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ARTICLE · 27 MARCH 2026

Digital Or Else: Proposed Regulations Would Nix Paper Crypto Payee Statements

Hogan Lovells Cadwalader
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Recently proposed regulations would authorize crypto brokers to deliver payee statements exclusively in electronic format.

United StatesTax

Recently proposed regulations would authorize crypto brokers to deliver payee statements exclusively in electronic format.

On March 5, 2026, the IRS and Treasury issued proposed regulations that, if finalized, would allow crypto brokers to offer Form 1099-DA payee statements digitally and not in paper form. Under the existing broker reporting regulations, discussed here and here, crypto brokers are required to provide Form 1099-DA payee statements to customers annually, either electronically or in paper format, if the customer does not affirmatively consent to electronic delivery or subsequently revokes its consent. The proposed regulations would, if finalized, eliminate (i) the paper format requirement, authorizing digital asset brokers to terminate relationships with customers who do not agree to electronic delivery, and (ii) a customer’s ability to withdraw consent if it previously agreed to electronic delivery.

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