Crypto Exchanges Impose Deadlines: Tax Consequences of Missed Holdings

Several major crypto exchanges are imposing deadlines for their users to either sell or withdraw their holdings. The deadline overview from August 16, 2026, lists seven such cut-off dates before August 31 alone. For example, Luno is closing its EU accounts on September 1, and the last day for sales and euro payouts is August 31.

The question of what happens to these holdings for tax purposes if a user misses the deadline has sparked confusion. The short answer is that it's still considered a disposal, but the longer answer lies in two public documents from the German Federal Ministry of Finance (BMF). These documents explain which day counts and how to calculate the rate applied.

The BMF circular defines 'disposal' as the transfer of an acquired asset to third parties for consideration. This means that a forced liquidation or conversion falls under the same provision as a sale triggered by the user themselves. The one-year holding period is still applicable, and the timestamp recorded by the trading platform decides when it's triggered.

In the case of a forced realisation, the exchange sets the pace, and users must rely on the moments recorded there to determine whether the one-year period has been breached. This means that voluntariness doesn't come into play, and the user cannot move the day after the fact or change it through a later payout.