Cryptocurrency exchanges, custodial services, and electronic wallet issuers in Ukraine will fall under CRS reporting rules starting July 1, 2026. This means these institutions will be required to collect information about clients' tax residency and transmit the relevant data as part of the international automatic exchange of tax information.
What Ministry of Finance Order No. 316 changed
The changes were approved by Order of the Ministry of Finance of Ukraine dated June 15, 2026, No. 316, "On Approval of Amendments to the Procedure for Applying the Common Reporting Standard and Due Diligence for Financial Account Information." The document took effect on July 1, 2026, and extends the CRS regime for cryptocurrencies in Ukraine to crypto assets, electronic money, and central bank digital currencies (CBDCs).
This is Ukraine's implementation of CRS 2.0, an updated version of the automatic tax information exchange standard approved by the OECD in 2023. While automatic exchange previously applied mainly to traditional bank accounts (we covered this in more detail in the article Will the tax authorities see foreign accounts in 2026: CRS, CARF, and the end of banking secrecy), reporting obligations now also cover cryptocurrency exchanges, custodial platforms, and electronic wallet issuers.
Custodial storage of clients' private cryptographic keys may also fall under the definition of a reportable account under the CRS rules for cryptocurrencies in Ukraine.
Account verification deadlines
The transitional period provides for due diligence procedures to be carried out in stages:
by December 31, 2026, institutions must complete the review of individual accounts with a balance exceeding the equivalent of $1,000,000;
by the end of 2027, review of the remaining individual accounts and organizational accounts with a balance exceeding $250,000.
Certain categories of electronic wallets with an average daily balance of up to $10,000 may be excluded from the reporting obligation, reducing the administrative burden on retail payment service operators.
What this means for crypto asset owners
A delay in setting up due diligence procedures could lead to risks of non-filing or incomplete filing of reports by accountable platforms as early as the 2026 reporting year. For users of crypto services, the new rules will have the following practical consequences:
Mandatory identification of tax status
Cryptocurrency exchanges and custodial services, which previously may not have requested information about clients' tax residency, will now be required to obtain and verify such data in accordance with the CRS requirements for cryptocurrencies in Ukraine, similar to the procedures applied by banks.
Automatic exchange of tax information
Information about accounts on foreign crypto platforms that meet the CRS criteria may be transmitted to the Ukrainian tax authorities as part of the automatic exchange of information between competent authorities, without a separate request.
Impact on CFCs and personal income
The new rules are particularly important for owners of significant crypto assets, individuals earning income from digital asset transactions, and controlling persons of CFCs (controlled foreign companies). This information must be taken into account when declaring income and fulfilling CFC reporting obligations and in tax planning.
What crypto asset owners should do
If you use cryptocurrency exchanges or custodial platforms, especially if your asset balances are approaching the CRS thresholds, it is advisable to proactively:
assess your tax residency status and check what information the platform may transmit under CRS;
check whether your accounts fall under the CRS reporting criteria;
prepare documents confirming the origin of funds and crypto assets;
verify that your tax reporting corresponds to the actual volume of assets and income received.
Maira Consult experts can help assess tax risks, verify compliance with CFC requirements, and prepare for the new automatic tax information exchange rules.
