Ledgible has formally submitted a comment letter to the U.S. Treasury Department and Internal Revenue Service (IRS) regarding the proposed regulations governing electronic delivery of Form 1099-DA statements for digital asset brokers. The letter was authored by and reflects Ledgible’s continued commitment to advancing practical, taxpayer-focused digital asset reporting policy.
The proposed regulations (REG-105064-25), published in March 2026, seek to modernize the electronic furnishing rules for Form 1099-DA by allowing digital asset brokers to move away from paper delivery methods while introducing new consent and notification requirements for taxpayers.
In its response, Ledgible acknowledged the Treasury and IRS’s efforts to modernize tax reporting infrastructure but raised concerns that several proposed provisions may unintentionally create operational burdens for brokers while adding friction for customers. The letter emphasizes the importance of maintaining a regulatory framework that is technology-neutral, operationally feasible, and aligned with the realities of modern digital asset platforms.
Key Recommendations from Ledgible
The comment letter outlines several recommendations intended to preserve taxpayer protections while ensuring that digital asset brokers can effectively implement compliant reporting systems.
Reducing Friction for Crypto-Native Platforms
Ledgible noted that many crypto-native organizations prioritize low-friction onboarding experiences and may struggle to operationalize rigid consent requirements during account creation. The letter recommends giving brokers flexibility to determine the appropriate time to obtain electronic delivery consent, including later in the customer journey when a reportable transaction actually occurs.
The letter also highlights that brokers often cannot determine at onboarding which type of Form 1099 a customer may ultimately receive, making separate consent frameworks difficult to implement in practice.
Harmonizing Rules Across All Forms 1099
A major theme throughout the submission is the need for harmonization across all Forms 1099, rather than creating a standalone framework exclusively for Form 1099-DA. Ledgible argued that customers increasingly interact with platforms offering multiple financial products, including digital assets, securities, staking rewards, and yield products, all of which may generate different types of tax forms.
The letter recommends establishing a unified, account-based electronic delivery framework that would allow taxpayers to consent once for all Forms 1099, regardless of the specific form ultimately issued.
Ensuring Equal Standards Between Digital Asset and Traditional Brokers
Ledgible also raised concerns that the proposed regulations impose notification requirements on digital asset brokers that exceed those currently applied to traditional financial institutions furnishing other Forms 1099, including Form 1099-B.
The letter argues that digital asset brokers should not be subject to higher operational standards than traditional brokers absent evidence that the existing electronic delivery framework has created meaningful taxpayer compliance issues.
Supporting Technology-Neutral Regulation
Finally, the comment letter encourages Treasury and the IRS to adopt a technology-neutral approach to future communications and notification requirements. As digital communication methods continue to evolve, Ledgible emphasized the importance of writing regulations flexible enough to accommodate future innovation without requiring continual regulatory updates.
Continuing Industry Engagement
Ledgible remains committed to constructive engagement with regulators, policymakers, and industry participants as digital asset reporting frameworks continue to mature globally. As the industry prepares for expanded reporting obligations under Form 1099-DA and broader international reporting initiatives such as CARF and DAC8, operational clarity and practical implementation pathways remain critical for successful compliance outcomes.
The full comment letter submitted to the IRS can be viewed here:
