Digital Asset Broker W-8/9 Onboarding Timeline

New Accounts starting in 2026	Starting on January 1, 2026, brokers will be required to collect a Form W-9 or W-8 for all new accounts.
Pre-Existing U.S. Persons in 2026 & 2027	For sales effected prior to January 1, 2028 with an account established prior to January 1, 2026, the IRS is permitting brokers to rely on uncertified TINs, so long as they match the Name and TIN with the IRS TIN Matching System, and the result comes back as a match. In the event that the result is not a match, a Form W-8 or W-9 would be required.
Pre-Existing Foreign Persons in 2026 & 2027	For sales effected prior to January 1, 2028 with an account established prior to January 1, 2026, brokers may treat a customer as an exempt foreign person if the customer has not been previously classified as a U.S. person and there is no U.S. residence address on file. In the event that there is U.S. indicia, and the TIN does not produce a match with the IRS TIN Matching system, a Form W-8 or W-9 would be required.
All Accounts in 2028 & Beyond	The relief period ends on January 1, 2028, at which point all accounts, regardless of U.S. status or date established, must be documented with either a Form W-8 or W-9.

Digital Asset Sales Effected in 2025 & 2026

No backup withholding is required for any digital asset sales or exchanges during 2025 & 2026.

Digital Asset Sales Effected in 2027

For sales of digital assets in 2027, backup withholding is required for:

Accounts created on or after January 1, 2026, that are not documented with a Form W-8 or W-9.
Accounts with US indicia created prior to January 1, 2026, that are not documented with a Form W-8 or W-9, and do not have a matched TIN based on the IRS TIN matching program.

Digital Asset Sales Effected in 2028 & Beyond

For sales of digital assets starting on January 1, 2028, backup withholding is required for any accounts not documented with a Form W-8 or W-9.