New Liabilities for Virtual Digital Asset Platforms

New Liabilities for Virtual Digital Asset Platforms

As digital assets become more mainstream, the Indian government has introduced stricter compliance requirements and legal liabilities for businesses dealing with Virtual Digital Assets (VDAs). These platforms include crypto exchanges, NFT marketplaces, custodial wallet providers, and VDA aggregators.

Effective FY 2025-26, the Ministry of Finance, through updates in Income Tax Act, Prevention of Money Laundering Act (PMLA), and other digital frameworks, has mandated that VDA platforms operate with the same regulatory discipline as traditional financial institutions.

This article outlines the new liabilities, reporting standards, penalties, and regulatory expectations for VDA platforms in India.


What Qualifies as a Virtual Digital Asset (VDA)?

As per the Finance Act, 2022, Virtual Digital Assets include:

  • Cryptocurrencies (e.g., Bitcoin, Ethereum, etc.)

  • Non-Fungible Tokens (NFTs)

  • Any digitally stored token of value not classified as legal tender or currency.

Key Liabilities Introduced for VDA Platforms in 2025

1. Mandatory TDS Compliance Under Section 194S

  • VDA platforms are required to deduct 1% TDS on all transactions involving transfer of VDAs, where consideration exceeds:

    • ₹10,000 per year (for individuals)

    • ₹50,000 per year (for specified persons or businesses)

  • Platforms must report TDS through Form 26Q/26QE and ensure timely payment to the government.

2. Inclusion under the Prevention of Money Laundering Act (PMLA)

  • As per the Ministry of Finance notification, VDA service providers are now treated as reporting entities under the PMLA.

  • They must follow:

    • KYC norms before onboarding customers

    • Suspicious Transaction Reporting (STR)

    • Record maintenance of user identities and transaction trails for at least 5 years

3. Annual Reporting Under Rule 114BA & Form 10AB

  • Platforms are required to furnish annual statements of VDA transactions under the Income Tax framework.

  • They must disclose transaction volumes, user data, consideration value, and wallet-to-wallet transfers.

4. Customer Due Diligence & Enhanced KYC

  • All users must undergo full PAN-based KYC with additional verification for large volume traders.

  • Transactions above ₹10 lakh require enhanced due diligence, including proof of source of funds.

5. VDA Wallet Monitoring

  • Platforms providing custodial wallets are liable for:

    • Ensuring security of digital wallets

    • Tracking and flagging blacklisted tokens or blockchain addresses

    • Disclosing wallet linkage to individuals/entities when requested by enforcement authorities.

6. Cross-Border Restrictions

  • Platforms facilitating cross-border VDA transactions must comply with FEMA provisions and FATF (Financial Action Task Force) guidelines.

  • Foreign transactions without regulatory clearance may attract penalties under FEMA and PMLA.

Penalties for Non-Compliance

Non-CompliancePenalty/Consequences
Failure to deduct TDSTax recovery + interest + ₹10,000 penalty
No KYC/AML Reporting₹1 lakh per failure + possible suspension
Non-filing of VDA transaction statements₹500/day late fees + prosecution possibilities
Ignoring wallet security or suspicious tradesEnforcement Directorate (ED) action under PMLA


Opportunities for VDA Platforms

With increased regulation comes enhanced legitimacy. Platforms that comply with the new rules can:

  • Build greater investor confidence

  • Gain access to institutional partnerships

  • Scale under well-defined legal frameworks

  • Stand out in the crowded VDA market through transparency and compliance


Conclusion

The year 2025 marks a new era of accountability for Virtual Digital Asset platforms in India. With stricter tax, AML, KYC, and compliance mandates, crypto exchanges and NFT platforms must evolve from tech-first startups to finance-compliant institutions.

Staying ahead of these regulatory shifts will not only protect platforms from penalties but also position them as trusted players in the future of digital finance.

For crypto platforms, compliance is no longer optional—it’s the cost of trust and survival.






Created & Posted by Pooja

Income Tax Expert at TAXAJ

 

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