Crypto Record-Keeping in the UK: What to Keep for Executors, Accountants and HMRC

Practical guidance on what crypto records to maintain, how to organise evidence packs, and what retention periods make sense — for executors, accountants, and HMRC compliance.

What records matter

For crypto held in the UK, record-keeping serves three purposes: proving what you own (for estate planning and probate), calculating tax obligations (Capital Gains Tax, Income Tax, Inheritance Tax), and demonstrating compliance (for HMRC enquiries). Essential records include: acquisition details (date, amount, cost basis, source of funds), disposal details (date, amount, proceeds, recipient), wallet addresses used for each transaction, exchange statements and correspondence, staking/lending/DeFi activity records, and airdrops or forks received. The challenge is that blockchain records alone are not enough — you need off-chain context to prove ownership and calculate tax.

Wallet and exchange evidence packs

An evidence pack for each wallet or exchange should include: account registration confirmation, identity verification records, deposit and withdrawal history, trade history with dates and values, wallet addresses associated with the account, any correspondence with customer support, and screenshots of balances at key dates (year-end, date of death for estates). For self-custody wallets, document: wallet type and software/hardware used, wallet addresses and their purpose, transaction history (exported from wallet or blockchain explorer), and any labelling or notes about transactions. This creates a clear chain of evidence linking you to your holdings.

Audit trail for estate planning

For inheritance purposes, the evidence pack should demonstrate: what wallets exist and their approximate holdings, who has knowledge of or access to each wallet, what recovery arrangements are in place, and the chain of authority for acting on the estate. This is separate from tax records — it's about proving what exists and how it can be accessed. A Policy Pack maintained with Bitzo includes this audit trail, with version history showing when documentation was created and updated. Learn more about our documentation approach.

Retention periods: practical guidance

HMRC can enquire into tax returns for up to 4 years (standard), 6 years (careless errors), or 20 years (deliberate non-compliance). For crypto, practical guidance suggests: retain acquisition records indefinitely (you'll need cost basis for future disposals), retain disposal records for at least 6 years after the tax year, retain estate-related records for at least 6 years after administration completes, and keep backups in multiple locations (cloud, physical, with trusted contacts). This is not legal advice — consult a tax adviser for your specific situation. The key principle is: when in doubt, keep the record.

How Bitzo fits

Bitzo creates and maintains comprehensive documentation for crypto security and inheritance planning. Our Policy Packs include: wallet inventory and evidence packs, trusted contact verification records, recovery workflow documentation, and full audit trails of all coordination activities. This documentation supports both estate administration and compliance requirements — without Bitzo ever holding keys or providing tax advice. Contact us to discuss how we can help you maintain proper records or explore our crypto inheritance planning page for more detail.

Frequently Asked Questions

Do I need to keep records of every small transaction?

For tax purposes, yes — every disposal is potentially taxable. Automated tracking tools can help, but ultimately you need records that allow you to calculate gains and losses accurately.

What if I've lost some historical records?

Reconstruct what you can from blockchain explorers, exchange statements, and bank records. Document your methodology. Consult a tax adviser for guidance on handling gaps.

How should I store sensitive records like wallet addresses?

Securely — encrypted storage, access controls, and backups. Wallet addresses alone don't give access to funds, but they can reveal holdings and transaction history.

Does HMRC have access to exchange records?

HMRC has used information powers to obtain customer data from UK exchanges. Assume that exchange-held activity is visible to HMRC and plan your record-keeping accordingly.

What records do executors need from me?

Executors need: evidence of what wallets exist, approximate values, access arrangements, and authority documentation. They don't need your private keys in advance — they need to know where to find them when the time comes.

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