Following the two-month consultation conducted from December to February, the bill that seeks to implement the Crypto-Asset Reporting Framework (CARF) and the amended Common Reporting Standard (CRS) (Bill) was gazetted on 22 May 2026. This marks an important step in Hong Kong’s alignment with the evolving global tax transparency framework and in addressing the reporting gap for crypto-assets.
CARF and the amended CRS are OECD-developed standards that establish separate but complementary reporting regimes: CARF is intended to capture transactions in crypto-assets, while the amended CRS is intended to extend the current scope of the CRS to capture holdings of crypto-assets.
Against this backdrop, the Bill has two main aspects. Firstly, it proposes amendments to the Inland Revenue Ordinance to give local effect to these OECD rules. In certain areas where Hong Kong has discretion or options, the Bill has incorporated feedback received during the consultation. Subject to the legislative process, CARF is proposed to commence on 1 January 2027 and the amended CRS on 1 January 2028.
The Bill also includes provisions establishing the administrative framework for CARF, namely the registration of in-scope crypto-asset service providers, record-keeping, compliance obligations and penalties. Equivalent amendments to the administrative framework under the existing CRS were introduced earlier under a separate bill gazetted in March to meet the OECD-imposed deadline and address issues identified in the OECD peer review. Once enacted, those amendments to the CRS administrative framework will take effect on 1 January 2027, ahead of the proposed commencement of the amended CRS on 1 January 2028. Please refer to our earlier news flash for details of those proposed changes. This news flash focuses on the Bill and our observations thereon.
South China and Hong Kong Tax Leader, China M&A Tax Leader, PwC Hong Kong
Tel: +[852] 2289 5616
South Private Clients and Family Office Tax Leader, PwC Hong Kong
Tel: +[852] 2289 3816