Crypto Law Profile
TD 10021 would have extended broker gross-proceeds reporting to certain DeFi front-end services. Public Law 119-5 disapproved it under the CRA.
Gross Proceeds Reporting by Brokers That Regularly Provide Services Effectuating Digital Asset Sales was a United States Treasury and Internal Revenue Service final rule, issued as TD 10021 and published in the Federal Register on December 30, 2024 at 89 FR 106928. The rule would have amended Internal Revenue Code section 6045 regulations to require certain decentralized finance industry participants to file information returns and furnish payee statements as brokers for covered digital asset sales. The rule is no longer operative: Congress disapproved it under the Congressional Review Act through H.J. Res. 25, which became Public Law 119-5 on April 10, 2025, and Treasury/IRS later removed the rule from the Code of Federal Regulations effective July 11, 2025.
As of June 4, 2026, the correct legal status for TD 10021 is CRA-revoked; no legal force or effect. Public Law 119-5 states that Congress disapproved the IRS rule relating to “Gross Proceeds Reporting by Brokers That Regularly Provide Services Effectuating Digital Asset Sales” and that the rule “shall have no force or effect.” Treasury and IRS then published a July 2025 Federal Register action stating that, under Public Law 119-5 and the CRA, the final rule has no force or effect and that section 6045 regulations were being reverted to the text in effect before TD 10021’s effective date.
This profile is therefore not an implementation guide for an active DeFi broker rule. It preserves the rule’s history, scope, and relationship to the broader U.S. digital asset broker reporting framework while flagging that the December 2024 rule was disapproved and removed. The related July 2024 digital asset broker regulations, TD 10000, are a separate framework and were not nullified by H.J. Res. 25, according to House Report 119-7.
TD 10021 focused on non-custodial or decentralized finance participants that Treasury and IRS had reserved for later treatment when they finalized TD 10000 in July 2024. The December 2024 rule would have adopted a revised “digital asset middleman” definition and treated certain “trading front-end services” as broker-like effectuating services when the provider ordinarily would know, or be in a position to know, the nature of the transaction giving rise to gross proceeds from a digital asset sale.
The revoked TD 10021 should be distinguished from the still-separate broker reporting rules for custodial digital asset brokers. IRS public guidance states that digital asset broker reporting on Form 1099-DA begins for transactions on or after January 1, 2025, and that those final regulations apply to brokers that take possession of customer digital assets, including custodial trading platforms, certain hosted wallet providers, digital asset kiosks, and certain processors of digital asset payments. The same IRS guidance states that those final regulations did not include reporting requirements for decentralized or non-custodial brokers that do not take possession of the assets being sold or exchanged.
H.J. Res. 25 was introduced on January 21, 2025 by Rep. Mike Carey, reported by the House Ways and Means Committee, passed the House on March 11, 2025 by a 292-132 vote with one present, passed the Senate on March 26, 2025 by a 70-28 vote, and became Public Law 119-5 on April 10, 2025. Treasury and IRS completed the regulatory cleanup on July 11, 2025 through a “Final rule; CRA Revocation” notice. For Crypto Laws, the rule is best categorized as a revoked U.S. federal tax reporting regulation affecting DeFi and digital asset broker reporting history, with a cross-reference to TD 10000 and Public Law 119-5.
Public Law 119-5 disapproved TD 10021 under the Congressional Review Act, giving the rule no legal force or effect.
Treasury and IRS removed TD 10021 from the CFR and reverted section 6045 regulations to the prior text.
Before revocation, the rule would have revised the digital asset middleman definition for certain DeFi participants.
Would have treated certain user-interface services that process orders for digital asset sales as effectuating services.
Would have assessed whether providers had control or influence allowing them to determine whether gross proceeds arose.
Would have required covered brokers to file information returns and furnish payee statements for certain digital asset dispositions.
The text excluded validation services and licensing software or selling hardware from the new front-end rule.
TD 10021 stated a January 1, 2027 applicability date, but that date is not operative after CRA disapproval.
Treasury and IRS published proposed digital asset broker reporting regulations under REG-122793-19.
Treasury and IRS finalized custodial digital asset broker reporting rules and reserved DeFi middleman treatment.
Treasury and IRS published the DeFi-focused broker reporting final rule at 89 FR 106928.
Rep. Mike Carey introduced the CRA joint resolution to disapprove TD 10021.
The House Ways and Means Committee reported H.J. Res. 25 as H. Rept. 119-7.
The House passed H.J. Res. 25 by a 292-132 vote, with one present.
The Senate passed H.J. Res. 25 without amendment by a 70-28 vote.
The CRA joint resolution became law, disapproving TD 10021 and giving it no force or effect.
Treasury and IRS published a CRA revocation removing TD 10021 from the CFR.
DeFi trading front-end service providers, Digital asset brokers, Digital asset middlemen, Taxpayers, Wallet providers
Cryptocurrency, Digital assets, NFTs, Stablecoins
US bill fields refer to H.J. Res. 25 / Public Law 119-5, the Congressional Review Act vehicle that disapproved TD 10021. The profiled agency rule itself has no legal force or effect.
