The IRS has officially finalized and published the Form 1099-DA, marking a pivotal moment in the evolution of digital asset tax reporting. This announcement is a significant milestone for software providers and brokers, as it provides clarity and allows the industry to proceed confidently with technical development to support 2025 reporting in Q1 of 2026. But as we celebrate this progress, it’s essential to recognize the critical gaps that still remain.

Let’s take a closer look at the situation.
The Form 1099-DA Is Ready… But Are We?
The finalized taxpayer Form 1099-DA is now available, and you can access it here. While this is a step forward, there are still unresolved issues that could hinder the industry’s ability to meet the IRS’s deadlines efficiently.
Key Missing Pieces
- Technical Specifications from the IRSOne of the most critical elements still missing is the technical specification guidance for supporting Form 1099-DA filings. The IRS has confirmed that all filings must go through their newer IRIS system rather than the legacy FIRE system. However, the necessary technical specification publications, such as Publication 5718, have not yet been updated to reflect support for Form 1099-DA.For brokers and software developers, this lack of guidance is a significant roadblock. Without the technical details, building compliant solutions becomes an exercise in uncertainty. This delay underscores the urgent need for the IRS to provide clarity to ensure stakeholders can meet the 2026 reporting requirements seamlessly.
- State Tax Authority GuidanceAnother unresolved issue is how state tax authorities will handle Form 1099-DA filings. As of now, we haven’t seen any updates or announcements from states regarding whether these forms will be required at the state level and, if so, how they will need to be filed. This uncertainty leaves brokers and software providers in limbo, unable to fully develop solutions that address both federal and state reporting requirements.State-level guidance is a critical component of the digital asset reporting landscape. Until there is more clarity, the industry will be unable to deliver comprehensive solutions that meet all regulatory requirements.
What’s Next?
As we move forward, the race to finalize technical development for Form 1099-DA compliance is on. But it’s not a race that can be won without the necessary tools and information.
For now, here are some steps stakeholders can take:
- Stay Informed: Regularly check for updates from the IRS on Publication 5718 and other relevant technical specifications.
- Engage with State Authorities: Begin dialogues with state tax departments to understand their positions on Form 1099-DA filings.
- Plan Proactively: Even in the absence of complete guidance, start mapping out potential development pathways to minimize delays once the missing pieces are provided.
Final Thoughts
The finalization of Form 1099-DA is a landmark event, but the work is far from over. As we navigate these gaps in guidance and state-level regulation, collaboration and proactive planning will be key to ensuring a smooth transition to compliance with these new reporting requirements.
At Ledgible, we’re keeping a close eye on these developments and are committed to helping brokers, software providers, and other stakeholders stay ahead of the curve. Together, we can ensure the digital asset industry is prepared to meet the challenges of 2026 reporting and beyond.