TL;DR: Yes, indirectly, and using Bitcoin as money is where the tax hides. Strike is a Bitcoin-only payments app built on the Lightning Network, and it now operates in the UK, so it is not an offshore exchange trying to stay out of view. It is not on the FCA's cryptoasset register itself, but it runs in the UK with FCA-approved financial promotions, and from 1 January 2026 the Cryptoasset Reporting Framework (CARF) brings UK-facing crypto providers into automatic reporting to HMRC. The catch with Strike is the way people use it. It feels like a money app, but Bitcoin is a crypto asset, so spending Bitcoin or sending it to someone else is generally a disposal for capital gains tax. If you have used Strike and not declared those gains, now is the time to sort it out.
Below, we look at what HMRC can realistically see, the unusual spot Strike occupies with UK regulators, why paying with Bitcoin trips people up at tax time, and the steps to take if you are behind. It reflects HMRC, FCA and OECD positions as of June 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.
Does Strike share data with HMRC?
Strike does not send HMRC a routine feed of its UK customers today, and there is no public record of a blanket customer-data handover. But Strike is not an offshore exchange holding UK users at arm's length either. It chose to launch in the UK and to run its marketing through the UK's financial-promotion rules, which is the behaviour of a business that intends to operate inside the system rather than around it.
HMRC does not need a routine feed to get hold of data, either. Its information powers, under Schedule 23 of the Finance Act 2011 and Schedule 36 of the Finance Act 2008, let it compel businesses to produce records, and it has turned them on the crypto sector before: in 2021 Coinbase handed over UK customer data for accounts that had received more than £5,000 in crypto. Add to that the fact that many users do not keep their activity entirely within Strike, since topping up or cashing out often passes through a UK bank or another exchange, and those on and off ramps are where HMRC can pick up the thread.
So the honest position is that Strike may not be reporting you automatically just yet, but your activity is far from invisible, and the reporting net is tightening.
What changes from 1 January 2026: the Cryptoasset Reporting Framework
Think of CARF as the crypto counterpart to the cross-border data sharing that has applied to bank accounts for years, drawn up by the OECD. The UK put it on the statute book as The Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025, which took effect on 1 January 2026, and our explainer on the OECD's CARF release goes deeper.
The reason it reaches Strike is that CARF is aimed at cryptoasset service providers, not just at exchanges with an FCA registration. A provider that lets UK residents buy, sell, send and receive Bitcoin is precisely the kind of business the regime is built to capture. So whether the data reaches HMRC through Strike's own reporting or through international exchange of information between CARF countries, the direction of travel is the same: a UK-facing Bitcoin app is no longer a quiet corner. CARF is the crypto version of the system that already shares offshore bank-account data across more than 100 countries.
What information is reported under CARF?
Once a provider falls in scope, CARF pins down exactly what it has to report for each UK-resident customer.
| 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 | - |
A provider files its report with its home tax authority, which then passes it to other CARF members, and that hand-off is the route by which a UK resident's data reaches HMRC. 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. |
| 31 May 2027 | First reports due to HMRC, covering the 2026 calendar year. |
| From 2027 onwards | International exchange of CARF data between countries begins. |
So from the 2026/27 tax year, HMRC can expect a yearly stream of reportable crypto activity to set against what people have declared.
Is Strike regulated in the UK?
This is where Strike sits in an unusual spot, different from both the offshore venues and the FCA-registered exchanges. Strike launched in the UK after rolling out across Europe, so it is a UK-facing business. It is not, however, on the FCA's cryptoasset register itself. Instead, its UK financial promotions are approved by an FCA-authorised firm permitted to approve cryptoasset promotions under the rules that have applied since October 2023. In plain terms, Strike reaches the UK market through the approved-promotions route rather than by holding its own cryptoasset registration.
It is worth being precise about what that does and does not mean. The promotions arrangement is about how Strike can market to UK consumers; it does not make Bitcoin a regulated investment, and it does not bring your holdings under the Financial Services Compensation Scheme. A wider UK cryptoasset regime is also on the way, which over time will pull more crypto firms into direct FCA authorisation. None of this changes your tax position. However Strike is regulated, you are the one responsible for declaring your gains and income to HMRC.
Why Bitcoin payments on Strike are easy to misreport
This is the part that catches Strike users out, because Strike is designed to feel like a money app rather than an investment account. The trouble is that Bitcoin is a crypto asset, and HMRC treats moving it the same way whether you call it spending or investing.
- Spending or sending Bitcoin is a disposal. Paying someone, sending Bitcoin abroad, or buying something with it is a disposal of that Bitcoin for capital gains tax, valued in pounds at the moment you send it. It does not feel like a sale, but it is treated as one.
- Lots of small payments add up. Strike is built for fast, low-cost Lightning payments, so a regular user can rack up a long list of little disposals over a year, each of which technically needs valuing and recording.
- Recurring buys build a tangled pool. Many people use Strike to buy a fixed amount of Bitcoin on a schedule. Every purchase goes into the same Section 104 pool, and that running average cost is what each later disposal is measured against, which is awkward to reconstruct by hand.
- Moving Bitcoin off Strike is not always a disposal, but has to be tracked. Withdrawing Bitcoin to your own wallet is a transfer, not a disposal, yet it still has to be matched so it is not mistaken for a sale, and so the cost basis follows the coins.
Pulling an accurate position out of all that by hand is genuinely hard, and treating Strike like a current account is one of the most common reasons people end up understating what they owe.
Why has HMRC been sending nudge letters about crypto?
Where HMRC's records and someone's declared figures do not match, the opening move is typically a nudge letter. It is not a formal investigation, more a nudge to revisit your tax affairs and put right anything missing, and it usually says HMRC holds information pointing to undeclared crypto.
The numbers have jumped: HMRC put out 64,982 crypto nudge letters across 2024/25, more than double the 27,713 of the prior year, a rise of about 134%, on figures from a UHY Hacker Young Freedom of Information request that the Financial Times wrote up in October 2025. Data matching is what powers these runs, and the pool of data feeding them widens every time another reporting stream switches on. Treat a letter as a cue to act rather than an accusation, because fixing a return yourself is almost always cheaper than letting it become a formal enquiry. Our guide on what to do if you receive an HMRC nudge letter about your crypto runs through the choices.
Can HMRC see my Strike transactions?
Not by peering into your account, and not as it happens. The picture HMRC builds is a data exercise: records it can demand under its powers, the footprints your money leaves at UK banks and UK-registered exchanges, and, as CARF spreads, data passed over from abroad, all set against what you filed. A Bitcoin payments app feels private, but that privacy is thinner than people expect, and it thins further each year.
How are Strike gains taxed in the UK?
Strike is Bitcoin only, so there is no crypto-to-crypto trading to worry about, but the disposals are still there, mostly disguised as payments. Selling Bitcoin for pounds is a disposal for capital gains tax, and so is spending or sending Bitcoin, each worked out using HMRC's share-pooling rules, which our comprehensive UK crypto tax guide explains in full. Any Bitcoin you receive as a credit or reward may be taxable as income at its value on the day you receive it, depending on the circumstances.
Example: Maya's Strike payments. Maya sets up a recurring £200 monthly Bitcoin buy on Strike, so over a year she builds a Section 104 pool from £2,400 of purchases. When a relative abroad needs help, she sends them £600 of Bitcoin straight from the app. To Maya it feels like sending money, but for tax it is a disposal of Bitcoin at its £600 value on the day. If the pooled cost of that slice was £400, she has a £200 capital gain to report, even though she never thought of it as a sale. For a quick estimate on a single disposal like this, our free crypto tax calculator does the sums.
What should I do if I have undeclared Strike gains?
What keeps you safe here is reaching HMRC before it reaches you. If you have used Strike and left gains or income off your return, a disclosure you make voluntarily is handled far more gently than one HMRC has to dig out itself.
1. Work out what you owe. Export your full Strike history and pull together every disposal: Bitcoin sold, spent or sent, plus any credits or rewards received and your deposits and withdrawals. Apply HMRC's share-pooling rules to the disposals and treat any rewards as income from crypto.
2. Tell HMRC. While a tax year is still open you can put it right with an online amendment to your Self Assessment return; that option lasts for 12 months beyond the filing deadline, so a return filed by 31 January 2026 stays amendable until 31 January 2027. For years already closed, HMRC's dedicated channel is the Cryptoasset Disclosure Facility, open since November 2023 for unpaid Income Tax or Capital Gains Tax on crypto.
3. Pay what is due. Unpaid tax gathers interest, and a penalty usually rides along with it, but coming forward before HMRC gets in touch keeps that penalty down, so speed pays for itself. If your Strike history is long or tangled, our directory can point you to a Recap-verified UK crypto tax specialist.
How Recap helps with Strike tax
Recap takes your Strike history and turns it into a complete UK tax report, with each Bitcoin payment, sale and reward classified and valued for you. You export your transaction history CSV from the Strike app and upload it to Recap, and Recap reads your buys, sells, sends, receives and credits, values them with our fair-market valuation engine, works out which movements are disposals, and applies HMRC's rules. You can see the setup on our Strike integration page.
Connect your accounts to Recap, upload your Strike export, and get a year of Bitcoin payments back as clear UK gains and income figures, in a report that is ready to file or to send to your accountant.
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
- 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
- FCA cryptoasset financial-promotion regime (in force from 8 October 2023); Strike's UK financial promotions approved by an FCA-authorised approver
- Coinbase 2021 UK customer-data disclosure (over £5,000)
