On 27 August 2026 HMRC published, for the first time, official statistics on taxable cryptoasset gains. The headline it chose was the 240 people who declared more than £1 million of capital gains from cryptoassets in the 2024 to 2025 tax year, reporting £717 million between them. That is the number that will travel. It is not the number that matters most to an accountancy practice.
The figure to sit with is the one underneath it. In the same year, 17,600 individuals made Capital Gains Tax-liable disposals of cryptoassets, reporting total disposal proceeds of £13.8 billion and gains of £1.38 billion — an average gain of £78,000 per individual. Seventeen and a half thousand people is a small population by tax standards. An average realised gain of £78,000 is not a small event in any one of their lives, and in a very large proportion of cases the first regulated professional to see that number written down is an accountant preparing a Self Assessment return.
Why this data did not exist before
HMRC is explicit that this is the first time it has published this specific data, and equally explicit about why it can. The statistics follow the introduction of a dedicated part of the Self Assessment return for cryptoasset capital gains. Before that box existed, crypto disposals were folded into the general capital gains pages and were, as a dataset, invisible. The profession has spent several years being asked about crypto by clients without anyone being able to say how common it actually was. Now there is a published, accredited official statistic, released as part of HMRC’s annual Capital Gains Tax statistics.
That matters for a practical reason. A firm deciding whether crypto is a fringe issue or a real one in its client base has, until this week, had nothing but anecdote to go on. It now has a number, a demographic profile and a direction of travel, all from a primary source. HMRC also reports that around 87% of the individuals reporting cryptoasset gains were male and around 13% were female.
The 2027 turn
The more consequential half of the announcement is about what happens next, and it is the part a practice should be planning around rather than reading as background.
From January 2026 the UK began implementing the Cryptoasset Reporting Framework, an international standard developed by the OECD. Under CARF, cryptoasset service providers are required to report customer information to tax authorities, and HMRC states it will receive data from 2027, describing the purpose plainly: helping to identify cryptoasset gains and income that have not been declared. Providers that fail to comply may face penalties of up to £300 per user.
Accountancy Age, publishing figures from national accountancy group UHY Hacker Young on the same day, puts more detail on the timetable and on the pressure already being applied. It reports that HMRC issued 81,000 nudge letters to crypto holders over the past twelve months, a 25% increase year on year, against 65,000 in 2024/25 and 27,714 in 2023/24. On CARF it dates the first automatic data feeds to 31 May 2027, covering 52 jurisdictions including Jersey, Guernsey, the Cayman Islands, Liechtenstein and Ireland, with a further 15 jurisdictions including Switzerland, Singapore and Gibraltar joining in 2028.
Until 2027 an undeclared crypto gain is an omission. After 2027 it is a discrepancy between two datasets, and only one of them was written by the client.
That distinction is the whole story for a practice. Every conversation about historic crypto activity that happens in the next eighteen months happens on one side of that line. Every one that happens afterwards happens on the other. HMRC operates a Crypto Disclosure Service on GOV.UK for people with undeclared cryptoasset income or gains, and it reports that its education and compliance activity since late 2023 generated an estimated additional £168 million of Capital Gains Tax in 2024 to 2025 alone.
What the return actually shows you
Set the compliance question aside for a moment, because it is the one the profession will naturally reach for first and it is not the more interesting one.
A cryptoasset disposal on a return tells an accountant several things at once. It says the client held a concentrated position in a single, volatile asset class. It says that position was almost certainly held outside a pension or an ISA, because the mainstream UK wrappers do not accommodate direct holdings of this kind. It says a realised sum has landed somewhere — usually a current account — and that the client made a decision to sell without, in most cases, anyone having modelled what the proceeds were for. And where the gain is large, it says the shape of that client’s balance sheet has changed materially in a single tax year.
Those are the classic conditions a financial planner is trained to examine: concentration, wrapper inefficiency, an uninvested lump sum, and a change in circumstances that nothing else in the client’s arrangements has caught up with. They are also, almost by definition, conditions that go unexamined, because the population reporting these gains and the population receiving regulated advice barely overlap. The lang cat’s State of Advice Report 2025 found that just 9% of UK adults had paid for financial advice in the preceding two years, and put the average age of an IFA client at 59. A cohort that is 87% male and reporting gains on Bitcoin, Ethereum and Dogecoin is not, in the main, that cohort.
Putting real numbers on it
The following is illustrative arithmetic, not a real client, and it is deliberately built on the published average rather than on the eye-catching £1 million cases.
A client disposes of cryptoassets in the 2026 to 2027 tax year and realises a gain of £78,000 — the average HMRC reports for 2024 to 2025. Their taxable income is £45,000, which puts them above the basic rate band, so the whole gain is taxed at the higher rate. Working it through with the rates published on GOV.UK and checked on 28 August 2026:
- Gain: £78,000, less the annual exempt amount of £3,000 for 2026 to 2027, leaves £75,000 chargeable.
- Rate: 24% for a higher rate taxpayer on gains made from 6 April 2026. Basic rate taxpayers pay 18% on so much of the gain as falls within the basic rate band and 24% above it.
- Tax: £18,000, payable by 31 January 2028.
- Left over: £60,000, plus the original cost, sitting in a bank account for roughly sixteen months before the tax is due.
The compliance work here is a computation. The interesting question is the last bullet. Sixty thousand pounds of realised, post-tax proceeds arriving in a current account is a planning event, and the accountant is the only person in the client’s professional life who knows it happened. Whether the client also needs to hold back the £18,000 rather than spend it is a separate and equally practical point, and it is one that a great many people who have never had a large gain before will get wrong. The mechanics of when a gain reaches an accountant and how little room is left by then are set out in more detail in the CGT signal.
Two things worth doing this week
Run a query for the crypto box. Most practice software can identify which returns filed for 2024 to 2025 and 2025 to 2026 included cryptoasset disposals. That query produces a list, and the list is useful twice over: it tells the firm whether it has three such clients or thirty, and it identifies the specific people for whom the arrival of exchange data in 2027 is a live issue rather than a general one. Anyone with cryptoassets who has gains to declare for 2025 to 2026 above the annual exempt amount needs them on a Self Assessment return by 31 January 2027, so the list is also a deadline list.
Ask the disposal question in the next meeting, not the next return. The single most common error in this area is the client who has swapped one token for another and does not believe anything has happened, because no money moved. HMRC is unambiguous that disposals include exchanging cryptoassets for a different type of cryptoasset. Asking about swaps, staking, mining and tokens received through employment or self-employment — all of which HMRC identifies as potentially taxable — costs a minute and routinely surfaces activity the client never thought to mention.
Where the planning conversation belongs
A large realised gain is a moment when two professions are looking at the same event for completely different reasons, which is the general case for why joined-up work between accountants and financial planners produces better outcomes than either doing its own half in isolation.
The accountant’s questions are backward-looking and precise: what was acquired, when, at what cost, what was disposed of, what is the gain, what is owed and by when. The planner’s questions run in the other direction: what are the proceeds for, what does this do to the client’s overall asset allocation, is the remaining holding still an appropriate size relative to everything else they own, has anything about the estate position changed, and is any of it protected. Neither set of questions answers the other. An introduction, made properly, is simply the mechanism by which the second set gets asked at all — and what that handover actually involves is described in the anatomy of an introduction.
None of that requires an accountant to express a view on cryptoassets, on what a client should hold, or on what they should do with the money. Naming a signal is not advice. It is the observation that something has changed in a client’s finances and that the change is the kind other people are qualified to look at. The gap between how few people receive advice and how many of those who do find it worthwhile — the lang cat put the second figure at 91% — is set out at more length on the advice gap.
What is not yet settled
Three things about this remain genuinely open, and it is worth being honest about which is which.
The first is the precise start of CARF reporting. HMRC’s own release says it will receive data from 2027 without naming a date; the 31 May 2027 date comes from UHY Hacker Young via Accountancy Age on 27 August 2026. Those are consistent, but only one of them is the tax authority speaking, and a practice planning client conversations should treat the year as firm and the day as reported rather than confirmed.
The second is scope. The 52 jurisdictions listed for 2027 and the 15 for 2028 are attributed to the same secondary source. A client holding assets on an exchange outside both groups is in a different position from one holding on a Jersey or Irish platform, and that is a question a practice should ask rather than assume.
The third is the rate environment. The CGT rates used above are those published on GOV.UK for gains made from 6 April 2026. Capital gains rates have moved twice in recent years, and any Budget can move them again; the arithmetic in this piece is correct for the current year and should be re-run against the rates in force whenever a disposal is actually made.
What is not uncertain is the direction. HMRC has built a box on the return, published the first statistics from it, sent 81,000 letters in a year and signed the UK up to an international data-sharing framework. The population producing those gains is largely unadvised. Both of those facts are now documented, and the point where they meet is a Self Assessment return sitting on an accountant’s desk. Where that concentration of wealth in one asset sits in a wider picture is the same question raised by the concentration signal.
Common questions
Does a crypto disposal go on the tax return even if the client never converted to pounds?
Yes. HMRC states in its 27 August 2026 release that Capital Gains Tax may apply when an individual disposes of cryptoassets, and that disposals include selling them or exchanging them for a different type of cryptoasset. Swapping one token for another is therefore a disposal with a sterling gain or loss attached to it, whether or not any money reached a bank account. That is the single most common misunderstanding a practice will meet, because the client sees one holding turning into another rather than a sale. HMRC also notes that Income Tax and National Insurance may apply to cryptoassets received through employment, self-employment, mining, staking or lending.
What changes in 2027 when HMRC starts receiving data from crypto exchanges?
The declaration stops being the only source. From January 2026 the UK began implementing the OECD Cryptoasset Reporting Framework, and HMRC states it will start receiving data from cryptoasset service providers in 2027, with providers who fail to comply facing penalties of up to 300 pounds per user. Accountancy Age, reporting figures from UHY Hacker Young on 27 August 2026, puts the first automatic feeds at 31 May 2027 covering 52 jurisdictions, with a further 15 following in 2028. Until then HMRC relies on voluntary disclosure and targeted requests. After it, an undeclared gain is a discrepancy in a dataset rather than an omission nobody can see.
What should a practice do about crypto gains that were never declared in earlier years?
Raise it now rather than after the data arrives. HMRC operates a Crypto Disclosure Service on GOV.UK specifically for people with undeclared cryptoasset income or gains, and the whole point of a disclosure route is that it is better used before the authority already knows. HMRC also confirms it has been running education and compliance activity on this since late 2023, which it estimates produced an additional 168 million pounds of Capital Gains Tax in 2024 to 2025. A practice cannot make the disclosure decision for a client, but it can make sure the client understands that the position changes in 2027 and that the window is finite.
Why does a crypto gain count as a financial planning signal and not just a tax computation?
Because of what it says about the shape of the client’s wealth rather than the size of the tax. A realised gain averaging 78,000 pounds across 17,600 people, and exceeding a million pounds for 240 of them, describes concentrated holdings in a single volatile asset class, usually held outside a pension or ISA and rarely reflected in a will or a protection arrangement. Those are the conditions a financial planner is trained to look at. The accountant is very often the only regulated professional who sees the number at all, which makes the return the point at which the question either gets asked or does not.
Is it within the remit of an accountant to raise planning off the back of a crypto disposal?
Noticing a signal and naming it is not regulated advice. Telling a client that a large realised gain sitting in cash is worth a conversation with a financial planner, and that the accountant knows someone who does that work, is an introduction rather than a recommendation of any product or investment. The regulated advice, its suitability and the responsibility for it sit with the authorised firm. What keeps the boundary clean is the language used in the meeting, a written record of what the client agreed could be passed on, and no view expressed on what the client should hold or buy.