In force · Effective · Applies to Banks, Fund managers
The Central Board of Direct Taxes amended rules 114F, 114G and 114H of the Income-tax Rules, 1962 by Notification No. 19/2026 (G.S.R. 158(E)) dated 5 March 2026, in force from 1 January 2026. For accounts other than US reportable accounts, financial assets now include interests in relevant crypto-assets, and depository accounts now include accounts holding central bank digital currency or specified electronic money products. The amendments also add reporting fields and let financial institutions skip reporting gross proceeds from crypto-asset sales already reported under the Crypto-Asset Reporting Framework.
Why it matters: India has written the OECD's crypto definitions into its tax reporting rules ahead of Hong Kong and Singapore, so banks and funds holding crypto or e-rupee for foreign tax residents report them first. R.M.
The amendments implement the OECD’s 2023 changes to the Common Reporting Standard (CRS) in rules 114F to 114H, which govern how Indian financial institutions identify and report accounts held by foreign tax residents. The notification, now titled the Income-tax (First Amendment) Rules, 2026 after a corrigendum (G.S.R. 189(E), 16 March 2026), comes into force on 1 January 2026 (rule 1(2)). Each change applies only to accounts other than US reportable accounts. The amended rule 114F is on the Income Tax Department’s site.
Crypto-assets as financial assets. “Financial asset” includes any interest, including a futures, forward or option, in a “relevant crypto-asset” (rule 114F(2), new proviso).
Digital money as deposits. A “depository account” includes accounts holding specified electronic money products or central bank digital currencies (CBDCs) for a customer (rule 114F(1)(a), new proviso). Small e-money accounts whose rolling 90-day average balance stays at or below USD 10,000 are excluded.
Definitions. New clauses define CBDCs, specified electronic money products (a digital representation of a single fiat currency, redeemable at par: rule 114F(9A)) and relevant crypto-assets (rule 114F(5A)).
Reporting. Rule 114G adds fields such as whether a valid self-certification was obtained and the account type. Gross proceeds from crypto-asset sales need not be reported under CRS if they are reported under CARF.
Implications
The rules were notified in March but apply from 1 January 2026, so institutions must cover the whole 2026 reporting year. Banks are affected first. Any bank holding e-rupee or e-money balances for customers who are tax residents elsewhere must now treat those balances as reportable deposit accounts. Funds and custodians that hold crypto-assets or crypto derivatives for foreign-resident investors must include them in CRS returns.
Indian crypto exchanges are covered only if they count as “financial institutions” under rule 114F(3), for example as custodial institutions. The amendments don’t change that definition, so it’s not clear how many exchanges fall within it.
The drafting of rule 114F(5A) is loose. It defines a relevant crypto-asset as one that is not a CBDC “or” not a specified electronic money product “or” one that cannot be used for payment or investment. The OECD text uses a single exclusion list. Read literally, the Indian clause excludes almost nothing. The intent is clearly the OECD meaning, but a corrigendum would remove the doubt.
Elsewhere in Asia
Hong Kong and Singapore are implementing CARF and the amended CRS together, from 2027. India has amended its CRS rules first. CARF-style reporting by crypto service providers runs separately, through section 509 and rules 241 to 244 of the Income-tax Rules, 2026.
What to watch
Whether these provisions carry over unchanged into the Income-tax Rules, 2026, which replaced the 1962 Rules on 1 April 2026. Also the notification of partner jurisdictions with which India will exchange the data.