Crypto Law Profile

Infrastructure Investment and Jobs Act Digital Asset Broker Reporting Provisions

IIJA §80603 created U.S. digital-asset broker reporting rules under IRC §§6045 and 6045A, with Form 1099-DA phased in from 2025.

United States Effective Law Jan 1, 2024

At a glance

Status Enacted federal tax reporting statute with phased Treasury/IRS implementation.
Statute Pub. L. 117-58 §80603 amended IRC §§6045, 6045A, and 6050I for digital assets.
Form 1099-DA Gross proceeds reporting applies to certain brokered transactions from Jan. 1, 2025.
DeFi Rule The 2024 non-custodial broker rule was revoked under the CRA and has no legal force.

Bill details

Bill number
H.R. 3684
Session
117th Congress
Chamber
Multiple
Legislative stage
Enacted

Action

Last action
Became Public Law No. 117-58.
Last action date
Nov 15, 2021

Sponsor

Primary sponsor
Rep. Peter A. DeFazio
Sponsor party
Democratic
Co-sponsors
5 House cosponsors listed by Congress.gov.

Source

Source provider
Congress.gov
Source ID
H.R.3684 / Pub. L. 117-58
State legislature
Official bill page

Overview

The Infrastructure Investment and Jobs Act digital asset broker reporting provisions are U.S. federal tax information-reporting rules enacted in Public Law 117-58, Section 80603. The statute amended Internal Revenue Code sections 6045, 6045A, and 6050I to address reporting for certain digital asset transactions. As of June 4, 2026, the statutory provisions are in force, while Treasury and IRS implementation is phased and supported by final regulations, transition relief, and form guidance.

Purpose of the IIJA Digital Asset Broker Reporting Provisions

Section 80603 was designed to place certain digital asset transactions into the existing federal information-reporting system for brokers. Rather than creating a standalone crypto tax regime, the provision expanded tax reporting infrastructure by adding digital assets to selected broker and transfer-reporting rules. The statutory definition of broker includes any person who, for consideration, is responsible for regularly providing a service that effectuates transfers of digital assets on behalf of another person.

The statute also defines a digital asset, unless Treasury provides otherwise, as a digital representation of value recorded on a cryptographically secured distributed ledger or similar technology. This definition is central to the section’s broker-reporting rules and the separate amendment treating digital assets as cash for purposes of section 6050I.

Key Reporting Rules for Digital Asset Brokers

The core broker-reporting change is in section 6045. Digital assets were added to the list of specified securities for basis-reporting purposes, and Treasury and the IRS issued final regulations requiring covered brokers to file information returns and furnish payee statements for certain digital asset sales and exchanges. IRS guidance states that Form 1099-DA reporting begins with transactions on or after January 1, 2025, with gross proceeds reporting first and basis reporting for certain transactions on or after January 1, 2026.

The final 2024 regulations apply mainly to brokers that take possession of digital assets being sold by customers. IRS examples include custodial digital asset trading platforms, certain hosted wallet providers, digital asset kiosks, and certain processors of digital asset payments. The same IRS guidance states that the final regulations do not include reporting requirements for commonly described decentralized or non-custodial brokers that do not take possession of the digital assets sold or exchanged.

Transfer Reporting and Section 6050I Treatment

Section 80603 also amended section 6045A. It clarified that transfer-statement reporting can apply to covered securities that are digital assets and added a reporting rule for certain transfers of digital assets from a broker-maintained account to an account or address not known to be associated with another broker.

The statute separately amended section 6050I by adding digital assets to the definition of cash for certain trade-or-business receipts reporting. However, IRS Announcement 2024-4 provides transitional guidance stating that, until Treasury and the IRS issue section 6050I regulations and related forms or instructions, digital assets are not required to be included when testing whether cash received in a transaction exceeds the $10,000 reporting threshold. Non-digital-asset cash reporting obligations remain separate.

Status, Phase-ins, and DeFi Rule Revocation

The final custodial-broker regulations, TD 10000, were published in the Federal Register on July 9, 2024 and became effective September 9, 2024. IRS guidance summarizes the operational phase-in: gross proceeds reporting for transactions on or after January 1, 2025; basis reporting for certain transactions on or after January 1, 2026; and real-estate reporting for digital assets used in covered closings on or after January 1, 2026.

Treasury and the IRS later finalized a separate December 2024 rule for certain decentralized finance participants, TD 10021. Congress disapproved that rule under the Congressional Review Act, and the President signed the disapproval resolution as Public Law 119-5 on April 10, 2025. A July 11, 2025 Federal Register action states that the disapproved rule has no legal force or effect and that the relevant regulations were reverted.

Implementation remains active. IRS pages updated in 2026 identify Form 1099-DA as the current broker reporting form, list transition relief for penalties and backup withholding, and note additional guidance for basis identification and electronic furnishing. This profile should therefore be reviewed periodically as IRS forms, instructions, and notices continue to develop.

Key provisions

Expanded broker definition

Adds certain persons providing services that effectuate digital asset transfers for others to the broker definition.

Broker reporting Jan 1, 2024 Source

Digital assets as specified securities

Treats digital assets as specified securities for broker basis reporting, subject to final regulations and phase-in rules.

Basis reporting Jan 1, 2026 Source

Form 1099-DA reporting

Requires covered brokers to report certain digital asset sales and exchanges on Form 1099-DA beginning with 2025 transactions.

Information returns Jan 1, 2025 Source

Transfer reporting under 6045A

Adds reporting for certain digital asset transfers from a broker account to a non-broker account or address.

Transfers Jan 1, 2024 Source

Section 6050I digital asset treatment

Adds digital assets to the statutory cash definition, but IRS transition guidance defers digital asset threshold testing pending regulations.

Trade receipts Source

Custodial broker scope

Final 2024 regulations focus on brokers taking possession of customer digital assets, including custodial platforms and hosted wallets.

Custody Sep 9, 2024 Source

Non-custodial broker rule revoked

The separate 2024 DeFi/non-custodial broker rule was disapproved under the Congressional Review Act and has no legal force.

DeFi Apr 10, 2025 Source

Transition relief

IRS notices provide transition relief for certain penalties, backup withholding, and basis-identification issues during implementation.

Relief Jun 12, 2025 Source

Timeline

  1. H.R. 3684 introduced

    Rep. Peter DeFazio introduced H.R. 3684 in the 117th Congress.

    Introduced Source
  2. Senate passed amended bill

    The Senate passed H.R. 3684 with an amendment by a 69-30 vote.

    Passed Source
  3. House agreed to Senate amendment

    The House agreed to the Senate amendment, resolving differences before presentment.

    Passed Source
  4. Enacted as Public Law 117-58

    H.R. 3684 became Public Law 117-58, including §80603 on digital asset information reporting.

    In force Source
  5. Initial IRS transition guidance

    IRS Announcement 2023-2 deferred additional §§6045 and 6045A digital asset reporting until final regulations.

    Published Source
  6. Proposed broker regulations

    Treasury and the IRS published proposed digital asset broker reporting regulations.

    Proposed Source
  7. Custodial broker final regulations

    TD 10000 finalized gross proceeds, basis, amount-realized, and related digital asset reporting rules.

    Published Source
  8. DeFi rule disapproved

    Public Law 119-5 disapproved the December 2024 non-custodial broker rule under the CRA.

    Repealed Source
  9. Additional transition relief

    Notice 2025-33 extended and modified transition relief for information reporting and backup withholding.

    Published Source
  10. IRS digital asset page updated

    IRS updated its digital asset page describing Form 1099-DA phase-ins and transition relief.

    Published Source

Who it affects

Actors

Custodial trading platforms, Digital asset brokers, Digital asset kiosks, Hosted wallet providers, Payment processors, Real estate reporting persons, Taxpayers

Asset classes

Cryptocurrency, Digital assets, NFTs, Stablecoins

Official sources

Editorial note

This profile covers the digital asset information-reporting provisions in IIJA §80603, not the full infrastructure statute. It reflects the CRA revocation of the separate 2024 DeFi/non-custodial broker rule.