Can You Use Average Cost Basis for Cryptocurrency IRS: Tax Treatment, Reporting, Regulation, and Records to Keep

If you have traded cryptocurrency, you have likely wondered about the easiest way to calculate your cost basis for tax purposes. The average cost method—commonly used for mutual funds—might seem appealing. However, the IRS has made significant changes to how digital asset cost basis must be tracked. This guide explains the current rules, what methods are permitted, and what records you need to keep to stay compliant.

📌 The Short Answer: Is Average Cost Allowed?

No. The IRS does not permit the use of the average cost basis method for cryptocurrency or other digital assets.[reference:0] Unlike mutual funds, where you can elect to use an average basis[reference:1], digital assets are treated as property, and the cost basis must be determined using either the specific identification method or the first-in, first-out (FIFO) method.[reference:2]

Furthermore, beginning January 1, 2025, the IRS requires taxpayers to track cost basis on a per-wallet or per-account basis, effectively eliminating the "universal" or pooled cost basis method that some taxpayers previously used.[reference:3][reference:4] This means you cannot simply average the cost of all your holdings across different wallets and exchanges.

⚠️ Important: The average cost method is not permitted for cryptocurrency. Using it on your tax return could result in an incorrect calculation of your capital gains or losses and may trigger an IRS audit or penalties.

💰 What Is Cost Basis and Why Does It Matter?

Your cost basis is the amount you paid to acquire a digital asset, including fees, commissions, and other acquisition costs.[reference:5] When you sell or dispose of the asset, your gain or loss is calculated as the difference between the sale proceeds and your cost basis.[reference:6]

Accurate cost basis tracking is essential because it directly affects the amount of tax you owe. A higher basis means a lower taxable gain (or a larger deductible loss). The IRS treats digital assets as property, so the same general tax principles that apply to stocks and real estate also apply to cryptocurrency transactions.[reference:7]

Your basis also determines your holding period, which affects whether your gain is taxed as short-term (held one year or less) or long-term (held more than one year).[reference:8] Short-term gains are taxed at ordinary income rates, while long-term gains benefit from preferential capital gains rates.

📂 The 2025 Per-Wallet Tracking Mandate

Effective January 1, 2025, the IRS requires taxpayers to track digital assets on a per-wallet or per-account basis.[reference:9][reference:10] This means you must calculate cost basis separately for each wallet, exchange account, or other location where you hold digital assets.[reference:11]

What Was the "Universal" Method?

Previously, some taxpayers used a "universal" or pooled method, where they treated all holdings across multiple wallets, exchanges, and cold storage as one big pool and could choose which basis to apply to a sale.[reference:12] This allowed cherry-picking the most favorable basis from any account. The IRS has now eliminated this practice.[reference:13]

The Safe Harbor Opportunity

To help taxpayers transition, the IRS issued Revenue Procedure 2024-28, which provides a one-time safe harbor to allocate unused basis among wallets and accounts as of January 1, 2025.[reference:14][reference:15] Under this safe harbor, taxpayers could reallocate basis using any reasonable method, as long as they kept detailed records of the allocation.[reference:16]

If you did not take advantage of this safe harbor by January 1, 2025, you are now "locked in" to whatever basis allocations existed at that time and cannot retroactively reallocate basis between wallets.[reference:17]

💡 Key insight: The per-wallet mandate means you must maintain separate records for each wallet or account. If you sell crypto from a specific wallet, you must use the basis of the assets held in that same wallet—not from another wallet where you might have a more favorable basis.[reference:18]

📋 Permitted Cost Basis Methods: FIFO and Specific Identification

Under current IRS guidance, taxpayers may use one of two methods to determine which units of digital assets are deemed sold or disposed of:

First-In, First-Out (FIFO)

FIFO is the default method used by the IRS if you do not specifically identify which units you are selling.[reference:19][reference:20] Under FIFO, the earliest acquired units are deemed sold first. This method is straightforward and often results in higher taxable gains in a rising market because older units typically have lower cost bases.

Specific Identification (Specific ID)

With Specific ID, you can choose which specific units you are selling, as long as you can identify them and substantiate their basis.[reference:21] To use this method, you must document the specific unit's unique identifier or maintain records showing the date and time each unit was acquired, its basis, and its fair market value at acquisition.[reference:22]

Specific ID offers more flexibility and can be more tax-efficient, as you can choose to sell units with the highest basis to minimize gains (or maximize losses). However, it requires meticulous recordkeeping.

What About HIFO and LIFO?

Some taxpayers have used HIFO (highest in, first out) or LIFO (last in, first out) methods. However, the IRS has not explicitly approved these as standalone methods for cryptocurrency.[reference:23] While some tax software supports them, you should proceed with caution and consult a tax professional before using HIFO or LIFO.[reference:24]

⚠️ Important: Whichever method you choose, you must apply it consistently on a per-wallet basis. You cannot use FIFO for one wallet and Specific ID for another without clear documentation.[reference:25]

📄 Form 1099-DA: What Brokers Report

Beginning in 2025, brokers are required to report digital asset transactions on the new Form 1099-DA, Digital Asset Proceeds From Broker Transactions.[reference:26][reference:27]

What Is Reported for 2025?

For the 2025 tax year, brokers must report gross proceeds from digital asset sales.[reference:28][reference:29] However, they are not required to report cost basis for 2025 transactions.[reference:30][reference:31] This means you will need to calculate your own cost basis using your records when preparing your tax return.[reference:32]

What Changes in 2026?

Starting in 2026, brokers must report both gross proceeds and cost basis for digital assets acquired on or after January 1, 2026, and held on the same platform through the date of sale.[reference:33][reference:34][reference:35] This will make reporting easier for some taxpayers but also increases the importance of accurate recordkeeping, as the IRS will receive matching data.[reference:36]

What You Must Do

Even if you do not receive a Form 1099-DA, you are still required to report all income, gains, and losses from digital asset transactions.[reference:37] You must also answer the digital asset question on your tax return, indicating whether you engaged in any digital asset transactions during the year.[reference:38]

📁 Records You Must Keep

Accurate recordkeeping is the foundation of proper tax reporting. The IRS requires you to maintain records that substantiate your cost basis and holding period for every digital asset transaction.[reference:39]

What to Record for Each Transaction

Special Considerations for Per-Wallet Tracking

How Long to Keep Records

You should keep your records for at least three years from the date you filed your tax return, or longer if you have carryover losses or other complex situations. In practice, many tax professionals recommend keeping records for at least seven years to be safe.

📌 Best practice: Use crypto tax software to automatically track your transactions and generate reports. However, always verify that the software is applying the correct per-wallet rules and that you have all the necessary data imported.

⚖️ Comparison: Cost Basis Methods

The table below compares the key cost basis methods for cryptocurrency, including whether they are permitted by the IRS.

Method How It Works IRS Permitted? Complexity Best For
FIFO Earliest acquired units sold first ✅ Yes (default) Low Simplicity, long-term holders
Specific Identification Choose specific units to sell ✅ Yes (with documentation) High Tax optimization, active traders
HIFO Highest cost units sold first ⚠️ Not explicitly approved High Minimizing gains
LIFO Most recently acquired units sold first ⚠️ Not explicitly approved High Tax optimization in some scenarios
Average Cost Average of all acquisition costs ❌ Not permitted Low N/A — not allowed

📌 This table is a general guide. Always consult a tax professional for your specific situation. IRS rules and interpretations may change.

📘 Scenario: Calculating Gain Under Per-Wallet Rules

Alex has two wallets: Wallet A (an exchange account) and Wallet B (a hardware wallet). Alex bought 1 BTC in Wallet A for $20,000 and later bought another 1 BTC in Wallet A for $30,000. In Wallet B, Alex bought 1 BTC for $25,000.

In 2025, Alex sells 1 BTC from Wallet A for $40,000. Under the per-wallet rules, Alex must use the basis from Wallet A only. Alex cannot use the $25,000 basis from Wallet B to reduce the gain.

Alex can choose either FIFO or Specific ID for Wallet A:

Alex chooses Specific ID to minimize the taxable gain but must keep records to substantiate the identification.

📌 The takeaway: Under the per-wallet rules, you cannot mix and match basis across wallets. Your choice of cost basis method (FIFO vs. Specific ID) must be applied separately to each wallet.

Practical Checklist for Crypto Tax Compliance

  • Inventory all wallets and accounts: Identify every exchange account, software wallet, and hardware wallet where you hold or have held digital assets.
  • Reconstruct transaction history: For each wallet, gather records of all acquisitions, dispositions, and transfers.
  • Allocate basis per wallet: Ensure that cost basis is tracked separately for each wallet, using FIFO or Specific ID.
  • Review safe harbor allocation: If you used Revenue Procedure 2024-28, keep a detailed lot allocation report.
  • Calculate gains and losses: For each taxable event (sale, exchange, or disposition), calculate gain or loss using the correct basis from the relevant wallet.
  • Prepare Form 8949: Report all capital gains and losses from digital asset transactions on Form 8949.[reference:50]
  • Answer the digital asset question: On your tax return, indicate whether you engaged in any digital asset transactions.[reference:51]
  • Keep records for at least 3 years: Retain all documentation in case of an IRS audit.

🚫 Common Mistakes

⚠️ Important: If the IRS disallows your basis because you cannot substantiate it, you could face accuracy-related penalties of 20% or more, plus interest.[reference:59]

Risk Warning

⚠️ Tax compliance for cryptocurrency is complex and carries significant risk. This guide is for educational purposes only and does not constitute legal, financial, or tax advice. The IRS rules are subject to change, and individual circumstances vary widely.

  • Penalty risk: Failure to report digital asset transactions or using incorrect cost basis can result in accuracy-related penalties (20% or more), civil fraud penalties (up to 75%), and potential criminal exposure in fraud cases.[reference:60]
  • Audit risk: The IRS is increasing enforcement of digital asset reporting. Inaccurate returns may trigger an audit.
  • Recordkeeping risk: If you cannot substantiate your cost basis with adequate records, the IRS may treat the sale as having zero basis, making the entire proceeds taxable.[reference:61]
  • Regulatory risk: Tax laws and IRS guidance for digital assets are evolving. What is true today may change in future years.
  • User risk: Mistakes in calculating basis or selecting the wrong method can lead to underpayment or overpayment of taxes.

Always consult a qualified tax professional for guidance on your specific situation. Keep meticulous records and stay informed about changes to IRS rules and regulations.

📌 Verification reminder: IRS forms, deadlines, and reporting requirements change frequently. Always verify current information directly from the IRS website or consult a tax professional.

Frequently Asked Questions

Can I use the average cost method for cryptocurrency on my IRS return?

No. The average cost method is not permitted for cryptocurrency. You must use either FIFO (first-in, first-out) or Specific Identification.[reference:62]

What is the per-wallet cost basis rule?

Beginning January 1, 2025, the IRS requires taxpayers to track cost basis on a per-wallet or per-account basis.[reference:63] This means you cannot pool basis across different wallets or accounts.

What is the safe harbor in Revenue Procedure 2024-28?

It is a one-time opportunity to allocate unused basis among your wallets and accounts as of January 1, 2025.[reference:64] You must keep a detailed record of how you allocated the basis.[reference:65]

What does Form 1099-DA report?

For 2025, Form 1099-DA reports gross proceeds from digital asset sales. Brokers are not required to report cost basis for 2025 transactions.[reference:66][reference:67] Starting in 2026, cost basis will also be reported for covered assets.[reference:68]

What records do I need to keep for crypto taxes?

You must keep records of the date, amount, fair market value, and wallet location for every acquisition and disposition of digital assets.[reference:69][reference:70]

Can I use HIFO or LIFO for cryptocurrency?

The IRS has not explicitly approved HIFO or LIFO as standalone methods for cryptocurrency.[reference:71] While some tax software supports them, you should consult a tax professional before using them.

What happens if I don't have records of my cost basis?

If you cannot substantiate your cost basis, the IRS may treat the sale as having zero basis, meaning the entire proceeds become taxable gain.[reference:72] You could also face accuracy-related penalties.[reference:73]

Do I need to report crypto transactions if I didn't receive a Form 1099-DA?

Yes. Every taxpayer must report all income, gains, and losses from digital asset transactions, regardless of whether they receive a Form 1099-DA.[reference:74]