Record-keeping for crypto-asset payments: a combined checklist
Status as of October 30, 2026. Two sets of rules shape the records a Canadian business keeps for crypto-asset payments: CRA income tax and GST/HST expectations, which apply to any business that accepts crypto-assets, and FINTRAC requirements, which apply if your business is a reporting entity such as a money services business (MSB). This checklist brings them together. It is general information, not legal or tax advice; confirm your obligations with the CRA, FINTRAC, a CPA or a lawyer.
Key points
- The CRA expects the date, time, CAD value, wallet addresses and how you determined fair market value (FMV) for crypto-assets you receive.
- Where FINTRAC rules apply to you, records must generally be kept for at least five years.
- MSB virtual currency transfers of $1,000 or more carry a longer list of required details.
- One well-designed per-payment record can serve both tax and FINTRAC purposes.
Which rules apply to you
If FINTRAC's exclusion for businesses that solely accept payment for their own goods or services applies to you, the CRA rows are your baseline. If you are unsure, see FINTRAC MSB registration.
| Rule set | Applies to | Record highlights |
|---|---|---|
| CRA income tax | Any business that accepts crypto-assets for goods or services | Date, time, CAD value at the time of the transaction, wallet addresses, how FMV was determined |
| CRA GST/HST | GST/HST registrants making taxable supplies | Tax calculated on the FMV of the crypto-asset at the time of the transaction |
| FINTRAC, general | Reporting entities, such as MSBs | Records generally kept for at least five years |
| FINTRAC, MSB transfers of $1,000 or more | MSBs handling virtual currency transfers | Date, amount and type of virtual currency, client details, beneficiary name and address, sending and receiving addresses, transaction hash, exchange rates; identity verification |
| FINTRAC, large receipts | Reporting entities receiving $10,000 or more, single or linked within 24 hours | A report within five working days |
The CRA sets its own rules on how long to keep business records; check its current guidance. Where FINTRAC rules apply, records must generally be kept for at least five years.
Per-payment fields
These fields cover the CRA's expectations and overlap with FINTRAC's MSB transfer records. Capture them when the payment arrives, not at year end.
Refunds deserve their own entries. A crypto-asset refund is generally a new outgoing transfer rather than a reversal, so record it with its own date, time, CAD value, rate source, addresses and transaction hash, and link it to the original invoice.
The crypto receipt record tool lays these out for a single payment, and the invoice builder sandbox shows how an invoice can carry the same ID, using no real funds.
| Field | Why it is there |
|---|---|
| Date and time, with time zone | The CRA asks for date and time, and FMV is measured at the time of the transaction |
| Invoice or order ID | Ties the payment to the sale and to the GST/HST charged |
| CAD price and taxes charged | Supports income and GST/HST reporting |
| Crypto-asset type and amount received | FINTRAC MSB transfer records include the amount and type of virtual currency |
| CAD fair market value at receipt | The CRA uses FMV in Canadian dollars at the time of the transaction |
| Rate source and rate used | The CRA asks how FMV was determined; FINTRAC MSB records include exchange rates |
| Transaction hash | Links the record to the blockchain; part of FINTRAC MSB transfer records |
| Sending and receiving addresses | The CRA lists wallet addresses; FINTRAC MSB records include both |
| Network fee paid, if any | Explains differences between what was invoiced and what arrived |
| Conversion details, when they happen | Date, CAD proceeds and fees when you later convert or dispose |
Extra fields if you are an MSB
These come from FINTRAC's requirements for MSB virtual currency transfers of $1,000 or more and from the travel rule, in effect since June 1, 2021. FINTRAC's MSB record-keeping guidance is the authority on the full list; treat this as a starting point.
- client details for the person or business you act for
- the beneficiary's name and address
- identity verification records for transfers of $1,000 or more
- travel rule information: originator and beneficiary name, address and account or reference number, sent or received with the transfer
- any large virtual currency transaction reports filed, with the receipts they cover
Monthly tasks
A monthly routine keeps small gaps from becoming year-end projects. Reconciling on-chain payments walks through the matching step in more detail.
- Export wallet or provider activity for the month.
- Match each incoming payment to an invoice ID, and flag anything unmatched.
- Confirm that each record has a time, a CAD FMV and the rate source.
- Record any conversions to Canadian dollars, with proceeds and fees.
- If you are a reporting entity, review linked receipts against the LVCTR 24-hour rule.
- Back up the month's records and rate evidence in a second location.
Annual tasks
Once a year, step back from individual payments and check that the totals, the treatment and the retention plan still hold together. Bring your CPA in at this stage.
- Total crypto-asset income at CAD FMV for the year and reconcile it to sales.
- Summarize the GST/HST charged on sales paid in crypto-assets.
- List disposals and conversions, and review with a CPA whether gains or losses are business income or capital, using Guides T4002 and T4037.
- Note any crypto-assets still held at year end and where they are held.
- Review retention: keep FINTRAC records for at least five years where they apply, and follow CRA guidance for tax records.
- Re-read current CRA and FINTRAC guidance, since rules and rates change.
Common gaps
These gaps come up when records are assembled after the fact rather than at the time of payment.
If you would like a second look at how your records fit your situation, the free scenario review offers an educational read of your scenario; it is not an audit or advice.
- Records with a date but no time.
- A CAD value with no note of where the rate came from.
- Payments that cannot be tied to an invoice.
- Missing wallet addresses or transaction hashes, so a payment cannot be traced on the blockchain.
- Conversions recorded without their fees.
FMV has to reflect the time of the transaction. Reconstructing values months later can make it hard to show how you determined FMV for each payment. Capture it when the payment arrives.
Questions people ask
How long should I keep crypto payment records?
Where FINTRAC rules apply, records must generally be kept for at least five years. For tax records, check the CRA's current guidance on retention.
Is a link to the transaction on a blockchain explorer enough?
It shows the transaction, but not the CAD value at the time, the rate source or the invoice it relates to. Keep those in your own records.
Do I need FINTRAC records if I am not an MSB?
FINTRAC record-keeping applies to reporting entities. A business outside FINTRAC's scope still keeps CRA records; if you are unsure of your status, ask FINTRAC.
Can one record serve both the CRA and FINTRAC?
Often, yes. The fields overlap: date and time, CAD value, rate source, addresses and transaction hash.
Sources
- CRA — Income from crypto-asset transactions
- CRA — Tax tip: reporting crypto-asset income as an individual carrying on a business (2024)
- FINTRAC — Record keeping requirements for MSBs
- FINTRAC — Large virtual currency transaction reports
Reviewed October 30, 2026. Educational information only; not financial, legal, tax or investment advice. This site does not process payments or hold funds.