US DeFi Broker Reporting Rule

As of June 4, 2026, the correct legal status for TD 10021 is CRA-revoked; no legal force or effect. Public Law 119-5 states that Congress disapproved the IRS rule relating to “Gross Proceeds Reporting by Brokers That Regularly Provide Services Effectuating Digital Asset Sales” and that the rule “shall have no force or effect.” Treasury and IRS then published a July 2025 Federal Register action stating that, under Public Law 119-5 and the CRA, the final rule has no force or effect and that section 6045 regulations were being reverted to the text in effect before TD 10021’s effective date.

This profile is therefore not an implementation guide for an active DeFi broker rule. It preserves the rule’s history, scope, and relationship to the broader U.S. digital asset broker reporting framework while flagging that the December 2024 rule was disapproved and removed. The related July 2024 digital asset broker regulations, TD 10000, are a separate framework and were not nullified by H.J. Res. 25, according to House Report 119-7.

TD 10021 focused on non-custodial or decentralized finance participants that Treasury and IRS had reserved for later treatment when they finalized TD 10000 in July 2024. The December 2024 rule would have adopted a revised “digital asset middleman” definition and treated certain “trading front-end services” as broker-like effectuating services when the provider ordinarily would know, or be in a position to know, the nature of the transaction giving rise to gross proceeds from a digital asset sale.

• Covered activity: The rule would have covered certain services receiving and processing a person’s order to sell digital assets through user-interface services designed to transmit order details for settlement on a distributed ledger or similar technology.
• Position-to-know standard: The rule would have looked to whether a front-end provider had control or sufficient influence over the service, including the ability to amend processing terms, collect transaction-flow fees, or confirm execution.
• Excluded activity: The rule text included exclusions for validation services and for licensing software or selling hardware, rather than treating every technical participant as a broker.
• Applicability date: TD 10021 stated that its revised digital asset middleman provisions would apply to sales of digital assets on or after January 1, 2027, but CRA disapproval means that date no longer creates operative duties under TD 10021.

The revoked TD 10021 should be distinguished from the still-separate broker reporting rules for custodial digital asset brokers. IRS public guidance states that digital asset broker reporting on Form 1099-DA begins for transactions on or after January 1, 2025, and that those final regulations apply to brokers that take possession of customer digital assets, including custodial trading platforms, certain hosted wallet providers, digital asset kiosks, and certain processors of digital asset payments. The same IRS guidance states that those final regulations did not include reporting requirements for decentralized or non-custodial brokers that do not take possession of the assets being sold or exchanged.

H.J. Res. 25 was introduced on January 21, 2025 by Rep. Mike Carey, reported by the House Ways and Means Committee, passed the House on March 11, 2025 by a 292-132 vote with one present, passed the Senate on March 26, 2025 by a 70-28 vote, and became Public Law 119-5 on April 10, 2025. Treasury and IRS completed the regulatory cleanup on July 11, 2025 through a “Final rule; CRA Revocation” notice. For Crypto Laws, the rule is best categorized as a revoked U.S. federal tax reporting regulation affecting DeFi and digital asset broker reporting history, with a cross-reference to TD 10000 and Public Law 119-5.