The 2025 tax year is the first with Form 1099-DA in circulation, and it has produced a specific kind of confusion among ETH stakers: people waiting for a form that is never going to arrive, and concluding from its absence that there's nothing to report.

Both halves of that are wrong in instructive ways.

What the form is

Form 1099-DA is the digital-asset version of the information reporting brokers have long done for securities under IRC §6045. Under final regulations issued June 28, 2024 (T.D. 10021), brokers must report customers' digital-asset dispositions to the IRS and the customer, starting with the 2025 tax year — so the first forms landed in early 2026.

The regulation's operative word is broker: a custodial platform that holds customer assets and effects their transactions. A custodial exchange that stakes on your behalf and credits your account is squarely inside that definition.

Who is excluded — deliberately

The final regulations explicitly leave non-custodial infrastructure outside the broker definition. A solo validator, or a staker whose provider operates the node while the withdrawal credentials stay with the staker, has no broker in the chain: nobody else holds the keys, nobody else effects the settlement. Nobody owes you a 1099-DA, and none will come.

This isn't an oversight being papered over in a future revision — it follows from what the form is. Information reporting exists so a third party who already sees your transactions can corroborate them to the IRS. In self-custodied staking, no such third party exists. The corroborating record is the chain itself.

What the form's absence doesn't change

The obligation to recognize staking income — at fair market value, when you gain dominion and control, consistent with Rev. Rul. 2023-14 — predates Form 1099-DA and does not depend on receiving one. Information reporting affects what the IRS already knows, not what you owe. A solo staker's income is self-reported: you carry the substantiation burden a broker would otherwise share.

That sentence is the practical heart of this article. Self-reported income with no third-party corroboration is precisely the profile where an examiner asks for records — addresses, transaction-level history, valuation sources. If your staking record is a dashboard screenshot and a CSV of unverified estimates, that request goes badly.

If you do receive one

Stakers using custodial exchanges may receive a 1099-DA that includes staking credits. Two things worth knowing:

• The form reflects the broker's view of activity it processed — its timing, its valuations. Broker records and the on-chain record can diverge, and provider transitions (migrations, mergers, validator-set handoffs) are a known source of amendment scenarios.
• If you believe a form is wrong, correcting the record requires an independent basis — your own transaction-level history against the chain. Accepting or disputing a broker's number are both record-keeping problems.

How any specific discrepancy should be handled on a return is a question for your tax professional.

What to keep instead

For a self-custodied validator, the defensible substitute for the form nobody will send you is your own audit-quality record: every settlement event, its on-chain reference, the price that valued it and where that price came from, reconciled against the chain rather than derived and hoped. That's the record TrueStake produces — the Tax Report is built row-for-row to be the thing you produce when asked to substantiate self-reported staking income.

The 1099-DA era doesn't put self-custodied stakers at a disadvantage. It puts unrecorded ones at a disadvantage.