Switzerland's Crypto Assets tax delayed until 2027! 74 countries' data sharing tax avoidance window reopened

Switzerland will delay the automatic exchange of information on Crypto Assets accounts with foreign tax authorities at least until 2027. The Federal Council has also approved Switzerland's participation in the amendments to international tax information exchange regulations, which are updates to existing laws, and both amendments will take effect in early 2026. Switzerland plans to exchange Crypto Assets tax data with 74 jurisdictions, but the United States, China, and Saudi Arabia are not included.

Political Considerations Behind Switzerland's Crypto Assets Tax Delay

(Source: Swiss Federal Council)

Switzerland will delay the automatic exchange of Crypto Assets account information with foreign tax authorities until at least 2027. Currently, Switzerland is still developing the legal framework for implementing the data sharing starting from January 1, 2026. On Wednesday, the Federal Council approved the amendments to the regulations related to Switzerland's participation in international tax information exchange. These amendments are updates to the original laws, and both amendments will come into effect at the beginning of 2026.

The council supported this broader initiative at the autumn meeting in 2025, agreeing to expand Switzerland's role in global tax data sharing according to the standards set by the OECD. The proposal updates the Common Reporting Standards for financial accounts and incorporates a new Crypto Assets Reporting Framework (CARF), which stipulates how to report holdings of crypto assets. These legal changes will take effect as planned without a national referendum.

However, a key political decision has postponed the actual start date for the sharing of Crypto Assets data. On November 3, 2025, the National Assembly's Economic Affairs and Taxation Committee suspended its work on Switzerland's intended list of partner countries for data exchange under the CARF. The Crypto Assets reporting rules will still be retained in the legal text, but these rules will not take effect until Switzerland is ready to begin communication with cooperating jurisdictions.

Therefore, CARF will officially be written into law starting from January 2026, but it will not be implemented as originally planned on January 1, 2026. The earliest implementation date is now set for 2027. This arrangement of “law taking effect but not yet enforced” demonstrates Switzerland's delicate balance between international tax transparency pressures and the preservation of financial privacy traditions.

Compliance Requirements for Crypto Assets Service Providers under the CARF Framework

For cryptocurrency companies, the revised rules are clear. Service providers must register, report relevant customer data, and conduct basic checks on customers if they have sufficient ties to Switzerland. The regulation also brings more associations and foundations under the regulatory framework while exempting those that meet specific criteria, and includes transitional measures to allow companies time to adapt to the new reporting system.

The revised regulation elaborates in detail what this means for Crypto Assets companies in practice. It stipulates that Crypto Assets service providers are obligated to report, conduct due diligence, and register, and clarifies the circumstances under which they have sufficient ties to Switzerland to be bound by this regulation. This clear compliance requirement necessitates that Crypto Assets exchanges, wallet service providers, and custodians operating in Switzerland must establish a complete customer identification and reporting system.

Five Major Compliance Obligations of Crypto Service Providers

Registration Obligation: All Crypto Assets service providers must register with the Swiss tax authorities.

Customer Due Diligence: It is necessary to perform identity verification and background checks on clients to confirm their tax residency status.

Data Report: Regularly report customers' Crypto Assets holdings and transaction information to tax authorities.

Record Keeping: Maintain complete transaction records and customer information for tax review.

Cross-border Reporting: If the client is a foreign tax resident, the relevant information will be shared with their tax residence country.

The regulation will also bring more associations and foundations under its regulatory scope, meaning that some crypto projects operating through foundation structures will also be regulated. At the same time, associations and foundations that meet specific criteria will be exempted, showing that regulatory authorities are trying to strike a balance between comprehensive regulation and avoiding excessive burdens. The establishment of transition measures is also important, giving companies time to build compliance systems rather than requiring immediate full enforcement.

74 country data sharing list US China Saudi Arabia absent

The Federal Council is consulting on a bill aimed at sharing Crypto Assets information with 111 jurisdictions that have participated in automatic information exchange, provided that these jurisdictions comply with the OECD's Crypto Assets reporting framework. Under the plan, Switzerland hopes to ultimately exchange coin tax data with 74 jurisdictions that meet CARF standards and demonstrate mutual interest.

The group includes all EU member states, the UK, and most G20 member countries, such as Japan, Australia, and Canada. This broad coverage means that most residents of developed countries holding Crypto Assets in Switzerland will ultimately have their information shared with their national tax authorities. For investors attempting to hide Crypto Assets through the Swiss banking system, this pathway will be essentially closed after 2027.

Currently, the United States, China, and Saudi Arabia are not part of this group of members, as they either do not comply with CARF or have not reached the necessary agreements. The absence of the United States is particularly noteworthy; as the world's largest economy and cryptocurrency market, the non-participation of the United States in the CARF framework means that information regarding Crypto Assets held by U.S. residents in Switzerland will temporarily not be automatically shared. This situation may reflect considerations of the U.S. tax policy itself and may also be related to the special status of the U.S. financial system.

China's absence may be related to its strict regulatory stance on Crypto Assets. Since 2021, China has completely banned Crypto Assets trading and mining, making participation in international Crypto Assets tax data sharing relatively insignificant under such a policy environment. Saudi Arabia's situation may be related to the developmental stage of its financial regulatory framework; although the country has actively embraced fintech in recent years, it is still in the exploratory stage regarding Crypto Assets regulation.

Transition Period Strategy Before Implementation in 2027

The setbacks test the speed at which major economies reach a consensus on the transparency issues surrounding Crypto Assets. Previously, Switzerland spent a year preparing to integrate Crypto Assets into its international tax transparency framework, but then delays occurred. This postponement indicates that while the international community has reached a consensus on the principles of tax transparency, it still faces complex technical and political challenges at the level of specific implementation.

The transition period from 2026 to 2027 provides adjustment time for both Crypto Assets investors and service providers. For investors, this means that before 2027, information regarding Crypto Assets held in Switzerland will not be automatically shared with foreign tax authorities. However, this does not mean that tax obligations can be evaded, as tax laws in most countries require residents to actively declare global income and assets, and concealment may face serious legal consequences.

For Crypto Assets service providers, the transition period provides valuable time to establish a compliance system. Reporting obligations, due diligence, and registration requirements all require the support of technical systems and processes, and building these systems from scratch takes time and financial investment. The Swiss government has avoided the chaos and surge in compliance costs that could result from immediate enforcement by setting up a transition period.

However, this delay has also raised some concerns. Postponing the implementation may lead some investors to transfer their assets to Switzerland to take advantage of the last window of information privacy, which could, in turn, create pressure for capital outflows before the implementation in 2027. Furthermore, whether Switzerland's delay will affect the implementation progress of other countries remains an uncertain factor in international tax cooperation.