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Sources last verified: 28 October 2026
Official sources cited at the end of this page.
Since 1 January 2026, anyone who concludes a crypto-asset trading contract with a Japanese exchange has had to give it a notification of their tax residence and any foreign tax identification number, on paper or electronically. That notification is the first step of Japan’s version of the OECD’s Crypto-Asset Reporting Framework, built into the Act on Special Provisions of the Income Tax Act, the Corporation Tax Act and the Local Tax Act Incidental to the Enforcement of Tax Treaties (実特法, Act No. 46 of 1969). By 30 April each year, from 2027, the exchange reports the transactions of users resident in reportable jurisdictions to the National Tax Agency (国税庁, NTA).
Customers with a contract in place on 31 December 2025 must file the same notification by 31 December 2026. A user who never files cannot be placed by the exchange from its own records: the NTA’s FAQ says the CARF rules, unlike the CRS rules, contain no procedure for that, and the law instead puts a criminal penalty on a user resident abroad who fails to file.
So the gap lands on the exchange’s first report. Every existing customer without a notification on 31 December 2026 is a user the exchange cannot place from its own records, four months before the deadline.
There are two ways to meet the Japanese rules. One mails the existing book through 2026 and checks each returned form by hand. The other takes and checks the notification inside onboarding and runs the existing book through the same flow. The first finishes in December; the second finishes when the customer does.
01 · Japan CARF at a Glance
| Point | Position as at 28 October 2026 |
| Legal basis | 実特法 arts. 10-9 to 10-13 and 13; its Cabinet Order (実特令) and Ministerial Ordinance (実特規); enacted in the FY2024 tax reform |
| Authority | National Tax Agency (国税庁); reports go to the district director of the head office’s tax office |
| In force | 1 January 2026 |
| Who reports | Crypto-asset exchange service providers, electronic payment instrument service providers and financial instruments business operators that buy, sell or exchange crypto-assets, or intermediate, broker or act as agent in those trades, as a business |
| User notification | When concluding a trading contract from 1 January 2026; holders of contracts on 31 December 2025 by 31 December 2026 (art. 10-9(1)) |
| Changes | A change notification within three months; new contrary information triggers a procedure within three months |
| Report | By 30 April of the following year, the first in 2027 for 2026 (art. 10-10(1)) |
| Filing | e-Tax where possible; otherwise CD-R or DVD-R |
| TIN | Foreign TIN only; Japan’s My Number is not reported |
| Penalties | Up to six months’ imprisonment or a fine of up to JPY 500,000 for the person responsible, with the company fined; the user offence applies to users resident abroad (art. 13(4), (5)) |
| Records | Five years from the year after the contract ends (art. 10-12) |
Our regulatory compliance engine settles each Japanese user’s residence before the first trade. It collects and checks the notification, runs the TIN, reasonableness and other required due diligence checks, resolves indicia automatically instead of by your compliance team, and prepares the validated report, with zero remediation.
02 · Who is Affected and What They Must Do
The duty sits with a 報告暗号資産交換業者等 (reporting crypto-asset exchange service provider): a crypto-asset exchange service provider under the Payment Services Act, an electronic payment instrument service provider, or a financial instruments business operator, in each case only where it buys, sells or exchanges crypto-assets, or intermediates those trades, as a business (NTA FAQ, Q5). The user carries a duty too: the notification is the user’s legal obligation, not a form the exchange may ask for.
| Question | Answer under 実特法 and the NTA FAQ |
| Which assets count? | Crypto-assets under the Payment Services Act, type-4 electronic payment instruments, and certain tokenised rights under FIEA art. 29-2(1)(8) that have the character of crypto-assets (実特令 art. 6-19). |
| Where do electronic payment instruments fall? | Type-4 instruments, a category of crypto-asset-type value not denominated in a currency, are CARF assets; types 1 to 3 are specified electronic payment instruments under the CRS regime, though crypto-assets bought or sold for them are still reported under CARF. |
| Must a Japanese resident file the notification? | Yes. Every user files it, whether or not the residence country is reportable (Q7). |
| Who is reported? | Users whose residence is a reportable country, and certain entities with a controlling person resident in one (art. 10-10(2)). |
| Which countries are reportable? | Treaty partners with a CARF exchange agreement, to be listed in the Ministerial Ordinance as agreements are made (Q6). |
| Does a CRS form already on file count? | Yes, where it was given to the same institution as a reporting financial institution and residence details have not changed (実特令 art. 6-15(3)). |
03 · NTA Compliance Measures and Technical Decisions
Confirm the notification
When the notification arrives, the exchange checks what it states against the other documents the user provides, such as the identity documents produced for anti-money-laundering verification under the Act on Prevention of Transfer of Criminal Proceeds. Where the country of the user’s address and the country of residence differ, the notification must explain why (Q10).
Look through the entity
For a 特定法人 (specified corporation), broadly an entity whose investment income or assets reach 50% of its total, the notification also covers its 実質的支配者 (beneficial owners), identified as under the anti-money-laundering rules. Listed companies and their group members, public bodies, most Japanese reporting financial institutions (investment entities and trustees excepted) and pure holding companies are among those outside the definition (Q25, Q26).
Keep it current
A user whose residence details change files a change notification within three months (art. 10-9(2)). If the exchange acquires new information that contradicts the notification, such as a foreign address or telephone number, it must run a procedure within three months: ask for a change notification and, if none comes, determine the country from that information (art. 10-9(4); 実特令 art. 6-17).
04 · The Role of the Tax Identification Number (TIN) in Japan
Only a foreign TIN is collected and reported. Japan’s own My Number is neither a notification item nor a reporting item (Q24). Where the user’s residence country issues TINs automatically to its residents, the NTA treats the user as normally having one, and it asks exchanges to check the TIN, as far as possible, against the OECD’s portal and its own country-by-country TIN information.
The check matters because, at onboarding, the notification is the only source of residence; the exchange can place the user from its own data only later, when new information triggers the procedure in article 10-9(4). The exchange confirms the TIN as far as possible alongside the identity documents it has seen; a TIN that is missing or implausible for the declared country is a question to put to the customer before the first trade, not in April. Our Japan CRS 2.0 article covers the same check for bank accounts.
05 · Reporting, Records and Penalties
By 30 April each year the exchange reports each reportable user’s name, address, date of birth, country of residence and foreign TIN, the details of controlling persons where relevant, and, per type of crypto-asset, its name and, for purchases and sales against currency or specified electronic payment means (特定電子支払手段, which include type 1 to 3 instruments), the total consideration, units and number of transactions, with crypto-to-crypto exchanges and transfers reported at fair market value (Q18; 実特規 art. 16-19(4)). Fees are netted for sales, purchases and crypto-to-crypto exchanges. A reportable contract is reported every year until it ends, even in a year with no trades (Q14).
Records of each notification and each residence determination are kept for five years from the year after the year the contract ends (art. 10-12), and a change notification is recorded separately rather than over the original (Q21). Article 10-11 disregards any arrangement one of whose main purposes is to avoid reporting.
The penalties are criminal. A user resident abroad who does not file the notification, or files a false one, and the person responsible where an exchange does not report by the deadline or reports false information, each face up to six months’ imprisonment (拘禁刑) or a fine of up to JPY 500,000 (art. 13(4)(v) and (vi)); the company itself is fined (art. 13(5)). The limit to users resident abroad is in article 13(4)(v) itself.
06 · Understanding CARF and CRS 2.0
Japan amended its CRS regime and introduced CARF reporting in the same FY2024 reform, and the two divide the ground. Electronic payment instruments of types 1 to 3 are specified electronic payment instruments under the CRS regime; type-4 instruments and other crypto-assets fall under CARF. A tokenised security that can be held or moved only through a financial institution is reported under the CRS, not CARF (Q17).
The overlap also saves work. A customer who has already filed a CRS notification with an exchange that is also a reporting financial institution does not file again for CARF, unless residence details have changed; the CRS notification is treated as filed for CARF on the relevant date (Q12).
07 · International Comparisons
Japan was one of 48 jurisdictions in the joint statement of 10 November 2023 committing to implement the CARF (Ministry of Finance), and is listed by the OECD among those expected to start CARF exchanges in 2027 (list of 14 September 2026). Singapore, the UAE and Hong Kong are listed for 2028; India has not committed. Our India CARF and UAE CARF articles cover two of them.
Japan’s design differs from the EU’s in one respect worth noting. DAC8 requires the provider to prevent a user who has not supplied the due diligence information, after two reminders and not before sixty days, from carrying out reportable transactions; Japan’s FAQ describes no restriction on the account and places the sanction for a missing notification on a user resident abroad.
08 · Two Ways to Meet Japan’s Crypto-Asset Rules
By mail and manual review
An exchange can write to its existing customers through 2026, collect paper or online notifications and check each against the KYC file by hand. It works for a small book. The case against it is timing: forms arrive in the last weeks of the year, and each one the exchange cannot reconcile is a user it cannot place in April.
Inside onboarding, step by step
TaxDo runs CARF due diligence inside onboarding, from the first user notification to the validated report, in five steps.
Step 1 · Collect the self-certification. Guided, one question at a time, for individuals and entities, with a digital signature; a specified corporation’s beneficial owners are collected in the same flow.
Step 2 · Validate the identity. Every TIN is checked in real time against official sources in 130+ countries, and the business against registries in 120+.
Step 3 · Run forensic due diligence with Verify+. Our Verify+ forensic engine runs 20+ checks on an individual and 30+ tax-native checks across eight areas on an entity, testing each declaration against what the exchange holds and classifying each transaction by reportable type.
Step 4 · Cure the gaps, without the compliance team:
4a · New users. Discrepancies are resolved in the same session, before the first trade.
4b · Existing users. One click starts remediation for the whole pre-2026 cohort through a link in your own brand, with every answer checked by Verify+ and each case closed by a signed self-certification and an audit-ready certificate.
Step 5 · Report, and keep the evidence. Schema-validated CARF XML from one data layer, prepared and validated for your exchange to submit. Our team can also submit it on your behalf on request, as an additional service. Every user keeps an immutable clearance record.
From Day-1 self-certification to CARF reporting, with zero remediation. Every user is cleared at onboarding.
Our CARF compliance software · Crypto exchanges and CASPs
Where this sits, and what it does not touch
It runs beside the identity verification the Act on Prevention of Transfer of Criminal Proceeds already requires, not in place of it. The reporting obligation, and the responsibility for what is reported, stays with the provider, including where TaxDo submits the report on its behalf at its request. TaxDo runs the due diligence and prepares and validates the report.
09 · Anticipated Regulatory Developments
10 November 2023
Japan joins the joint statement on implementing the CARF.
FY2024 tax reform
The reporting regime is written into 実特法, its Cabinet Order and Ministerial Ordinance, effective 1 January 2026.
1 January 2026
New users notify their residence when they conclude a trading contract.
23 July 2026
An amending act moving crypto-asset regulation from the Payment Services Act to the Financial Instruments and Exchange Act is promulgated. 実特法 still refers to the Payment Services Act definitions, and the Financial Services Agency has asked for the necessary amendments in its FY2027 tax reform request, to take effect with the new act; it is a request, not an enacted change.
31 December 2026
Deadline for notifications from customers with a contract in place on 31 December 2025.
30 April 2027
First reports, for 2026, followed by exchange with partner jurisdictions in 2027.
10 · Related Reading
Framework articles: CARF and crypto tax transparency · Self-certification under CRS 2.0, DAC8 and CARF · Japan CRS 2.0 · India CARF · UAE CARF
Product: Regulatory compliance engine · Day 1 onboarding validation
