Form 1099-DA Readiness
Built to comply with — 2025 broker-reporting era
Form 1099-DA is the new IRS broker-reporting form for digital assets, effective for the 2025 tax year. Solo stakers and self-custodied validators are not covered brokers and will not receive a 1099-DA for staking rewards.
What Form 1099-DA is
Form 1099-DA is the IRS's new information-reporting form for digital asset transactions. Under final regulations issued June 28, 2024 (T.D. 10021), brokers are required to report digital asset dispositions on Form 1099-DA starting with the 2025 tax year (forms issued in early 2026).
The regulations implement IRC §6045, which has long required brokers to report proceeds from securities sales to both the IRS and the customer. The 2024 final rules extend that requirement to digital assets, defining "broker" broadly to include custodial exchanges and other custodial platforms that regularly facilitate digital asset transfers.
Solo stakers and self-custodied validators are not covered
The final regulations explicitly exclude non-custodial infrastructure from the "broker" definition. A solo ETH validator — or a staker using a non-custodial staking service — does not receive a Form 1099-DA for staking reward withdrawals. The staker's withdrawal address is self-custodied; there is no intermediary in the role of a "broker" that handles the staker's keys or controls the withdrawal.
This means the staking-reward income on a self-custodied validator's tax return is self-reported, not corroborated by a third-party 1099. The IRS's corroboration point for such taxpayers is the on-chain record itself — which is why TrueStake's reconciliation-to-the-wei approach and complete citation chain matter as an audit-defense posture.
What changes in the 2025 filing era
Starting with the 2025 tax year, taxpayers who did use a custodial exchange for staking may receive a Form 1099-DA reporting their rewards. Form 8949 instructions updated for 2025 require digital-asset dispositions to be reported using different boxes depending on whether a 1099-DA was issued for that transaction.
For self-custodied validators: nothing changes procedurally. The obligation to recognize staking rewards as income under Rev. Rul. 2023-14 existed before 1099-DA and continues unchanged. The absence of a 1099-DA does not reduce or defer the income-recognition obligation.
TrueStake's export is designed to function as the taxpayer's own audit-quality record of self-reported staking income — the substitute for the broker-issued form that solo stakers will never receive.
Not tax advice. Consult a qualified tax professional regarding your specific circumstances.
Citations
- [1]T.D. 10021, Digital Asset Broker Reporting Regulations (June 28, 2024)· Final regulations implementing IRC §6045 broker reporting for digital assets
- [2]IRC §6045 — Brokers — Returns of information· Statutory authority for 1099-DA broker reporting
- [3]IRS Form 1099-DA (2025)· The form itself — effective for 2025 tax year
- [4]Instructions for Form 8949 (2025)· Box guidance for digital-asset dispositions with and without 1099-DA