CARF implementation follows a structured timeline coordinated across participating jurisdictions. Understanding these milestones is essential for compliance planning.

2022-2023: Adoption Phase

October 2022: OECD Publication

The OECD published the final CARF model rules, commentary, and XML schema. This established the framework that jurisdictions would transpose into domestic law.

May 2023: EU Adopts DAC8

The European Union moved quickly, adopting DAC8 which transposes CARF (with enhancements) into EU law. This committed all 27 EU member states to implementation.

November 2023: Joint Statement

76 jurisdictions issued a joint statement committing to implement CARF with first exchanges by 2027. Signatories included the US, UK, Canada, Australia, Japan, Korea, and Singapore.

2024-2025: Transposition Period

During 2024-2025, jurisdictions are transposing CARF into domestic law:

Legislative Process

  • Drafting domestic legislation based on OECD model rules
  • Parliamentary review and approval
  • Regulatory guidance development
  • Registration framework establishment

CASP Preparation

  • Gap analysis against current systems
  • System development or vendor selection
  • Process redesign for due diligence
  • Staff training programs

2026: First Collection Year

For early-adopting jurisdictions (including the EU), 2026 is the first full year of data collection:

January 1, 2026: Rules Take Effect

  • Due diligence requirements begin
  • Self-certification collection required for new users
  • Transaction tracking systems must be operational

Throughout 2026

  • Collection of user information via self-certification
  • Transaction data accumulation
  • Remediation of pre-existing accounts
  • TIN validation against user declarations

Pre-Existing Users: CASPs must complete due diligence on users who existed before CARF took effect. Deadlines vary but typically allow 12-24 months for remediation.

2027: First Reports and Exchange

Early 2027: First Reports Due

CASPs submit first CARF reports covering 2026 transactions:

  • Report submission to domestic tax authority
  • Deadline typically Q2 2027 (varies by jurisdiction)
  • XML format per OECD schema

September 2027: First Automatic Exchange

Tax authorities exchange collected information with partner jurisdictions:

  • Bilateral exchanges through CRS infrastructure
  • Multilateral exchanges through Common Transmission System
  • Information available for tax compliance verification

Regional Variations

European Union

  • January 2026: Data collection begins
  • 2027: First reports due and first automatic exchanges
  • Mandatory for all EU member states
  • Extended scope for non-EU CASPs serving EU residents

United States

  • Separate domestic rules (Form 1099-DA) with similar timeline
  • CARF participation for international exchange
  • Coordination with existing broker reporting requirements

United Kingdom

  • Post-Brexit independent implementation
  • Similar timeline to EU
  • HMRC consultation completed

Asia-Pacific

  • Singapore, Japan, Korea committed to 2027
  • Hong Kong considering participation
  • Australia implementation timeline TBD

Compliance Preparation Timeline

Recommended preparation milestones for CASPs:

  • 12+ months before go-live: Gap analysis and system design
  • 9 months before: System development or implementation
  • 6 months before: User acceptance testing
  • 3 months before: Process deployment and staff training
  • Go-live: Begin collecting required information
  • Ongoing: Monitoring, remediation, reporting

Conclusion

The CARF timeline is aggressive but achievable with proper planning. CASPs should not wait for final domestic rules—the OECD model provides sufficient clarity to begin preparation now. Organizations that delay risk non-compliance at go-live.

Automate CARF Compliance

Self-certification, TIN validation, transaction reporting, and XML generation for 76 jurisdictions.

Expert Consulting