The decision came in November 2025, weeks before CARF was supposed to go live. At its session of 3–4 November 2025 the National Council’s Economic Affairs and Taxation Committee suspended its deliberation on the partner-state bill, and on 26 November 2025 the Federal Council confirmed what followed from that: the crypto-asset provisions of Swiss automatic-exchange law would not apply in 2026 at all. Switzerland will implement CARF on 1 January 2027 at the earliest.
The headline spread fast. “Switzerland delays crypto tax sharing” was the framing most outlets used, and it was accurate enough to quote. But the implications for people who actually hold crypto in Switzerland are more layered than that framing suggests.
This is what the delay actually means — and, more practically, what it does not mean.
Two Different Timelines Running in Parallel
The confusion in most coverage comes from conflating two things that Switzerland decoupled at the end of 2025.
Timeline 1: The law. Switzerland’s implementation of CARF sits in the Federal Act and Ordinance on the International Automatic Exchange of Information in Tax Matters, and Parliament approved the underlying multilateral agreement — the CARF MCAA of 8 June 2023 — in its final vote of 26 September 2025. This is the framework that defines who must report, what must be collected, and how the data must be structured.
Timeline 2: The switch. The Federal Council can only ratify that agreement once Parliament has approved the partner states Switzerland will exchange with. The committee suspended exactly that bill — by 18 votes to zero with four abstentions — saying it would return to it once there is clarity on how other states are proceeding and on how the international community reads the standard. Several significant markets had already pushed their own start dates back.
The result is blunter than “delayed exchange.” The machinery is built and switched off. Nothing runs through it for 2026.
What the first commentary understated
The suspension landed with under two months to go before the regime was supposed to start, which is why several Swiss legal and compliance firms published commentary within the same week. What most of that commentary — and most of the January coverage that followed it — understated is how much the pause switched off. The law is real and it is coming. Nothing under it is running now. Those are two different statements, and "2027" does not mean there is nothing to do until then.
What 2026 Actually Looks Like
If the exchange is delayed, what did 1 January 2026 activate? Less than many explainers published in late 2025 assumed.
There is no due-diligence duty in 2026. The State Secretariat for International Finance (SIF) is explicit about it in its published questions and answers: the due-diligence provisions relating to CARF “will not apply in 2026,” and accordingly “reporting providers of crypto services will not be required to exercise due diligence under Swiss law in 2026.” Your Swiss bank or exchange is not under a CARF collection obligation this year.
Nothing moves in either direction. Because the treaty cannot be ratified until Parliament approves the partner states, it does not apply to Switzerland at all in 2026 — and Switzerland will not receive crypto-asset data from abroad for the 2026 calendar year either.
The clock for existing users has not started. Swiss providers must obtain a self-certification from pre-existing crypto-asset users within twelve months of a cut-off date. That cut-off date moved with everything else: it is now the day before Switzerland activates CARF with its first partner jurisdiction, so the twelve months have not begun to run.
Providers may still prepare voluntarily. SIF confirmed that a provider can, on its own initiative and on its own contractual basis, bring its self-certification into line with the OECD framework from 1 January 2026. Some have; others paused the build. That is a commercial choice rather than a legal duty, and it is why two Swiss institutions can currently ask you for quite different things. Registration with the Swiss Federal Tax Administration (SFTA), by contrast, is not a 2026 obligation at all.
What Gets Reported When CARF Does Take Effect
Understanding what CARF covers requires understanding what counts as a reportable transaction.
In scope: exchanges of crypto for fiat currency, crypto-to-crypto swaps, transfers between service providers, and outbound transfers to external wallets. The definition of “relevant crypto-assets” is broad — it covers any digital asset that can be used for payment or investment purposes, which includes Bitcoin, Ethereum, stablecoins, tokenized securities, and investment-purpose NFTs.
Out of scope: non-tradable digital collectibles (think limited-edition art with no secondary market), central bank digital currencies, and — critically — self-custodied assets held without any Swiss service provider involvement. If you hold crypto in your own hardware wallet and never use a Swiss exchange or bank to acquire, transfer, or trade it, there is no RCASP to report on your behalf.
CARF’s reporting obligation falls on Reporting Crypto-Asset Service Providers, not on individual holders directly. If you hold crypto entirely in self-custody — acquired outside Switzerland, held in your own wallet, transacted without using a Swiss-supervised institution — no Swiss RCASP has an obligation to report your holdings.
This does not affect your Swiss wealth tax or income tax obligations, which exist independently of CARF. It means, more narrowly, that CARF data exchange would not be the mechanism through which foreign tax authorities learn about those holdings.
The 2026 vs. 2027 Comparison That Actually Matters
Most coverage focused on what changed (the exchange date). The more useful comparison for someone holding crypto in Switzerland is what is different between the two years in practical terms. If you want the prior question answered first — what CARF actually reports about you as an individual, line by line through the framework — there is a plain reading of that here: What CARF Actually Reports About You.
| 2026 | 2027 at the earliest | |
|---|---|---|
| CARF law | On the statute book, provisions not applicable | Applies from the date Parliament activates it |
| RCASP due diligence and data collection | Not required under Swiss law | Begins when Switzerland activates with a first partner state |
| RCASP registration with the SFTA | Not required | Required |
| International data exchange | None, in either direction | Only after Parliament approves the partner states |
| Self-certification deadline for existing users | Clock has not started | Twelve months from the day before activation |
| Swiss domestic reporting | No change — wealth tax and income tax obligations exist independently | No change |
| Self-custody impact | None | None |
| Action required from holders | Get your declarations in order while the channel is dark | Ensure foreign tax obligations are met before data reaches foreign authorities |
The core practical difference is not where 2026 data sits. It is that there is no CARF data for 2026. Your wealth tax and income tax obligations for the year are untouched — what has not started is the parallel channel that would let another tax authority check them against your platform’s records.
The postponement does not make the framework go away. It hands you a defined window, and the window is quieter than the coverage suggested.
Why the Committee Paused
The reason for the delay is worth understanding, because it tells you something about how durable the pause is likely to be.
The committee suspended deliberations not because Switzerland changed its mind about CARF in principle — Parliament approved the underlying OECD agreement in September 2025 with clear support. The pause was about timing: the vote was 18 to zero with four abstentions to set the partner-state bill aside and resume once it is clear how other states are proceeding and how the standard is being interpreted internationally.
This is a different category of delay than a policy reversal. Switzerland is not walking back its commitment to international crypto data sharing. It is declining to walk first through a door several of its peers have not yet walked through — which, for a jurisdiction whose financial sector competes partly on exactly this kind of timing, is a familiar instinct rather than a surprising one.
Regulatory pattern note
Worth separating from the CARF story: the CRS side of the 2026 update did take effect on 1 January 2026 as planned, and it ran in the opposite direction to what a number of summaries claimed. Rather than pulling Swiss associations and foundations into scope, it wrote the OECD exemption for qualified non-profit entities into Swiss law, so tax-exempt bodies count as non-reporting financial institutions. CARF was postponed; the CRS amendments around it were not.
What This Means for Swiss Crypto Banks
For AMINA Bank — which traded as SEBA Bank until it rebranded on 1 December 2023 — Sygnum, and the crypto custody arms of the major cantonal banks, the postponement lands as a project-schedule problem rather than a compliance one.
These institutions have been building CARF-capable data infrastructure since 2024. What changed is that none of it is legally required yet: no SFTA registration duty, no due-diligence duty, no transmission deadline, and no fixed date to plan against, because the activation date belongs to Parliament rather than to the regulatory calendar.
Some are carrying on regardless, and SIF has explicitly allowed that — a provider may align its self-certification with the OECD framework from 1 January 2026 on its own contractual basis. Others paused. That is why two Swiss institutions can currently give you two different answers about what they need from you, and why neither answer is wrong.
From a practical standpoint, this matters most for clients who had expected 2026 to be the year their home country received information about their Swiss crypto holdings. Nothing is being collected under CARF for 2026, so nothing will be exchanged for it.
The Holder’s Honest Read
Here is what the delay does not mean.
It does not mean Switzerland has backed away from CARF. The statute is on the books, the institutional infrastructure is largely built, and the 74-country partner list is suspended rather than withdrawn.
It does not mean you have until 2027 to get your holdings in order. Your Swiss wealth tax obligations — which require declaring the market value of your crypto portfolio as of December 31 each year — exist completely independently of CARF and were unaffected by the delay. The same applies to any income tax obligations arising from staking rewards or crypto classified as business income.
It does not mean foreign tax authorities cannot access information about your Swiss crypto holdings through other channels. Mutual legal assistance treaties, CRS data on crypto-linked fiat accounts, and direct requests remain available. CARF is a new mechanism, not the only one.
What the postponement does mean, practically: if you have been intending to review your holding structure, assess your reporting obligations in your country of tax residence, or check that your Swiss bank accounts and exchange positions are reflected correctly in your domestic filings — the window is open, and it is wider than the January coverage implied, because nothing is accumulating under CARF yet. That is a thing to use, not a thing to wait out.
What Comes Next
Three things are worth tracking as 2026 progresses.
Partner state list resumption. The committee said it would take the bill back up in 2026. As this note is updated in September 2026, it has not. When it does, the order matters: Parliament approves the partner states first, and only then can the Federal Council ratify. The effective date is Parliament’s to set, not the government’s.
The SFTA’s own guidance. SIF has said the Federal Tax Administration will publish its CARF guidance only after the decision on implementation is taken. Until that document exists, the operational detail — cut-off dates, documentation deadlines, file formats — is not settled, which is part of why institutions are giving inconsistent answers.
The CRS changes that did happen. The 1 January 2026 amendments to the Common Reporting Standard went ahead: new treatment for certain e-money products and central bank digital currencies, an extension of the term “financial assets” to cover certain crypto-assets, and the exemption for qualified non-profit entities written into Swiss law. These landed with far less coverage than the CARF postponement and have their own implications for Swiss structures.
For those watching the regulatory calendar: CARF is written, not running. 2026 is a blank year in the record. The window that opened with the postponement closes on a date nobody has set yet — which is a reason to use it now rather than to wait to be told when it ends.
Related field notes: FINMA’s Crypto Guidance 01/2026 explains the custody infrastructure that CARF reporting depends on at the institutional level. The Swiss Crypto Tax Advantage covers the wealth tax and capital gains regime that operates independently of CARF. MiCA vs. FINMA examines how the EU regulatory framework that governs CARF partner states interacts with Switzerland’s approach.