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In the past two years, discussions about tax regulation have been increasing, especially with the introduction of the CARF framework, which has caused many people to start worrying. However, many opinions confuse several important concepts, leading to a flood of misinformation. Today, let's clarify this issue.
First, it is important to understand that CRS and CARF are completely different matters.
CRS is an old framework mainly targeting traditional financial sectors—banks, brokerages, insurance companies. Cryptocurrency exchanges? They are generally outside the scope of CRS. Some have mentioned that CRS 2.0 might expand into the crypto space, but nothing has been finalized yet, and countries are still in negotiations.
CARF is the real tax framework specifically for crypto assets. This framework requires exchanges to report users' transaction data. It sounds quite strict, but there are many details worth paying attention to.
Many articles conflate CRS and CARF, either because the authors haven't fully understood or intentionally create panic.
Second, the compliance pressures faced by major exchanges are not synchronized in time.
A leading exchange, due to its entity being registered in the UAE, has explicitly stated that it will only fully respond to CARF requirements starting from January 2027. Among mainstream large exchanges, this is the latest schedule.
In contrast, exchanges like OKX, Bybit, and Bitget, most of which are based in Seychelles, face tighter compliance timelines—some need to start preparations as early as January 2026. The difference in schedules is quite obvious.
But the most critical question here is: How much will Chinese users actually be affected?
For CARF to truly take effect, there must be an information exchange agreement between the two countries. The user data reported by exchanges needs to be received somewhere; only then can the channels be connected. What is the current situation? China has not yet joined the CARF framework, nor has it signed any crypto information exchange agreements with the countries where these exchanges are registered.
In other words, even if exchanges report data as required, there is no pathway for that data to reach China.
A more realistic point is: which exchange would proactively share user data with a government? This is not aligned with any rational business logic. The survival of exchanges depends on continued operation, and doing such things would be akin to digging their own graves.
Overall, in the short term, the actual risk to Chinese users is almost zero. CRS is of little relevance, and CARF is the key, but China has not joined it for now, and the information flow channels have not been established.
Rather than being driven by various anxieties, it’s better to focus on normal investment decisions. The market changes quickly, and maintaining a stable mindset is even more important.