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Digital Assets in Estate Planning: Cryptocurrency, NFTs, and Advisor Guidance

· 19 min

Executive Summary

The convergence of legislative, tax, and regulatory change in 2025-2026 has transformed the treatment of digital assets in UK estate planning. The Property (Digital Assets etc) Act 2025 confirmed digital assets as a third category of personal property, resolving longstanding legal uncertainty.1 HMRC's Cryptoassets Manual confirms cryptoassets are property for inheritance tax purposes, and enforcement activity has intensified sharply, with IHT-specific nudge letters now targeting agents and personal representatives.2 The Crypto-Asset Reporting Framework became operational on 1 January 2026, and the FCA's comprehensive regulatory regime targets October 2027 implementation.3 For financial advisers, the residence-based IHT regime enacted from April 2025 has materially altered the situs analysis for internationally mobile clients holding crypto. This article provides an integrated legal, tax, and regulatory analysis with a practical operational framework for advisers seeking to incorporate digital asset considerations into estate planning workflows.

1. Introduction: Why Digital Assets Demand Advisory Attention Now

Twelve months ago, the legal status of cryptoassets as personal property remained a matter of academic debate. The advisory landscape has since undergone a structural transformation. The Property (Digital Assets etc) Act 2025 received Royal Assent on 2 December 2025, confirming digital assets as a third category of personal property under English law.1 HMRC has moved from general awareness to targeted enforcement, sending IHT-specific nudge letters to agents who have previously submitted IHT returns.4 The Crypto-Asset Reporting Framework (CARF) is now operational, and the FCA has published a comprehensive suite of consultation papers signalling full regulatory coverage of cryptoasset activities from October 2027.5

These developments are not isolated. They represent a coordinated shift across legal recognition, tax enforcement, and regulatory architecture that collectively demands an advisory response. FCA research indicates that 8% of UK adults hold cryptoassets, with a continuing trend toward larger individual holdings among remaining participants.6 A Professional Adviser survey found that 71.4% of advisers believed their peers were not sufficiently aware of client crypto use -- a finding that, while based on a limited sample, reflects a widely acknowledged advisory gap.7

For financial advisers engaged in estate planning, the question is no longer whether digital assets require attention, but how to integrate them systematically into existing advisory processes. This article examines the legal foundation, tax treatment, enforcement landscape, regulatory trajectory, and practical operational considerations that shape the adviser's role.

2.1 The Act's Pivotal Provision

The Property (Digital Assets etc) Act 2025 (c.29) provides that "a thing (including a thing that is digital or electronic in nature) is not prevented from being the object of personal property rights merely because it is neither (a) a thing in possession, nor (b) a thing in action."1 This single provision resolves the doctrinal difficulty that had constrained the treatment of cryptoassets and other digital assets within English property law.

The Act implements recommendations from the Law Commission's Final Report on Digital Assets (LC401, June 2023), which proposed limited statutory intervention to confirm the existence of a third category of personal property capable of accommodating crypto-tokens and other novel digital assets.8 A supplemental report and draft Bill followed in July 2024, and the Act received Royal Assent on 2 December 2025, coming into force on the same day.9

2.2 Estate Planning Implications

The Act's significance for estate planning is foundational. Digital assets can now be:

  • Bequeathed by will -- executors have a firm legal basis for collecting, valuing, and distributing digital assets as part of the personal estate.10
  • Settled into trusts -- crypto-tokens and NFTs can be the subject of express trusts, discretionary trusts, and other trust structures, subject to the standard IHT entry charge (20% above the nil-rate band on lifetime transfers) and periodic/exit charges.11
  • Subject to LPA authority -- property and financial affairs LPAs can extend to digital assets, provided the instrument's language is sufficiently broad to encompass them.10
  • Subject to equitable interests -- beneficial ownership claims, tracing remedies, and constructive trust arguments apply.

The Act deliberately does not enumerate which digital assets fall within the third category, leaving boundary development to the courts and the UK Jurisdiction Taskforce (UKJT).8 Practitioners should note that while legal certainty has arrived at the foundational level, specific questions regarding particular asset types may require judicial determination.

2.3 Practical Significance for Advisers

The transition from theoretical debate to statutory recognition means that advisers can no longer characterise digital assets as a niche or legally uncertain category. The advisory question has become operational: how should digital assets be identified, documented, valued, and integrated into estate planning structures? The following sections address the tax, enforcement, and regulatory dimensions that shape the answer.

3. HMRC Tax Treatment and Enforcement

3.1 Classification and IHT Treatment

HMRC's Cryptoassets Manual provides the primary guidance framework, classifying cryptoassets into four main types: exchange tokens (e.g., Bitcoin, Ethereum), utility tokens, security tokens, and stablecoins.12 NFTs are separately identifiable and not pooled for Capital Gains Tax purposes, though HMRC has not published NFT-specific IHT guidance.13 The absence of bespoke NFT guidance means that practitioners must apply general principles -- NFTs constitute property for IHT purposes and are valued at the date of death -- while recognising that the valuation methodology for unique, non-fungible digital assets presents challenges distinct from those of exchange tokens with readily observable market prices.

The core IHT position is unambiguous. HMRC CRYPTO25000 confirms that "cryptoassets will be property for the purposes of Inheritance Tax."2 This means cryptoassets form part of the deceased's estate at the date-of-death value, are subject to IHT at the applicable rate (currently 40% above the nil-rate band), and must be reported in IHT returns.

3.2 The Situs Question

For individuals who are not long-term UK residents (and, historically, non-UK domiciled individuals), the location -- situs -- of cryptoassets determines whether they fall within the UK IHT net. HMRC's position at CRYPTO22600 is that the location of exchange tokens follows the residence of the beneficial owner.14 Where no relevant Double Taxation Treaty applies, common law principles govern the analysis.

This situs position has significant implications. Unlike traditional financial assets held with regulated custodians in identifiable jurisdictions, cryptoassets exist on distributed ledgers without a single physical location. HMRC's approach of linking situs to the beneficial owner's residence effectively treats crypto as following the person rather than the platform, regardless of where the exchange or wallet infrastructure is based.

3.3 Valuation Challenges and the Phantom Tax Risk

Cryptoasset valuation for IHT purposes is based on the date-of-death value. Given the well-documented volatility of crypto markets, retrospective valuation evidence may be required, and obtaining reliable date-of-death valuations for less liquid tokens or NFTs can present significant practical difficulty. Where assets are held across multiple exchanges and wallets, the personal representative faces a consolidation exercise that has no direct parallel in traditional estate administration.

A distinctive risk arises where private keys or seed phrases are not communicated to personal representatives. Cryptoassets stored in self-custody wallets may become permanently irrecoverable at death, yet HMRC may still assess IHT on their date-of-death value. There are currently no specific IHT reliefs for post-death value decreases attributable to inaccessibility, creating what might be described as a "phantom tax" scenario -- liability on assets that can be valued but not realised.2 The practical consequence is potentially severe: an estate may face a six-figure IHT liability on cryptoassets that the personal representative cannot access, sell, or distribute. This risk underscores the importance of proactive documentation, addressed in Section 6.

3.4 HMRC Enforcement Intensification

HMRC's compliance activity has escalated materially. In tax year 2024/25, HMRC sent approximately 65,000 nudge letters to crypto holders, representing a 134% increase from fewer than 28,000 in the prior year, according to figures obtained through a Freedom of Information request by UHY Hacker Young.1516 More significantly for estate planning practitioners, HMRC began sending IHT-specific letters to agents and personal representatives in late 2025, directly targeting those who have previously submitted IHT returns.4

The ICAEW reported in December 2025 that "agents may be overlooking IHT on cryptoassets" and noted that HMRC is requesting agents liaise with personal representatives to amend any IHT returns containing errors, citing reference OTM000752.17 Professional Adviser subsequently reported in February 2026 that these IHT-focused letters target "specific, potential tax irregularities" and aim to prompt voluntary disclosure before formal inquiries.18

The enforcement trajectory is clear: HMRC expects cryptoassets to be identified, valued at the date of death, and declared in IHT returns. Advisers who do not raise digital assets in estate planning conversations risk facilitating incomplete IHT disclosures.

4. The Residence-Based IHT Regime and Crypto Situs

4.1 From Domicile to Residence

The residence-based IHT regime, enacted under the Finance Act 2025 and operational from 6 April 2025, replaced the domicile-based system with a long-term resident test.19 An individual who has been UK resident for at least 10 of the previous 20 tax years is classified as a "long-term UK resident" whose worldwide assets fall within the UK IHT estate. Tail provisions of 3 to 10 years (depending on the duration of prior residence) maintain IHT exposure after departure from the UK.

4.2 Material Impact on Crypto Holders

The intersection of the residence-based regime with HMRC's crypto situs position creates material consequences for internationally mobile clients. Consider a practical scenario: a non-UK domiciled individual who has been UK resident for 12 of the past 20 years holds Bitcoin worth GBP 500,000 on a Singapore-based exchange. Under the previous domicile-based system, an individual who maintained non-UK domicile could potentially argue that these assets were excluded property. Under the residence-based regime, the individual is a long-term UK resident, and their worldwide crypto holdings -- regardless of the exchange's jurisdiction -- fall within the UK IHT estate.19

HMRC's situs position, treating exchange tokens as located at the beneficial owner's residence, reinforces this outcome.14 The combination means that for long-term UK residents, the location of the exchange, the nationality of the token issuer, and the jurisdiction of the wallet provider are all irrelevant to IHT exposure.

4.3 Tail Provision Complexities

The tail provisions add further complexity for clients who leave the UK. An individual who has been UK resident for 15 of the previous 20 years and then emigrates remains within the UK IHT net for a period of up to 10 years post-departure.19 During this tail period, worldwide crypto holdings continue to be subject to UK IHT. Advisers dealing with internationally mobile clients must therefore consider not only current residence status but the client's residence history and planned future movements.

The interaction between crypto situs rules and the tail provisions creates a particular challenge for emigrating clients who assume that relocating their exchange accounts to non-UK platforms will remove their crypto from the UK IHT estate. HMRC's position that situs follows the beneficial owner's residence, combined with the tail provisions, means such assumptions are incorrect for the duration of the tail period.

4.4 Pension Death Benefit Interactions

The confirmed inclusion of pension death benefits within IHT from April 2027 introduces an additional planning dimension.19 While the direct intersection with cryptoassets may appear limited, regulated crypto exchange-traded products (ETPs) held within SIPP structures represent a genuine planning consideration. Advisers should be aware that the combined effect of pension IHT inclusion and crypto within the estate may require holistic modelling of the total IHT liability, particularly for clients with significant digital asset exposure alongside pension wealth.

5. The Information Revolution: CARF and Regulatory Trajectory

5.1 Crypto-Asset Reporting Framework

The Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744) came into force on 1 January 2026, implementing the OECD Crypto-Asset Reporting Framework in the UK.3 UK reporting cryptoasset service providers (RCASPs) must collect transaction data and report annually to HMRC. First reports, covering calendar year 2026, are due by 31 May 2027. Finance Bill 2025-26 extends reporting to cover UK-resident customers specifically.20

HMRC estimates that CARF will raise between GBP 315 million and GBP 350 million in additional tax revenue between 2026 and 2030.21 The revenue estimate reflects the scale of currently unreported or under-reported crypto transactions.

Penalties for non-compliance by RCASPs are substantial: up to GBP 5,000 per year for inadequate recordkeeping, GBP 300 per reportable user for missing self-certifications, and escalating daily penalties for late or inaccurate reports.3 These penalty provisions are designed to ensure high compliance rates among reporting entities, maximising the data available to HMRC.

For estate planning, CARF's significance lies in the data it will provide HMRC. Cross-referencing CARF transaction reports against IHT returns will enable HMRC to identify estates where crypto holdings have been omitted or undervalued. The enforcement trajectory evident in the nudge letter programme is likely to accelerate once CARF data flows commence in 2027. Non-disclosure of cryptoassets in IHT returns will become increasingly detectable.

5.2 FCA Regulatory Framework

The draft Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 was laid before Parliament on 15 December 2025 under draft affirmative procedure.5 If approved, it will bring cryptoasset activities within the FCA's regulatory remit from 25 October 2027.

The FCA published three concurrent consultation papers in December 2025: CP25/40 addressing trading platforms, intermediaries, staking, and decentralised finance; CP25/41 covering admissions, disclosures, and a market abuse regime; and CP25/42 proposing a prudential regime for cryptoasset firms.22 A further consultation in January 2026 addresses Consumer Duty application and SM&CR categorisation for crypto firms.23

An important distinction must be drawn: the FCA's incoming crypto regulatory regime is directed at cryptoasset firms -- exchanges, custodians, and platforms -- rather than at financial advisers who discuss clients' existing crypto holdings in the context of estate planning. Advisers are not required to hold separate authorisation to raise crypto estate planning considerations with clients. However, understanding the regulatory trajectory is relevant to the quality of advice provided and to the adviser's ability to assess the regulatory status of platforms where client assets are held.

5.3 The Ownership Landscape

The FCA's Cryptoassets Consumer Research 2025 (Wave 6, December 2025) found that 8% of UK adults hold cryptoassets, a decline from 12% in 2024.6 The research identified a continuing trend in the reduction of small-value holdings, mainly of GBP 100 or below, and an increase in those with larger-value cryptoasset holdings. Bitcoin remains the most commonly held asset (57% of holders), followed by Ethereum (43%). The survey, conducted by YouGov between August and September 2025, suggests that while the number of holders has contracted, those who remain hold larger positions -- a pattern consistent with market maturation.

For advisers, the declining ownership rate should not diminish attention to digital assets. The combination of larger individual holdings and HMRC's enforcement focus means that the estate planning consequences of overlooking crypto in a client's portfolio are potentially more significant, not less.

6. The Adviser's Operational Framework

6.1 Identification: Expanding the Fact-Find

The first operational challenge is identification. Standard fact-find questionnaires may not prompt disclosure of digital asset holdings. Advisers should consider incorporating specific questions addressing:

  • Direct holdings of cryptocurrency, stablecoins, utility tokens, or security tokens
  • NFT collections or other tokenised assets
  • Holdings on centralised exchanges (Coinbase, Binance, Kraken, and similar platforms)
  • Self-custody wallets (hardware wallets, software wallets)
  • Participation in decentralised finance protocols (staking, lending, liquidity provision)
  • Digital assets held within corporate or trust structures

The STEP Digital Assets research, conducted jointly with Queen Mary University's Cloud Legal Project, found that clients frequently experience difficulties accessing digital assets on death or incapacity and recommended a threefold approach of education, collaboration, and legislation.24 The first element -- education -- begins with the adviser raising the topic proactively.

Clients may not volunteer information about crypto holdings unless specifically asked. The stigma associated with speculative assets, combined with privacy concerns inherent to cryptocurrency culture, means that a direct and normalised line of questioning within the fact-find is more effective than relying on general open-ended prompts about "other assets."

6.2 Secure Documentation

Once digital assets are identified, documentation presents a unique challenge. Private keys and seed phrases provide unrestricted access to self-custody wallets. Including them directly in a will is inappropriate, as wills become public documents after probate. Best practice involves creating a secure, encrypted digital asset inventory held separately from the will, with the will referencing its existence and location.

STEP has published a Digital Assets Inventory template for practitioners, providing a structured approach to recording asset types, platforms, access mechanisms, and nominated individuals.25 The inventory approach allows the testator to update digital asset details without requiring a codicil or new will, provided the will's reference to the inventory is appropriately drafted.

Advisers should note the distinction between their role in flagging the need for such documentation and the solicitor's role in drafting appropriate will provisions. The referral pathway to a solicitor experienced in digital asset estate planning is a key element of the advisory framework.

6.3 Will and Trust Integration

Will drafting for digital asset holders requires specific attention to:

  • Residuary clauses -- ensuring digital assets are captured by broadly drafted residuary provisions rather than falling outside the will's scope
  • Specific legacies -- where clients wish to leave particular crypto holdings or NFTs to named beneficiaries, specific legacy clauses must identify the assets with sufficient precision
  • Executor powers -- the will should grant executors express authority to manage, sell, or transfer digital assets, including authority to engage specialist assistance

For higher-value digital asset portfolios, trust structures merit consideration. Discretionary trusts can accommodate crypto holdings, subject to standard IHT entry charges.11 The flexibility of discretionary trusts is particularly relevant for volatile assets where the composition and value of the portfolio may change substantially between settlement and distribution.

6.4 LPA Provisions

The Property (Digital Assets etc) Act 2025 means that digital assets can be subject to attorney authority under a lasting power of attorney for property and financial affairs.10 Advisers should ensure that:

  • LPA instruments include language sufficiently broad to encompass digital assets
  • Attorneys are informed of the existence of digital asset holdings (though not necessarily given immediate access to private keys)
  • Operational protocols exist for attorneys to access digital assets in the event of the donor's incapacity

The incapacity scenario is particularly acute for self-custody crypto holders. Unlike bank accounts, where attorneys can present the registered LPA to the institution and obtain access, self-custody wallets have no institutional intermediary. If the donor loses capacity and the attorney does not have access to private keys or seed phrases, the assets may be effectively frozen until -- and unless -- technical recovery methods succeed.

6.5 Referral Pathways and Risk Management

Financial advisers are not crypto-tax specialists, and the framework presented here does not imply they should become so. The adviser's role is to identify digital asset holdings, flag estate planning implications, and refer appropriately. Key referral pathways include:

  • Solicitors with digital asset expertise for will and trust drafting
  • Crypto-tax specialists for detailed IHT computation, situs analysis, and HMRC correspondence
  • STEP digital assets practitioners for complex cross-border or trust-based planning

Risk management requires documenting advice given, including file notes recording that digital assets were raised in the fact-find, what holdings were disclosed, and what referrals were made. Where a client declines to engage with digital asset planning, a clear file note recording that declination is essential.

Conclusion

The 12-month period from December 2025 to the end of 2026 represents a watershed for digital assets in UK estate planning. The Property (Digital Assets etc) Act 2025 has resolved legal uncertainty, HMRC enforcement on crypto IHT has moved from general awareness to targeted agent correspondence, CARF is operational, and the FCA's comprehensive regulatory regime is advancing toward October 2027 implementation. These developments are not sequential -- they are concurrent and mutually reinforcing.

For financial advisers, the practical consequence is that digital assets can no longer be treated as a peripheral or emerging consideration. The ICAEW's warning that agents may be overlooking IHT on cryptoassets is a direct signal to the advisory community.17 The CARF data flows commencing from 2027 will give HMRC the means to identify omissions systematically rather than relying on voluntary disclosure.

The operational framework outlined in this article -- identification through expanded fact-finds, secure documentation of access credentials, integration into wills, trusts, and LPAs, and appropriate referral to specialists -- provides a structured approach. A 2023 Professional Adviser survey found that 71.4% of respondents acknowledged insufficient peer awareness of client crypto use, underscoring the scale of the advisory gap that remains to be addressed.7

The convergence of legal recognition, tax enforcement, and regulatory architecture demands a proportionate advisory response. Digital asset estate planning is not a speculative discipline; it is an increasingly routine professional obligation.

CPD Declaration

Estimated Reading Time: 19 minutes Technical Level: Advanced Practice Areas: Estate Planning, Inheritance Tax, Digital Assets, Financial Planning

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the key provisions of the Property (Digital Assets etc) Act 2025 and their implications for bequeathing, settling, and managing digital assets within estate planning structures
  2. Explain HMRC's IHT treatment of cryptoassets under CRYPTO25000, including the situs rules for exchange tokens under the residence-based IHT regime enacted from April 2025
  3. Distinguish between the tax treatment of exchange tokens, utility tokens, security tokens, and NFTs within the IHT and CGT frameworks, including the absence of NFT-specific IHT guidance
  4. Apply a practical operational framework for identifying, documenting, and advising on digital assets within existing advisory workflows, including fact-find modifications and referral pathways
  5. Evaluate the impact of the Crypto-Asset Reporting Framework (SI 2025/744) and the FCA's incoming regulatory regime on the adviser's estate planning responsibilities and HMRC's enforcement capability

SRA Competency Mapping

  • A2: Maintain a current knowledge of law, practice, procedure and professional requirements relevant to the area of practice
  • B6: Undertake effective and appropriate identification, assessment, and management of risk

Reflective Questions

  1. How would the current fact-find process within your practice identify clients holding significant cryptoasset positions, and what amendments might be required to capture digital asset holdings systematically?
  2. What protocols should be established for documenting digital asset access credentials in a manner that balances IHT disclosure obligations with the security risks of recording private keys?
  3. How might the Crypto-Asset Reporting Framework data flows from 2027 change the risk profile of failing to include cryptoassets in IHT returns, and what proactive steps could mitigate that risk?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-04. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. Property (Digital Assets etc) Act 2025 c.29 (2 December 2025). https://www.legislation.gov.uk/ukpga/2025/29/enacted ↩ ↩2 ↩3

  2. HMRC Cryptoassets Manual, CRYPTO25000 -- Inheritance Tax. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto25000 ↩ ↩2 ↩3

  3. The Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025, SI 2025/744. https://www.legislation.gov.uk/uksi/2025/744/contents/made ↩ ↩2 ↩3

  4. ICAEW, "Agents may be overlooking IHT on cryptoassets" (December 2025). https://www.icaew.com/insights/tax-news/2025/dec-2025/agents-may-be-overlooking-iht-on-cryptoassets ↩ ↩2

  5. The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 (draft, 15 December 2025). https://www.legislation.gov.uk/ukdsi/2025/9780348277586/contents ↩ ↩2

  6. FCA, Cryptoassets Consumer Research 2025, Wave 6 (December 2025). https://www.fca.org.uk/publications/research-notes/cryptoassets-consumer-research-2025 ↩ ↩2

  7. Professional Adviser, "71.4% of advisers say peers are not aware enough of client crypto use" (October 2023). https://www.professionaladviser.com/news/4134608/advisers-peers-aware-client-crypto ↩ ↩2

  8. Law Commission, Digital Assets: Final Report (LC401, June 2023). https://lawcom.gov.uk/project/digital-assets/ ↩ ↩2

  9. Law Commission, Digital Assets: Supplemental Report and Draft Bill (July 2024). https://lawcom.gov.uk/document/digital-assets-supplemental-report-and-draft-bill/ ↩

  10. The Gazette, "What testators and executors need to know about the Property (Digital Assets etc) Act 2025." https://www.thegazette.co.uk/all-notices/content/104332 ↩ ↩2 ↩3

  11. HMRC Inheritance Tax Manual, IHTM42000 -- Trusts: settlements and other dispositions. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm42000 ↩ ↩2

  12. HMRC Cryptoassets Manual, CRYPTO10100 -- What are cryptoassets. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto10100 ↩

  13. HMRC Cryptoassets Manual, CRYPTO22200 -- Capital Gains Tax: pooling. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto22200 ↩

  14. HMRC Cryptoassets Manual, CRYPTO22600 -- Determining the location of exchange tokens. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto22600 ↩ ↩2

  15. Accountancy Daily, "Letter blitz as HMRC cracks down on crypto investors" (2025). https://www.accountancydaily.co/letter-blitz-hmrc-cracks-down-crypto-investors ↩

  16. UHY Hacker Young, FOI-sourced data on HMRC crypto nudge letters (2025). https://www.uhy-uk.com/insights/nudge-letters-sent-crypto-traders-more-double-65000-hmrc-suspects-thousands-have-underpaid ↩

  17. ICAEW, "Agents may be overlooking IHT on cryptoassets" (December 2025), reference OTM000752. https://www.icaew.com/insights/tax-news/2025/dec-2025/agents-may-be-overlooking-iht-on-cryptoassets ↩ ↩2

  18. Professional Adviser, "HMRC sends crypto IHT 'nudge' letters to advisers" (3 February 2026). https://www.professionaladviser.com/news/4525107/hmrc-sends-crypto-iht-nudge-letters-advisers ↩

  19. GOV.UK, Inheritance Tax: long-term UK residents guidance (2025). https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident ↩ ↩2 ↩3 ↩4

  20. GOV.UK, "Domestic reporting of UK resident cryptoasset users under the Cryptoasset Reporting Framework." https://www.gov.uk/government/publications/cryptoasset-reporting-framework/implementation-of-the-cryptoasset-reporting-framework-carf ↩

  21. ICAEW, "UK's cryptoasset reporting framework expected to raise GBP 315m" (July 2025). https://www.icaew.com/insights/tax-news/2025/jul-2025/uks-cryptoasset-reporting-framework-expected-to-raise-315m ↩

  22. FCA CP25/40, Regulating cryptoasset activities (December 2025). https://www.fca.org.uk/publications/consultation-papers/cp25-40-regulating-cryptoasset-activities ↩

  23. FCA, "FCA seeks feedback on further rules for cryptoasset firms" (January 2026). https://www.fca.org.uk/news/news-stories/fca-seeks-feedback-further-rules-cryptoasset-firms ↩

  24. STEP, "Digital Assets: A Call to Action" research report. https://www.step.org/research-reports/digital-assets-call-action ↩

  25. STEP, "Inventory for Digital Assets and Digital Devices." https://www.step.org/knowledge-hub/inventory-digital-assets-and-digital-devices ↩

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