three separate Forms 1099-DA: short-term covered, long-term covered, and noncovered. One trade, three forms, and only two carry a basis.

There is a related trap for anyone who has dutifully uploaded their transaction history to an exchange: "Under current law, brokers may use customer-provided acquisition information solely for lot-selection purposes and not for reporting basis or acquisition dates." Telling your exchange what you paid helps it pick which lot to sell. It does not put your number in box 1g.

And if the broker does not use that information at all, the fallback is unforgiving: "treat digital assets transferred into the customer's account as acquired as of the date and time of the transfer." A coin held three years in a cold wallet, deposited and sold the same week, can be reported with an acquisition date of the deposit — which reads as short-term.

Because the rule that would have required it was repealed, and under the Congressional Review Act it is treated as though it had never taken effect. This is the part of the story the ranking articles skip, and it is a matter of public record with dates.

The sequence, from the Federal Register:

• 30 December 2024. Treasury publishes a final rule at 89 FR 106928, docketed TD 10021, amending the section 6045 regulations "to require certain decentralized finance industry participants to file and furnish information returns as brokers." Stated effective date: 28 February 2025.
• 11 March 2025. The House passes H.J. Res. 25, a joint resolution of disapproval under the Congressional Review Act. The Senate passes it on 26 March.
• 10 April 2025. The President signs it as Public Law 119-5. The rule now has no force or effect.
• 11 July 2025. Treasury publishes the removal at 90 FR 30825, action line "Final rule; CRA Revocation", reverting the regulatory text to what stood before TD 10021.

The removal document states the consequence in one sentence: "any rule that takes effect and later is made of no force or effect by enactment of a joint resolution shall be treated as though such rule had never taken effect."

What came back when the text reverted is the interesting bit. The removal reinstated two exclusions in section 1.6045-1(b)(2) that say, verbatim, who is not a broker:

• (ix) "A person solely engaged in the business of validating distributed ledger transactions, through proof-of-work, proof-of-stake, or any other similar consensus mechanism, without providing other functions or services."
• (x) "A person solely engaged in the business of selling hardware or licensing software, the sole function of which is to permit a person to control private keys which are used for accessing digital assets on a distributed ledger, without providing other functions or services."

Those two paragraphs are why running a Solana validator and shipping a self-custody wallet are both outside the reporting regime. If you have ever wondered how staking infrastructure escapes 1099 duties, that is the text.

The current instructions carry the same logic forward: you are not a digital asset middleman if you "only provide hardware or software (by sale, license, or otherwise) that permits users to control private keys to access digital assets on a distributed ledger, without providing other functions or services." What remains in the middleman definition is narrow — accepting crypto as payment for reportable property, real estate reporting persons, brokers accepting crypto for their own services, payment processors, and physical kiosks.

Treasury explained the split in the TD 10000 preamble. The non-custodial middleman rules "are not being finalized with these final regulations," because custodial brokers "carry out a substantial majority of digital asset transactions" and Treasury did not want to delay the custodial rules while it studied the rest. It then said directly that it "recognize[s] that persons that are solely engaged in the business of providing validation services ... or persons that are solely engaged in the business of selling certain hardware, or licensing certain software, for which the sole function is to permit persons to control private keys ... are not digital asset brokers." Treasury added that it intends to "expeditiously issue separate final regulations" for non-custodial participants. As of today, it has not.

The same regulations define an unhosted wallet as "a non-custodial means of storing, electronically or otherwise, a user's private keys," covering both hot and cold variants. Choosing a self-custody wallet over an exchange account is not a reporting loophole. It is a choice to be the only party keeping records.

Several of the most common DeFi actions are carved out of 1099-DA reporting entirely, and the carve-out has a citation. The instructions list, under exceptions, that "until the Treasury Department and IRS issue further guidance, Notice 2024-57 provides that brokers do not have to file information returns on digital asset sales in the following transactions":

• Wrapping and unwrapping transactions
• Liquidity provider transactions
• Staking transactions
• Transactions described by market participants as lending of digital assets
• Transactions described by market participants as short sales
• Notional principal contract transactions

Read the caveat attached to that list: "This reporting exception does not apply to rewards or other compensation earned by participants in these transactions." No form does not mean no income.

Separately, in both the 2025 and 2026 instructions, a two-sentence rule catches a lot of people out: "Rewards and staking payments. Do not report rewards and staking payments on Form 1099-DA." Staking yield is not absent from your return because it is untaxed; it is absent from this form because this form reports dispositions. Stake SOL through a liquid staking protocol and nothing in that flow lands in box 1f.

One more, for the memecoin crowd: wash sale reporting here is scoped to tokenized securities only — "Losses from wash sales of tokenized securities must be reported" — and the average basis method is likewise "only available for digital assets that are also a tokenized security." Neither reaches an ordinary SPL token. That describes what the form reports, not an invitation; the tax treatment of memecoin trading is a question for your own advisor, and these rules are under active development.

No. The instructions say so in one line, and it is the same line in both the 2025 and 2026 revisions. On the account number box: "The account number requested here is the number assigned by the broker to a customer, not the customer's wallet address."

That is as explicit as tax form instructions get. There is no box on Form 1099-DA for an on-chain address and no box for a transaction signature. Boxes 12a and 12b report the number of units transferred into the custodial account and the date of the transfer-in — a quantity and a date, not a counterparty.

Draw the right conclusion, though. A date and a quantity landing in a custodial account is a thread, and public ledgers are public: anyone can already run a wallet tracker over any address on Solana. The form does not hand over your address. It does not need to.

This is the change with the longest tail, and it has nothing to do with brokers. Under section 1.1012-1(j) of the 2024 final regulations, specific identification and the FIFO default apply to units held within a single wallet or account, for all acquisitions and dispositions on or after 1 January 2025. The older practice of pooling basis across every wallet you own — what Rev. Proc. 2024-28 calls "a so-called universal or multi-wallet approach" — does not survive that rule.

Rev. Proc. 2024-28 is the transition. It provides a safe harbor under section 1012(c)(1) for allocating "unused basis" to the assets in each wallet or account as of 1 January 2025, by either specific unit allocation or a global allocation method. Three features are easy to miss:

• The global allocation route had a pre-2025 paperwork deadline. A taxpayer using it "must describe the global allocation method in the taxpayer's books and records before January 1, 2025." That date has passed.
• The allocation is irrevocable "for all purposes of section 1012."
• It does not bless your numbers. "This safe harbor does not apply to the taxpayer's calculation of the amount of unused basis, which must be substantiated separately."

For a self-custody trader the operative rule is the timing one. A specific identification of units in an unhosted wallet must be recorded in your books "no later than the date and time of sale, disposition, or transfer." Not at year end, and not when your software imports the history. Absent identification, the default is FIFO from the earliest purchase date within that wallet.

If you run multiple wallets — a funding wallet, a hot wallet for copy trading on Solana, a cold wallet for holdings — each is now its own basis silo. That is the single strongest argument for keeping fewer wallets and better records; our note on portfolio management covers the practical side.

Two dated items are on the calendar, and both are checkable.

First, backup withholding. Section 3406 requires a payor to withhold at the fourth lowest individual rate — currently 24 percent — when a payee has not furnished a certified TIN. Notice 2025-33 extends the relief first granted in Notice 2024-56 and states that "backup withholding tax obligations under sections 3406 and 3403 will not be required on any digital asset sale effected by a broker during calendar year 2025 or calendar year 2026." Read the boundary: the relief is written year by year, and as it stands covers 2025 and 2026, so box 4 on those forms should read zero. Whether anything changes for 2027 depends on guidance that does not exist yet, which makes a current W-9 on file at every custodial venue cheap insurance.

Second, an open rulemaking nobody is covering. On 6 March 2026 Treasury published a notice of proposed rulemaking at 91 FR 10983, REG-105064-25, "Electronic Furnishing of Payee Statements Regarding Digital Asset Sales by Brokers." It would give brokers "an alternative process for obtaining consent from their customers to receive these statements in an electronic format without offering a paper delivery alternative." Comments closed 5 May 2026, and a hearing notice followed at 91 FR 28460 on 18 May 2026. Plumbing, but live — and a reminder that this regime is still being built.

If your trading happens on-chain through a non-custodial tool, no 1099-DA describes it, and your records are the only record. That is the whole practical takeaway, and it cuts both ways.

uwuu is non-custodial by design: you keep your keys, trades execute from your own wallet in under 400 milliseconds, and we never take possession of your assets. We do not issue Forms 1099-DA, and nothing in the regulations quoted above creates a reporting path for a tool that does not hold your coins. The flip side is unavoidable: no statement arrives in February to reconcile against. Every mirrored trade is a disposition in your own accounting, and whether copy trading is profitable is a different question from whether it is documented.

Three habits make the difference, none of them exotic:

• Export continuously, not annually. On-chain history is permanent but your ability to interpret it is not. A monthly export with timestamps beats reconstructing a year of swaps from an explorer.
• Keep the wallets and the purposes separate. Since 2025 each wallet is its own basis pool. Mixing a long-term SOL position into the wallet you use for memecoin trading makes FIFO work against you.
• Record transaction costs. The broker rules reduce proceeds by fees and commissions, and the basis rules allocate exchange costs to the disposition. Solana fees are small per trade and not small over ten thousand trades.

If you are picking between an on-chain tool and a centralised venue, the reporting difference belongs in the comparison alongside execution and cost. A custodial exchange sends you a form, which is genuinely useful, and sends the IRS the same form, which is also genuine. A non-custodial tool sends neither. Our breakdown of copy trading platforms and the main Solana trading bot comparison both treat custody as a first-class criterion, and the verified on-chain leaderboard exists precisely because every trade it ranks is independently auditable — the same property that makes your own records reconstructable. One honest note on cost, since this is an article about numbers: uwuu charges a performance-based fee, so you pay only when you profit. That is a trading expense like any other, and it belongs in your arithmetic.

What is a 1099-DA?

Form 1099-DA, "Digital Asset Proceeds From Broker Transactions", is an IRS information return that a US digital asset broker files to report the gross proceeds of a digital asset sale it effected for a customer, and in some cases the cost basis. It carries OMB number 1545-2330. Brokers report each transaction on a separate form, and furnish you a copy of what they send the IRS.

Why does my 1099-DA show no cost basis?

Almost certainly because the asset is a "noncovered security" and the broker checked box 9. An asset is noncovered if it was acquired before 2026, if the broker did not have custody when you acquired it, or if it was transferred in to the broker. When box 9 is checked, the broker does not have to complete boxes 1d, 1g, 1h, 1i or 6 — meaning no acquisition date, no basis and no holding period.

Do I get a 1099-DA for DeFi or DEX trades?

No. The regulation that would have required decentralized finance participants to report as brokers, TD 10021 at 89 FR 106928, was disapproved by Congress under the Congressional Review Act and signed as Public Law 119-5 on 10 April 2025. Treasury removed it from the CFR effective 11 July 2025 at 90 FR 30825, and under the CRA it is treated as though it never took effect. Reporting obligations never arriving does not mean the underlying gains are not taxable.

Does Form 1099-DA report my wallet address?

No. The instructions state that the account number box is "the number assigned by the broker to a customer, not the customer's wallet address." Boxes 12a and 12b report the number of units transferred into a custodial account and the transfer-in date, which is a quantity and a date rather than an address.

What changed on Form 1099-DA for 2026?

Basis reporting became mandatory for covered securities. The 2025 instructions said brokers "are not required to report basis information with respect to sales effected in 2025"; the 2026 instructions make it mandatory for covered securities and voluntary for noncovered ones. The 2026 revision also introduced de minimis reporting thresholds that do not appear anywhere in the 2025 instructions: $600 for payment processor sales, $10,000 for designated qualifying stablecoin sales, and $600 for specified NFTs.

Is staking income reported on a 1099-DA?

Not on this form. The instructions say directly: "Do not report rewards and staking payments on Form 1099-DA." Separately, Notice 2024-57 relieves brokers from filing information returns on staking, wrapping and unwrapping, liquidity provider, lending, short sale and notional principal contract transactions until further guidance — with the explicit caveat that the exception "does not apply to rewards or other compensation earned by participants in these transactions."

Will there be backup withholding on my crypto sales?

Not for 2025 or 2026 sales. Notice 2025-33 states that backup withholding obligations under sections 3406 and 3403 "will not be required on any digital asset sale effected by a broker during calendar year 2025 or calendar year 2026." The statutory rate is the fourth lowest individual rate, currently 24 percent, and it applies when a payee has not furnished a certified TIN — so keeping a current W-9 on file with each custodial venue is the simple precaution.

Every document quoted above is free and public: Form 1099-DA and its instructions on irs.gov (the 2026 revision, dated 18 February 2026); Treasury Decision 10000 at 89 FR 56480; the DeFi rule and its repeal at 89 FR 106928 and 90 FR 30825; Rev. Proc. 2024-28 for the basis transition; Notice 2024-57 for the transaction carve-outs; Notice 2025-33 for withholding relief; and REG-105064-25 at 91 FR 10983 for the open rulemaking.

If a blog post tells you something about this form that one of those documents contradicts, believe the document. And if your situation involves thousands of on-chain dispositions, hire someone — the forms are readable, the arithmetic is not.