TL;DR: Assume HMRC can obtain or receive Bybit-related data, but the route depends on which Bybit platform you used. This is the first thing to untangle, because since December 2025 there are really two Bybits for a UK customer. There is Bybit's UK platform, made available under a financial-promotion arrangement approved by Archax, an FCA-authorised firm, offering spot and P2P trading. Bybit itself is not FCA-authorised or registered, but a UK-facing arrangement like this is the kind the reporting rules that began on 1 January 2026 under CARF are designed to capture. And there is the older global Bybit platform, a Dubai-based offshore venue from a UK point of view, which is where most UK users have traded. Neither keeps you out of HMRC's sight. If you have gains or income from Bybit you have not declared, it is worth sorting now.
This guide explains the split, what HMRC can see in each case, where Bybit stands with regulators, and the steps to take if you owe tax. It reflects HMRC, FCA and OECD positions as of July 2026.
Disclaimer
This guide is intended as a generic informative piece. This is not accounting or tax advice that can be relied upon for any UK individual's specific circumstances. Please speak to a qualified tax advisor about your specific circumstances before acting upon any of the information in this article.
Two Bybits: the UK platform and the global platform
- Bybit's UK platform (via Archax). Bybit relaunched UK access on 19 December 2025 under a financial-promotion arrangement approved by Archax, an FCA-authorised London firm, under Section 21 of the Financial Services and Markets Act, the same model used for other exchanges' UK marketing. Archax's role is approving and supporting Bybit's financial promotions to UK users, which is not the same as operating the account, holding custody, or being the CARF reporting provider. The platform offers spot and P2P trading, not derivatives. Bybit itself is not FCA-authorised or registered, and crypto held through it is not covered by the Financial Ombudsman Service or the Financial Services Compensation Scheme.
- The global Bybit platform. A Dubai-based offshore venue from a UK user's perspective. This is the platform most UK users have used historically.
Which one your records sit on determines how HMRC gets your data, so the two are handled separately below. If you traded before the UK relaunch, your history is almost certainly on the global platform.
Does Bybit share data with HMRC?
Take the UK route first. Bybit's UK platform is made available under Archax's FCA-authorised approval of its financial promotions, and it serves UK residents, so it is the kind of UK-facing arrangement the reporting rules are built for. Whether Bybit is itself the reporting provider under CARF depends on its status and UK nexus, so treat UK-side activity as likely to be reported rather than certain to be, covered under CARF below.
The global platform is the more familiar question. As an offshore venue it does not file routine UK-customer reports with HMRC, and there is no public record of a bulk handover like Coinbase's in 2021. But offshore is not out of reach. HMRC may not get a direct real-time feed from the global platform, but it can use its domestic information powers, under Schedule 23 of the Finance Act 2011 and Schedule 36 of the Finance Act 2008, against UK-connected data holders such as UK banks and UK-registered exchanges, and it can receive overseas data through international exchange, including CARF where the provider or its jurisdiction is in scope. Crypto rarely stays put either: funding a Bybit account or withdrawing profits usually routes through a UK bank or a UK-registered exchange, which is where a trail begins.
The honest summary: Bybit's UK platform is the kind of UK-facing activity the reporting rules are built to capture, and the global platform, while not reporting you directly today, leaves a trail that HMRC can follow and that CARF widens from 2027.
What changes from 1 January 2026: the Cryptoasset Reporting Framework
CARF, the OECD's Cryptoasset Reporting Framework, makes crypto activity flow automatically between tax authorities, the same way bank data has for years. The UK turned it into law with The Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025, in force from 1 January 2026, and Finance Act 2026 extended the reporting duty to information about UK-resident users; our explainer on the OECD's CARF release covers how it works.
It can apply to both Bybits, by different paths. Where Bybit's UK-facing arrangement falls within the reporting regime, UK-side activity would be reported by the relevant in-scope provider. For the global platform, CARF's international reach is the relevant mechanism: many jurisdictions, increasingly including the major hubs, collect crypto data and exchange it across borders, so data on a UK resident held by an overseas exchange can make its way to HMRC over time.
What information is reported under CARF?
For each UK-resident customer, an in-scope provider hands over a defined list.
| Identity data | Transaction data |
|---|---|
| Full name | Transaction types (exchanges, transfers, spending) |
| Date of birth | Annual aggregate value |
| Home address | Units and asset type |
| Country of tax residence | - |
| National Insurance / UTR | - |
For Bybit this matters because the global platform's data does not have to reach HMRC directly: a report filed with a provider's home authority is exchanged onward with the other CARF members, HMRC included. Under HMRC's CARF guidance, the rules carry penalties for users and providers alike: a user who deliberately or carelessly fails to provide a valid self-certification can face a penalty of up to £300, while reporting providers face separate penalties for due-diligence, reporting, notification, registration and record-keeping failures.
When does CARF reporting take effect?
| Date | What happens |
|---|---|
| 1 January 2026 | Data collection begins for in-scope providers with UK customers. |
| 1 January to 31 May 2027 | First reports due to HMRC, covering the 2026 calendar year. |
| By 30 September 2027 | First international exchange of CARF data between tax authorities. |
For Bybit's UK arrangement, where it is in scope, that means the standard UK timeline; for the global platform, data reaching HMRC depends on its jurisdiction's participation, but the trend only runs one way.
Is Bybit legal to use in the UK?
Bybit is available to UK users again, but through a specific arrangement: Bybit's UK platform is made available under Archax's FCA-authorised approval of its financial promotions, offering spot and P2P only. Bybit is not itself on the FCA's cryptoasset register or otherwise FCA-authorised, and it has appeared on the FCA's warning list, having previously been flagged for serving UK consumers without authorisation before it suspended its UK service when the FCA tightened the financial-promotion rules. The warning relates to Bybit's own unauthorised status rather than to the Archax-approved promotion arrangement, so check the FCA register and warning list for the current entry and status.
Two limits matter for UK users. Crypto derivatives cannot be sold to UK retail consumers under the FCA ban in force since January 2021, which is why Bybit's UK platform offers spot and P2P only and why the global platform's perpetuals, futures and leveraged tokens are not something a UK retail trader can lawfully be offered. And as with every crypto venue, none of this alters your tax position: gains and income are reportable to HMRC whichever platform produced them.
Why a Bybit account is hard to get right at tax time
Bybit packs a lot into one account, and if you used the global platform the range is wide. Several activity types each carry their own treatment.
- Spot trades and Convert. Selling crypto or swapping one coin for another, including Bybit's quick Convert feature, is a disposal for capital gains, even when no fiat is involved.
- Derivatives and funding. On the global platform, perpetuals and futures generate realised profit and loss when positions close, plus funding payments between traders, all of which need accounting for and raise the question of whether profits are capital or income.
- Earn and bonuses. Rewards from Bybit Earn, and bonuses or incentives credited to your account, are income, valued when you receive them.
- Copy trading. If you copied another trader, the trades executed in your account are your disposals, even though you did not place them yourself.
The difficulty is rarely one transaction; it is the volume and the variety, often spread across the global platform and now Bybit UK as well. That is exactly the kind of gap that leaves your figures out of step with what HMRC eventually holds.
Why has HMRC been sending nudge letters about crypto?
When HMRC's data does not match a person's return, it tends to open with a nudge letter: not an investigation, just a prompt to review your affairs and correct anything missed, usually noting that HMRC holds information suggesting undeclared crypto.
The volumes have jumped:
| Tax year | Crypto nudge letters |
|---|---|
| 2024/25 | 64,982 |
| 2023/24 | 27,713 |
The figures are from a UHY Hacker Young Freedom of Information request reported by the Financial Times in October 2025. These run on data matching, and the pool feeding them keeps growing as CARF reporting comes online. Treat a letter as a prompt rather than an accusation: putting your return right voluntarily is almost always cheaper than a formal enquiry. Our guide on what to do if you receive an HMRC nudge letter about your crypto sets out the steps.
Can HMRC see my Bybit transactions?
For Bybit's UK platform, increasingly, because it is a UK-facing arrangement of the kind the reporting rules now in force are built to capture. For the global platform, not by logging in or in real time, but through HMRC's information powers against UK-connected data holders, the trail your funds leave at UK banks and UK-registered exchanges, and CARF data passed in from abroad where the provider is in scope. Either way, the realistic assumption is that your Bybit activity is traceable, and more so each year.
What should I do if I have undeclared Bybit gains?
Undeclared Bybit gains or income are best dealt with on your own initiative, before HMRC makes contact, because a disclosure you volunteer is treated much more gently than one HMRC has to prise out.
Three steps.
1. Work out what you owe. Gather everything: spot trades and Convert, any derivatives positions and funding on the global platform, Bybit Earn and bonuses, and transfers in and out, across both Bybit UK and the global platform if you used both. Run the disposals through HMRC's share-pooling rules, explained in our comprehensive UK crypto tax guide, and treat Earn and bonuses as income from crypto. For a quick estimate on a single disposal, our free crypto tax calculator helps.
As a rough illustration, someone who sold crypto on Bybit for £9,000 that they had bought for £5,000 has a £4,000 gain. After the £3,000 annual exempt amount, £1,000 is taxable, and assuming no other gains or losses and that it falls within their basic-rate band, the CGT would be £180 at 18% for the 2026/27 tax year. If they also received £500 of Bybit Earn rewards over the year, that £500 is income, taxed at their marginal rate. The exact figures depend on your other income and on HMRC's share-pooling rules, so the cleanest way to know your real position is to run the numbers.
2. Tell HMRC. A year still in date is fixed with an online amendment to your Self Assessment return; the window is 12 months past the filing deadline, so a 2024/25 return filed by 31 January 2026 remains open until 31 January 2027. Once that passes, HMRC's Cryptoasset Disclosure Facility has handled unpaid Income Tax or Capital Gains Tax on crypto since November 2023.
3. Pay what is due. Interest builds on unpaid tax, and HMRC may add a penalty as well; since that penalty is smaller for those who come forward first, delay has a price.
With derivatives potentially in play and activity split across two platforms, advice is well worth it; our directory lists Recap-verified UK crypto tax specialists for exactly this.
How Recap helps with Bybit tax
Recap brings your Bybit history into one place and works out the tax. You can connect via API or import your Bybit transaction CSV, pulling in spot trades, Convert, derivatives profit and loss, funding, Earn and bonuses, and reconciling activity from both the global platform and Bybit UK. Recap classifies and values everything and produces your gains and income under HMRC's rules.
Connect your Bybit account to Recap and turn a busy, multi-product history into a single UK tax report, ready to file or hand to your accountant.
Key takeaways
- There are two Bybits, and it changes the answer. Bybit's UK platform is made available under Archax's FCA-authorised financial-promotion approval and offers spot and P2P; the older global platform is a Dubai-based offshore venue from a UK point of view.
- Bybit itself is not FCA-authorised. It has appeared on the FCA warning list, crypto held through it is not covered by the Financial Ombudsman Service or the Financial Services Compensation Scheme, and its derivatives cannot be sold to UK retail consumers.
- Neither route keeps you out of HMRC's sight. UK-side activity is the kind CARF's reporting rules are built for, and the global platform is reachable through HMRC's information powers against UK-connected data holders, the trail your funds leave at UK banks, and CARF's international exchange from 2027.
- Bybit accounts are easy to misreport. Spot trades and Convert are disposals; Earn and bonuses are income; derivatives profit and copy-trading disposals add more, often spread across both platforms.
- If you are behind, coming forward first is cheaper. Amend a Self Assessment return up to 12 months after the filing deadline, or use the Cryptoasset Disclosure Facility for older years; an unprompted disclosure can mean lower penalties, depending on the circumstances.
References
- HMRC and OECD: Cryptoasset Reporting Framework, domestic reporting of UK-resident cryptoasset users
- HMRC: Implementation of the Cryptoasset Reporting Framework (penalties for users and reporting providers)
- The Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744); Finance Act 2026 extended reporting to UK-resident users
- Schedule 23, Finance Act 2011
- Schedule 36, Finance Act 2008
- HMRC Cryptoasset Disclosure Facility
- Nudge-letter statistics: UHY Hacker Young FOI, reported by the Financial Times, October 2025
- Bybit FCA warning-list entry (not FCA-authorised) (confirm the live entry and its current status and date before publishing)
- Bybit UK relaunch under an Archax-approved financial-promotion arrangement (spot and P2P, not derivatives), 19 December 2025: CoinDesk. Bybit itself is not FCA-authorised or registered; the global platform is Dubai-based and offshore from a UK perspective.
- FCA ban on the sale of crypto derivatives to UK retail consumers, in force from 6 January 2021
- Bybit February 2025 hack (on or about 21 February 2025): FBI attribution of around $1.5bn theft to North Korea; Bybit incident timeline (around $1.46bn, client assets stated 1:1 backed). Largest crypto heist on record.
