Decentralised finance is the most structurally complex area of cryptoasset taxation that UK investors and tax professionals currently face. Every interaction with a lending protocol, liquidity pool, or automated market maker generates a potential taxable event under current HMRC guidance, regardless of whether any economic gain has been realised in a usable form. The resulting compliance burden, widely described by industry respondents and HMRC itself as disproportionate, has driven years of consultation, a contested call for evidence, and the Autumn Budget 2025 announcement of a proposed no-gain/no-loss framework that would fundamentally alter how DeFi capital flows are taxed.
At KoinX, we help investors and tax professionals navigate the precise GBP valuations, disposal calculations, and income classifications that HMRC’s current DeFi rules require, and the data below reflects exactly why that infrastructure has become operationally essential for active DeFi participants in the UK.
This article compiles over thirty verified statistics from primary sources, including HMRC consultation documents and internal manual guidance, HM Treasury publications, the FCA consumer research series, the Bank for International Settlements, and Office for Budget Responsibility projections. Every figure is drawn directly from the originating document and cited with a specific source URL. No figures are synthesised, inferred, or fabricated.
Scope and Methodology
All statistics in this article were compiled against the following criteria applied uniformly throughout:
Sources were accepted only if the organisation produced the data itself. Accepted primary sources include HMRC consultation documents, call for evidence outcomes and summary of responses, the HMRC Cryptoassets Manual, HM Treasury impact assessments, the Financial Conduct Authority’s consumer research series, the Bank for International Settlements working paper series, and the Office for Budget Responsibility. Commentary, blog posts, accounting firm client advisories, and news aggregators were excluded without exception.
A two-year publication window was applied to all statistics. Data must derive from documents published in 2024 or 2025. Where a figure originates from an earlier document and no more recent equivalent exists from a primary source, the original year is explicitly retained in the bullet. All bullets include the year of the source document.
Geographic scope is the United Kingdom throughout. The TVL and DeFi market statistics are global in scope where cited from the BIS working paper, and are included to contextualise HMRC’s regulatory challenge rather than to represent UK-only market size.
Statistical integrity was maintained by limiting each bullet to a single numeric finding from a single source with no synthesis, rounding, or inference beyond the original. Source URLs point to the specific consultation document, manual section, or research paper, never to a homepage or aggregator.
A material limitation is acknowledged upfront: HMRC does not publish UK-specific DeFi participation rates, a dedicated DeFi tax gap estimate, or sector-specific revenue collections from DeFi yield taxation. The compliance dimension of this article is therefore constructed from the available proxies: consultation response data, FCA consumer lending and staking participation figures, and enforcement statistics for the wider cryptoassets compliance programme.
UK DeFi Tax in 2026: The Defining Numbers
- 32 formal written responses to the HMRC consultation on DeFi lending and staking were received from stakeholders including individuals, businesses, tax professionals, and representative bodies between 27 April 2023 and 22 June 2023, based on the HMRC summary of responses published November 2025.
- Stakeholders unanimously supported HMRC reviewing the current DeFi tax rules, with key themes including a need for more straightforward compliance, flexibility to adapt to new arrangements, and greater tax certainty, based on the HMRC DeFi consultation summary of responses published November 2025.
- 9% of UK cryptoasset users reported participating in cryptoasset lending or borrowing in the 12 months prior to the 2024 FCA survey, based on FCA Cryptoassets Consumer Research 2024 Wave 5.
- Just over half (51%) of UK cryptoasset users said they had not participated in lending or borrowing of cryptoassets and had not heard of these activities, based on FCA Cryptoassets Consumer Research 2024 Wave 5.
- The Autumn Budget 2025 confirmed the government will introduce a no-gain/no-loss legislative framework for DeFi lending and liquidity pool transactions, with draft legislation included in Finance Bill 2025-26, based on the summary of responses to the DeFi consultation published November 2025.
- 939 DeFi protocols on Ethereum were studied in the BIS working paper on TVL verifiability, published May 2025, finding that 10.5% of protocols rely partially or entirely on external off-chain data sources, making their TVL figures difficult to independently verify.
- Rates of cryptoasset lending and borrowing among UK users remained in line with 2024 levels in 2025, based on FCA Cryptoassets Consumer Research 2025 Wave 6.
- The UK tax gap stood at 5.3%, or £46.8 billion, in the 2023 to 2024 tax year, based on the HMRC Measuring Tax Gaps 2025 report published June 2025.
- 8% of UK adults owned cryptoassets in 2025, equivalent to approximately 4.5 million adults, down from 12% in 2024, based on FCA Cryptoassets Consumer Research 2025 Wave 6.
- HMRC’s implementation cost for the CARF IT infrastructure, exchange, and compliance systems is estimated at £69 million, based on the HMRC CARF impact assessment published June 2025.
HMRC DeFi Tax Rules: Beneficial Ownership and CGT Treatment
- Under HMRC’s current guidance set out in Cryptoassets Manual section CRYPTO61000 onwards, a DeFi lending or liquidity pool transaction can be treated as a disposal for Capital Gains Tax purposes if beneficial ownership of the cryptoassets changes at the point of transfer, based on the HMRC Cryptoassets Manual.
- HMRC’s Cryptoassets Manual section CRYPTO61120 defines 2 types of transaction covered by the DeFi lending and staking guidance: a person transferring control of tokens to a borrower under a repayment obligation, and a liquidity provider transferring control to a DeFi platform, based on the HMRC Cryptoassets Manual CRYPTO61120.
- HMRC does not consider any return received from a DeFi transaction to be interest for tax purposes, because cryptoassets are not currency or money, based on the HMRC Cryptoassets Manual section CRYPTO61110.
- HMRC’s guidance at section CRYPTO21200 of the Cryptoassets Manual states that where staking activity does not amount to a trade, the GBP sterling value of tokens awarded at the time of receipt is taxable as miscellaneous income, based on the HMRC Cryptoassets Manual.
- HMRC’s official guidance updated April 2025 confirms that tokens received from lending through DeFi, where not carried on as a trade, are treated as other taxable income subject to the £1,000 trading and miscellaneous income allowance, based on HMRC GOV.UK guidance updated April 2025.
- Under HMRC guidance at CRYPTO61214, DeFi returns can be taxed either as miscellaneous income if of a revenue nature or as a capital gain if of a capital nature, with determination based on whether the return is income-like or capital-like, based on the HMRC DeFi consultation document published November 2025.
- HMRC’s income tax guidance at CRYPTO61211 states that where DeFi lending does not constitute a trade, the making of a DeFi loan may give rise to a disposal of a chargeable asset, making Capital Gains Tax applicable to the disposal, based on the HMRC Cryptoassets Manual CRYPTO61211.
- The HMRC DeFi consultation identified that the current tax rules can lead to a dry tax charge, creating a CGT liability from a transaction where no gain has been realised in a form which can be used to meet the liability, based on the HMRC DeFi Call for Evidence published July 2022.
The HMRC DeFi Consultation: Policy Development Statistics
- The HMRC Call for Evidence on DeFi taxation ran from 5 July 2022 to 31 August 2022, with most respondents agreeing that a change in the tax rules would be beneficial for the industry and users, based on the HMRC DeFi consultation document published April 2023.
- The 2023 HMRC DeFi consultation ran from 27 April 2023 to 22 June 2023, seeking views on a potential legislative solution to align taxation of DeFi transactions with their economic substance, based on the HMRC consultation landing page.
- The 3 options considered in the HMRC DeFi Call for Evidence were: bringing cryptoasset loans into repo and stock lending regimes; creating separate rules following similar principles; and introducing new NGNL rules to defer tax until economic disposal, based on the HMRC DeFi consultation summary of responses November 2025.
- Respondents to the 2022 call for evidence favoured options 2 and 3 in equal numbers, with almost all agreeing that a change of tax rules was beneficial, but most not seeing Option 1 (the repo approach) as optimal, based on the HMRC DeFi consultation summary of responses November 2025.
- The vast majority of respondents to the 2023 consultation who addressed multi-token liquidity pool arrangements strongly advocated for treating deposits into and redemptions from these pools as NGNL disposals, based on the HMRC DeFi consultation summary of responses November 2025.
- A third of respondents to the 2023 HMRC DeFi consultation believed the proposed new rules would reduce the administrative burden, while another third believed adopting the repo-like approach would increase the administrative burden, based on the HMRC summary of responses November 2025.
- The HMRC DeFi consultation confirmed that proposed new rules for cryptoasset loans and liquidity pools would apply whether or not arrangements involve an intermediary, meaning they would cover both DeFi and centralised finance (CeFi), based on the HMRC consultation summary of responses November 2025.
- The government confirmed it is developing the NGNL approach in relation to individuals first, before assessing whether it could be extended to cover corporates, based on the HMRC DeFi consultation summary of responses November 2025.
- DeFi returns are confirmed to remain taxable as miscellaneous income under the proposed NGNL regime, with the government stating it is not currently exploring specific provisions to change this, based on the HMRC DeFi consultation summary of responses November 2025.
TVL, DeFi Market Size, and Data Transparency Statistics
- A 2025 BIS working paper studying 939 DeFi protocols on Ethereum found that 78.6% use standard balance queries, while a significant number employ non-standard methods, reducing interpretability of TVL figures, based on BIS Working Paper No. 1268 published May 2025.
- At the end of 2024, Ethereum TVL estimates published by different aggregators varied from approximately $80 billion to $190 billion, indicating significant methodological differences in TVL computation, based on BIS Working Paper No. 1268 published May 2025.
- The BIS working paper found that 10.5% of the 939 DeFi protocols studied rely partially or entirely on data from external services to compute TVL, impairing full reproducibility of the metric, based on BIS Working Paper No. 1268 published May 2025.
- 240 balance queries executed on the same contracts and tokens were found to be repeated on multiple protocols in the BIS study, representing potential double-counting in TVL metrics, based on BIS Working Paper No. 1268 published May 2025.
- A case study of 400 protocols in the BIS working paper found that the proposed verifiable TVL measure aligned with published TVL figures for only 46.5% of protocols, indicating widespread divergence between published and verifiable figures, based on BIS Working Paper No. 1268 published May 2025.
UK Cryptoasset Adoption and DeFi Participation Statistics
- 27% of UK cryptoasset users reported participating in cryptoasset staking in the 12 months prior to the 2024 FCA survey, compared to 9% who reported participating in lending or borrowing, based on FCA Cryptoassets Consumer Research 2024 Wave 5.
- 43% of UK cryptoasset users in 2024 reported they had not participated in staking and had not heard of it, while 26% had not participated but had heard of it, based on FCA Cryptoassets Consumer Research 2024 Wave 5.
- The proportion of UK cryptoasset users who participated in cryptoasset staking fell by 5 percentage points to 22% in 2025, while among those more willing to take higher risks for higher returns, 28% reported staking participation, based on FCA Cryptoassets Consumer Research 2025 Wave 6.
- 91% of UK adults were aware of cryptoassets in 2025, unchanged from 2024, with awareness of stablecoins among users rising to 58% from 53% in 2024, based on FCA Cryptoassets Consumer Research 2025 Wave 6.
- 12% of UK adults, approximately 7 million people, owned cryptoassets in August 2024, based on FCA Cryptoassets Consumer Research 2024 Wave 5.
- Cryptoasset users are more tolerant of financial risk than those who are aware of crypto but choose not to invest, with approximately 63% of users saying they are willing to take higher risks for higher returns in 2025, based on FCA Cryptoassets Consumer Research 2025 Wave 6.
CARF Reporting and DeFi Compliance Infrastructure
- Several respondents to the HMRC CARF consultation requested additional guidance on establishing when individuals or entities have control or sufficient influence in the context of decentralised services, including decentralised exchanges and other DeFi arrangements, based on the HMRC CARF consultation summary of responses published October 2024.
- Multiple respondents to the HMRC CARF consultation requested that software developers and non-custodial platforms be categorically excluded from the definition of a Reporting Cryptoasset Service Provider, based on the HMRC CARF consultation summary of responses October 2024.
- The HMRC CARF consultation received 33 written responses from stakeholders, with respondents generally supportive of the proposals while noting the need for further guidance on decentralised services, based on the HMRC CARF consultation summary of responses October 2024.
- UK RCASPs must submit their first CARF reports to HMRC between 1 January and 31 May 2027 covering all cryptoasset transactions including those in DeFi protocols where they qualify as relevant cryptoassets, based on the HMRC CARF guidance updated January 2026.
- The FCA published Consultation Paper CP25/40 in December 2025 covering proposed rules for trading platforms, intermediaries, lending, borrowing, staking, and decentralised finance, explicitly including DeFi within its scope, based on the FCA CP25/40 published December 2025.
- The new UK cryptoasset regulatory regime is not expected to come into force until 25 October 2027, based on the FCA cryptoassets regulatory timeline as of December 2025.
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