Photo Adi Pane © Reyl Intesa Sanpaolo
By Adi Pane, Account Manager, Asset Services, at Reyl Intesa Sanpaolo
For more than a decade, part of crypto’s appeal — particularly for international capital — rested on structural opacity. Decentralisation, open access and the absence of a framework equivalent to CRS allowed digital assets to operate outside the reporting architecture applied to traditional finance. That environment is now changing rapidly.
The OECD’s Crypto-Asset Reporting Framework (CARF) is the first coordinated global standard for tax transparency in crypto-asset transactions. Switzerland’s adoption of the standard followed a carefully staged process: Parliament approved CARF on 26 September 2025, and the legal framework entered into force on 1 January 2026. Following a decision by the Economic Affairs and Taxation Committee of the National Council in November 2025, due diligence and data collection obligations will become operational from 2027, with the first international exchanges expected in 2028 — placing Switzerland alongside Australia, Canada, Hong Kong, Singapore and the United Arab Emirates in the second exchange wave. The Federal Council proposed exchanges with 74 partner jurisdictions, including all EU member states and the United Kingdom, while the United States and Saudi Arabia remain exceptions for now. In March 2026, 76 members of the Global Forum committed to implementing CARF.
CARF does not introduce any new taxes. Its impact is structural: it industrialises transparency by making reporting systematic rather than investigation-based. It remains to be seen whether assets that benefited from lower visibility will migrate significantly into regulated custody, but the incentive structure is shifting.
The CRS experience offers only a partial precedent. When automatic exchange of information was introduced for traditional bank assets, flows consolidated around regulated institutions as opacity-based models became unviable. There is one major difference with crypto assets: self-custody has no equivalent in traditional banking, making the migration thesis less automatic than the CRS analogy might suggest.
CARF’s rollout coincides with a broader institutionalisation of digital assets, reflected in spot Bitcoin and Ethereum ETPs representing more than $120 billion in assets under management as well as significant trading volumes. With flagship vehicles such as BlackRock’s spot Bitcoin ETF (IBIT) alone accounting for $66.5 billion in assets under management, the trend appears structural, driven by a combination of regulatory anticipation and risk appetite. For banks already subject to CRS and AML frameworks, CARF is less a break with the past than an extension of the existing compliance architecture. Turning that into a competitive advantage will depend as much on execution as on positioning.
Switzerland enters the CARF era with notable structural strengths: a mature wealth management industry, a progressive legal framework for distributed ledger technology (DLT) and infrastructure such as SDX (SIX Digital Exchange). These elements create conditions that could benefit the Swiss financial centre, but favourable conditions do not automatically translate into outcomes.
Competition from Singapore, the United Arab Emirates and major US institutions remains intense and shows no sign of easing. The UAE moved quickly to establish advanced digital asset regulation; Singapore has reinforced its position as Asia’s leading wealth management hub. The open question is whether Switzerland’s compliance depth will prove more attractive than the speed and scale offered by these jurisdictions.
The operational challenge may also be underestimated. CARF creates a compliance phase before revenues arrive: systems must be built before exchanges begin in 2028, requiring investment with no immediate return. Portfolio attribution, transaction tracing, beneficial ownership verification and data standardisation are all complex undertakings. RCASP (Reporting Crypto-Asset Service Provider) obligations could extend beyond custody to prime lending and prime brokerage — a broader scope than many institutions initially anticipate.
For Swiss banks, the question is no longer whether digital assets belong in regulated finance, but which institutions will be best placed to intermediate them — and whether Swiss institutions will move quickly enough to find out.
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