CARF + HMRC: The Quiet Executive Hiring Boom in Tax, Reporting and Controls

5 January 2026

If you are running finance, tax, reporting or controls inside a crypto business, you already understand the “why” behind tax transparency.
What is new, and genuinely newsworthy, is that the UK’s CARF implementation is now concrete enough that boards are approving leadership hires against it.

HMRC’s position is explicit: if you provide cryptoasset services in the UK, you must collect user data and report it to HMRC under the Cryptoasset Reporting Framework (CARF).
That sounds like a reporting obligation. In practice, it is a platform-operating-model upgrade that cuts across onboarding, entity classification, data lineage, finance operations and governance.

So the story here is not “what to do”, it is “what is already happening”.
CARF is quietly reshaping senior hiring because it forces a simple executive reality:
your reporting output is only as defensible as your data capture, controls, and ownership model.

1) The real shift: CARF turns “reporting” into a data and controls product

For years, many crypto businesses have treated reporting as downstream: reconcile at year-end, then file.
CARF pushes the centre of gravity upstream.
It makes onboarding data, tax residence evidence, entity and controlling person logic, and transaction categorisation part of your “reporting surface area”.

HMRC’s own framing is telling. It does not describe CARF as a discretionary best practice.
It sets out what you need to report, when you need to report, how you need to report, and what penalties can apply.
That is why CFOs and controllers are now pulling CARF into the same conversation as auditability, operational resilience, and platform governance.

In other words, CARF is not “tax versus product”.
It is tax becoming a set of operational and data guarantees the platform must be able to evidence repeatedly.

2) What we are seeing in the market: the executive roles being prioritised

The hiring story is not that everyone is building large teams.
It is that leadership teams are making a small number of high-leverage senior hires that sit at the junction of tax, reporting, data and controls.
Below are the archetypes we see most often when CARF enters board-level headcount planning.

The accountable owner for tax transparency reporting

The first hire is usually not “a CARF project manager”.
It is a senior owner with enough authority to align product, compliance, ops, finance and data, and to take accountability for reporting quality and governance.
HMRC’s penalties language, and the explicit reporting obligations, are the reason this is moving into accountable ownership rather than a committee model.

Common titles:

• Head of Regulatory Reporting (Digital Assets)
• Director of Tax Transparency or Tax Reporting
• Head of Reporting and Controls

What tends to distinguish the strongest profiles:

• They have run annual reporting cycles where evidence quality mattered, not only the numbers.
• They can operate comfortably across policy, ops design and data governance.
• They can engage advisers without outsourcing accountability.

Reporting data leadership

The second hire is the quiet bottleneck: senior reporting data leadership.
HMRC points to specific reporting mechanics and references an XML schema and transmission approach aligned to OECD materials.
That is a clue. This is closer to regulatory reporting engineering than it is to finance BI.

Common titles:

• Head of Reporting Data or Regulatory Data Lead
• Reporting Analytics Engineering Lead
• Data Governance Lead (Tax and Regulatory Reporting)

Why this keeps getting funded:

• Because “data lineage as evidence” is now a deliverable, not an aspiration.
• Because exception handling and reconciliation become permanent workflows if they are not engineered properly.
• Because the cost of manual reporting factories is compounding, both financially and operationally.

Controls, governance and assurance leadership

A third cluster is controls and governance leadership, often sitting with finance controls, risk, or GRC.
This is driven by the nature of the obligation and the penalty regime, including a focus on valid self-certifications in the UK rules.

Common titles:

• Head of Controls (Digital Assets)
• Risk and Controls Lead, Reporting
• GRC Lead (Data Controls and Reporting Assurance)

What “good” looks like in practice:

• Controls that are testable and scalable, not policy documents.
• Clear sign-off governance, including who attests to what and on what evidence.
• Quality assurance designed into the reporting lifecycle, not bolted on at deadline time.

 Finance operations and client operations leaders

In many businesses, CARF exposure concentrates in the messy middle: onboarding exceptions, documentation remediation, entity classification edge cases, and customer comms.
That work sits somewhere between finance ops, compliance ops and client operations.
So we are increasingly seeing senior ops hires tasked with making this repeatable and auditable.

Common titles:

• Director of Finance Operations (Reporting and Controls)
• Head of Client Operations (Documentation and Evidence)
• Reporting Operations Lead

This is the category that tends to surprise leadership teams, because it is not “tax”, but it dictates whether tax and reporting can be executed cleanly at scale.

3) The skill mix that keeps making it onto shortlists

CARF-related senior hiring is not about finding someone who can recite CARF.
It is about finding leadership that can make a reporting lifecycle durable inside a fast-moving product environment.
Four traits show up repeatedly in candidates who make it to final rounds.

1. Evidence-first thinking.
   They treat tax residence, entity status and transaction categorisation as evidence workflows, with traceability, not as a once-a-year exercise.
2. Data literacy that is operational, not performative.
   They can speak credibly about data ownership, lineage, reconciliation, exceptions and quality gates, without turning the business into a reporting consultancy.
3. Controls pragmatism.
   They know how to build controls that pass scrutiny while protecting velocity.
4. Cross-functional authority.
   They have the judgement and seniority to align product, compliance, finance and ops without endless negotiation cycles.

4) Why 2026 is the “signal year” for senior hiring

Even for teams that are comfortable with reporting cycles, the interesting part of CARF is the global direction of travel.
OECD has published the transmission format and guidance, and anticipates first exchanges commencing in 2027.
That reality changes the internal conversation.
Reporting becomes less about “UK filing” and more about building a standard that can survive external exchange, scrutiny and comparisons.

That is why the hiring pattern is so consistent: the teams leaning into CARF are not necessarily those adding the most headcount, they are those upgrading leadership ownership, data, and controls early enough that reporting becomes routine rather than disruptive.

How RecruitBlock supports senior CARF-related hiring

RecruitBlock supports crypto and digital assets firms hiring senior non-technical leadership across finance, tax, compliance, risk, controls, operations and institutional digital assets.
If CARF is changing your 2026 leadership priorities, these are the most relevant entry points:

• Institutional Crypto Leadership
• Hire Crypto Finance and Accounting Leaders
• Crypto Legal and Compliance Recruitment
• London Crypto and Web3 Recruitment and European Crypto Recruitment

Sources

1. HMRC, Reporting cryptoasset user and transaction data (last updated 1 January 2026).
2. HMRC, Collecting cryptoasset user and transaction data (last updated 1 January 2026).
3. UK legislation and explanatory material: The Reporting Cryptoasset Service Providers (Due Diligence and Reporting) Regulations 2025 and Explanatory Memorandum.
4. OECD transmission format and guidance: OECD announcement (2 October 2024).

Note: This article is for general information only and is not tax or legal advice. Requirements vary by business model and entity structure.