No, You Won't Get a 1099-DA From Your Crypto Payment Gateway. Here's What to File Instead.

If you accept crypto through a non-custodial payment gateway in 2026, you will not get a Form 1099-DA from your gateway in early 2027. You will not get one in 2028 either. This is not an oversight. It is how the rules are written.

That sentence catches merchants off guard every quarter I bring it up. The mental model people carry over from card processing — Stripe sends me a 1099-K, the IRS already has the number, I just match — does not transfer. The IRS designed the rules this way on purpose. The burden of reporting your crypto receipts sits on you, the merchant, no matter how your gateway is set up.

This post explains why no 1099-DA shows up in your inbox, what you actually need to file instead, and the three pieces of data you need to capture at every receipt so that filing it isn’t painful.

Why no 1099-DA arrives

Form 1099-DA — Digital Asset Proceeds From Broker Transactions — is the form that custodial brokers (centralized exchanges that hold customer assets, mostly) use to report sales and exchanges of digital assets to the IRS. The 2026 instructions spell out who is in scope: brokers who effect sales for customers.

Two things matter for the merchant question.

First, the form reports sales by a broker on behalf of a customer. A merchant accepting crypto from a customer isn’t selling crypto through a broker. The customer pays you. The funds move on-chain to your wallet. There is no broker effecting a sale of anything for you.

Second, the broker analysis is narrower than “anyone involved in a crypto payment.” The final regulations and 2026 instructions cover brokers that effect sales of digital assets for customers, including certain digital asset middlemen and processors of digital asset payments. A payment processor lands in the broker bucket when it regularly takes in digital assets from one party and then pays out to another party. A non-custodial gateway works differently. The customer’s payment lands directly in your wallet. The gateway never touches the funds.

So no 1099-DA from a non-custodial gateway. That covers Aurpay, BitPay’s non-custodial flows, Coinbase Commerce’s non-custodial products, BTCPay Server, and the rest.

What about custodial gateways?

A few payment processors do custody funds. They take customer crypto into their own pooled wallets, convert it to fiat or stablecoin, and then pay you out. These services look closer to traditional payment processors, and parts of the broker reporting rules can apply depending on the setup.

Even there, the form you might receive looks nothing like the 1099-K you get from Stripe. The 1099-K reports gross payment volume. The 1099-DA reports proceeds and (starting with 2026 transactions) cost basis of digital asset dispositions. If the gateway converted your customer’s BTC to USD before depositing fiat to your bank, that’s a disposition on the gateway’s side, not a sale you initiated. Whether that produces a form to you is fact-specific.

For most merchants reading this — most of the merchant-friendly options are non-custodial — none of this applies. You don’t get a 1099-DA. Period.

What the 1099-DA timeline actually looks like

For context, since most crypto-curious merchants have seen headlines about new reporting rules:

• 2025 calendar year transactions, reported in early 2026: brokers report gross proceeds only. No cost basis yet. The IRS announced good-faith relief from penalties for this first year if the broker made a reasonable attempt to comply.
• 2026 calendar year transactions, reported in early 2027: brokers must also report cost basis on covered transactions.
• Filing deadlines: these follow the standard information-return cycle. 2025-year forms are due in early 2026, and 2026-year forms in early 2027. The merchant point: these are broker deadlines, not a deadline for your gateway to send you a receipt summary.

These dates apply to brokers. If you run a merchant business on a non-custodial gateway, they don’t touch you on the receiving end. They would only touch you if you yourself became a “broker,” and accepting crypto payments doesn’t do that.

What you actually file

Without a 1099-DA arriving to do half the work for you, you file the way crypto-accepting businesses have filed since Notice 2014-21 first established that digital assets are property: as ordinary income at the fair market value when received, then track basis for any later disposition.

If you’re a sole proprietor, single-member LLC, or independent contractor accepting crypto for goods and services, here’s the path through your 1040:

1. Schedule C: report the gross receipts. The amount is the USD fair market value of the crypto at the moment of receipt. IRS guidance on digital asset transactions is unambiguous: receipt of digital assets for services or as payment for goods sold is ordinary income measured at FMV.
2. Schedule D + Form 8949: when you later dispose of the crypto — converting to USD, swapping to another token, paying a supplier with it — calculate gain or loss against the basis (the FMV at receipt). Short-term or long-term depends on how long you held.
3. The digital asset question on Form 1040: “At any time during the year, did you receive, sell, exchange, or otherwise dispose of a digital asset?” Yes. The question has been on the 1040 since 2019 and continues unchanged.

If you operate as an S-corp, C-corp, or multi-member LLC taxed as a partnership, the same logic applies but rolls up through Form 1120-S, 1120, or 1065 respectively. The income line is gross receipts at FMV at receipt; the dispositions line is on the entity’s own gain/loss schedule.

The three numbers you must capture, at every receipt

The above filings work only if you have clean records. The records work only if you captured the right data at the moment the payment hit. There are three numbers:

1. USD fair market value at the block timestamp. Use the moment the transaction was confirmed on-chain, not the time the customer clicked “pay” or the time your dashboard caught up. This is the basis under IRS rules and the cost basis for any later disposition.
2. Transaction hash. The unique 64-character identifier of the on-chain transaction. Without this you cannot prove receipt to the IRS or to your CPA.
3. Receiving wallet address. Establishes that the asset became yours, not someone else’s.

Your payment gateway should expose all three through its dashboard, API, or CSV export. If it doesn’t, and some don’t, you can rebuild the data from your wallet’s transaction history on a block explorer. Either way, you cannot file accurately without these three numbers.

The mismatch — no 1099-DA arrives, yet you still owe the IRS the same information — is why discipline at the receipt point matters. No platform behind you is covering for missed records.

What changes when you sell or convert

Two separate tax events live in most crypto-accepting businesses:

Event one: receipt. Customer pays you 0.01 BTC when BTC = $100,000. You recognize $1,000 of ordinary income on Schedule C. Your basis in that 0.01 BTC is $1,000.

Event two: disposition. A month later, BTC is at $110,000. You convert your 0.01 BTC to 1,100 USDC. You realize a capital gain: proceeds $1,100, basis $1,000, gain $100. Short-term capital gain since you held less than a year. Report on Form 8949 → Schedule D.

Most merchants miss event two because the dollar value at sale sits so close to the dollar value at receipt. They think there’s nothing to report. There is. Even a $5 gain on a stablecoin conversion is technically reportable. In practice, a stablecoin-to-USD conversion near 1:1 produces gain or loss that often rounds to zero, but you should still have the trail.

BTC and ETH conversions are where the bigger gain/loss exposure lives. If you collect $50,000 of BTC over a quarter and convert to USD the following quarter at a 20% higher BTC price, that’s a $10,000 capital gain to report on top of the $50,000 ordinary income already recognized at receipt.

State income tax (the easy part) and sales tax (its own conversation)

Most states follow federal treatment of digital assets as property. Receipt = income at FMV. Disposition = gain/loss. Your state return will mirror the federal calculation in most cases.

Sales tax is a separate problem and gets its own post in this series. Quick preview: even though no 1099-DA arrives, you still owe sales tax on taxable receipts in jurisdictions where you have nexus, calculated at FMV in USD and remitted in USD. The “did I get a form” question and the “do I owe state sales tax” question are unrelated.

The year-end checklist

If you accept crypto and want to be ready when your CPA opens your file:

• Per-receipt records with tx hash + block timestamp + USD FMV at timestamp + receiving wallet, for every payment all year.
• Per-disposition records for every conversion, swap, or outbound payment: date, proceeds in USD, basis from the corresponding receipt, gain or loss.
• Reconciliation between your gateway’s transaction list, your wallet’s on-chain history, and your accounting system’s general ledger — quarterly at minimum.
• A written policy for which asset price source you use to calculate FMV (e.g., CoinMarketCap, Coinbase spot, Kraken mid-price), and the time-of-day convention. Pick one. Stick with it.
• For each entity in your structure, a clear answer to “did this entity receive, sell, exchange, or dispose of a digital asset this year.” If yes — you answer yes on the 1040 question.

None of this changes with the 1099-DA rollout, because the 1099-DA doesn’t come to you. The IRS expects you to have done the work all year. The 1099-DA they may receive from a custodial counterparty (e.g. the exchange where you eventually converted BTC to USD) is one input they match against. It won’t represent your gross receipts. It represents your dispositions on that exchange’s platform. Your receipts data has to come from you.

Three questions to bring to your tax preparer

1. For my crypto-accepting business, what’s my entity’s filing position and which schedules carry crypto receipts vs. dispositions?
2. How are we documenting FMV at receipt for each payment — which price source, which time-of-day, and is it written into our accounting policy?
3. What’s the audit defense if the IRS asks “where did this $50,000 of digital asset receipts come from”? Walk me through the documentation chain from on-chain transaction to general ledger.

The 1099-DA was supposed to make digital asset tax compliance easier. For investors and exchange users, it largely will. For merchants accepting crypto through non-custodial gateways, what you file doesn’t change. What does change: the IRS now holds machine-readable data on the rest of the digital asset ecosystem, and your receipts that didn’t generate a 1099-DA stand out by their absence. If your books are clean, that’s fine. If they aren’t, it’s a problem.

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This article is general information for merchants and finance leads. It is not tax or legal advice, and it does not establish a client relationship. Tax treatment of digital assets depends on your specific facts and your entity structure, and IRS guidance continues to evolve. Consult a licensed tax preparer who has filed crypto-business returns before applying any of this to your filings.