SEC Proposes New Crypto Asset Reporting Framework with Structured XML Requirements
SEC Form 1-CRYPTO is part of the U.S. Securities and Exchange Commission’s proposed Regulation Crypto Assets framework, introducing new disclosure and structured reporting requirements for certain crypto asset offerings.
Announced on August 18, 2026, the proposal would establish two exemptions from the registration requirements of the Securities Act of 1933 and introduce new reporting obligations for issuers relying on those exemptions.
What Is Regulation Crypto Assets?
The SEC’s proposed framework would create two exemptions for offerings involving covered crypto asset investment contracts:
1.
A startup exemption allowing offerings of up to $5 million during a four-year period.
A startup exemption allowing offerings of up to $5 million during a four-year period.
2.
A fundraising exemption allowing offerings of up to $75 million during each 12-month period.
A fundraising exemption allowing offerings of up to $75 million during each 12-month period.
Issuers using either exemption would need to provide specified principles-based narrative disclosures to investors. Those relying on the larger fundraising exemption would also be required to provide financial statements and comply with ongoing reporting requirements.
The proposal also includes a conditional safe harbor under which a crypto asset could, if specified conditions are met, no longer be treated as subject to an investment contract for purposes of the relevant definitions of a security.
SEC Proposes New Form 1-CRYPTO
A key component of the proposed fundraising exemption is a new Form 1-CRYPTO.
Form 1-CRYPTO would be used for offering statements under the fundraising exemption and would consist of three parts:
Part I:
An XML-based fillable form containing key information about the issuer and offering.
An XML-based fillable form containing key information about the issuer and offering.
Part II:
The body of the disclosure document and financial statements.
The body of the disclosure document and financial statements.
Part III:
Signatures, exhibit index, and supporting exhibits.
Signatures, exhibit index, and supporting exhibits.
Documents required under the proposed fundraising exemption would be filed electronically through EDGAR.
View the full SEC proposed rule
Part I of Form 1-CRYPTO Would Use Structured XML
The structured reporting aspect of the proposal is particularly significant.
The SEC proposes that Part I of Form 1-CRYPTO be submitted through EDGAR using Form 1-CRYPTO-specific XML. Issuers would have two ways to prepare the submission.
They could complete a fillable web form provided through EDGAR, with EDGAR converting the information into the required XML format. Alternatively, issuers could use their own software to prepare and submit the XML information directly in accordance with the technical specifications for Form 1-CRYPTO.
The SEC says using form-specific XML could help Commission staff process, aggregate, and analyze reported information and could also make the disclosures easier for markets and investors to access and compare.
For organizations managing SEC filings and other structured regulatory submissions, evolving EDGAR requirements reinforce the importance of reporting processes that can accommodate changes in formats, validation rules, and regulatory specifications. Ez-XBRL supports U.S. regulatory reporting through its SEC reporting solutions.
Could XBRL Be Considered for Form 1-CRYPTO?
The SEC proposal does not currently require XBRL for Form 1-CRYPTO. The proposed structured format for Part I is form-specific XML.
However, the Commission has expressly requested feedback on whether Part I should instead be submitted using a different structured data language.
XBRL US has said it intends to submit a comment letter recommending that XBRL be the required reporting format for the proposed form.
Read the XBRL US update on Regulation Crypto Assets
XBRL International has also highlighted the proposal and the discussion around the appropriate structured reporting format for Form 1-CRYPTO.
Read the XBRL International analysis
Any decision to use XBRL rather than the proposed XML format would depend on the SEC’s consideration of public comments and the requirements ultimately adopted in a final rule.
What Happens Next?
Regulation Crypto Assets remains a proposed rule and is not yet a final SEC requirement.
The proposal was published in the Federal Register on August 21, 2026, and the public comment period is open until October 20, 2026. The SEC may modify the requirements before adopting any final rules.
View the SEC rulemaking page and comment information
For regulatory reporting teams, the proposal is worth monitoring as the SEC considers how structured data should be incorporated into the new crypto asset reporting framework.
Preparing for Evolving SEC Structured Reporting Requirements
SEC filing requirements continue to evolve as new forms, reporting formats, taxonomies, validation requirements, and structured data specifications are introduced.
Ez-XBRL’s Integix digital and regulatory reporting platform supports organizations preparing structured regulatory filings, while XOR Review provides collaborative review and validation capabilities for XBRL and Inline XBRL reporting.
Organizations can also use Ez-XBRL’s managed XBRL reporting services for additional support across SEC and other regulatory reporting requirements.
As the SEC considers feedback on Regulation Crypto Assets, Ez-XBRL will continue to track developments relating to Form 1-CRYPTO, EDGAR structured reporting, and any potential future implications for XBRL reporting.
FAQs
Is Form 1-CRYPTO an XBRL filing requirement?
No. Under the SEC’s current proposal, Part I of Form 1-CRYPTO would use form-specific XML. XBRL is not currently mandated.
What is Form 1-CRYPTO?
Form 1-CRYPTO is a proposed SEC filing form for issuers relying on the proposed fundraising exemption under Regulation Crypto Assets.
Will Form 1-CRYPTO be filed through EDGAR?
Yes. The SEC proposes that filings under the fundraising exemption be submitted electronically through EDGAR. For Part I of Form 1-CRYPTO, issuers could either use the SEC-provided fillable web form or use their own software, including a third-party filing solution, to prepare and submit the required XML directly to EDGAR.
Could the SEC require XBRL for Form 1-CRYPTO in the future?
Potentially. The SEC has requested feedback on whether a different structured data language should be used, and XBRL US has indicated that it plans to recommend XBRL.
Is Regulation Crypto Assets already in effect?
No. It is currently a proposed rule and may change before any final requirements are adopted.
Stay ahead of evolving SEC structured reporting requirements.
