The Call That Wasn't About a Vacancy

A finance director we placed a couple of years back rang the office last week, and for once it had nothing to do with a role.

She wanted to know if we'd seen the HMRC crypto figures. We hadn't, not at that point. Once we had, it was obvious why she'd rung someone she trusts rather than her own accountant first.

The numbers HMRC published are the first proper look at what UK crypto investors actually declared. Buried inside them is a bigger story about who is ready for what happens next, and who properly isn't.

What Did HMRC's First Crypto Tax Data Actually Show?

In the 2024/25 tax year, 17,600 people declared capital gains tax on crypto disposals, totalling £13.8 billion in proceeds and £1.38 billion in gains. Average declared gain per filer worked out at £78,000, though that figure hides a lot.

Just 240 filers, 1.4% of the total, accounted for more than half of everything declared between them, £717 million. The 11,440 smallest filers made up 65% of the group and barely 7% of the money.

Men made up 87% of the crowd, against 56% for standard capital gains filers, and it skewed younger too, with 81% under 54.

And HMRC's earlier compliance letters had already pulled in £168 million in extra revenue before this data was even published. You can read the fuller breakdown in Accountancy Age's analysis of the release.

None of that is really the headline. The headline is what changes from 2027.

Why Does This Become a Finance Hiring Problem and Not Just a Tax One?

Because from 2027, under the Crypto-Asset Reporting Framework, HMRC gets automatic data straight from exchanges and custodians about what UK residents actually hold and trade. That closes the gap between what gets declared and what HMRC already knows, and it means a business needs someone senior enough, and curious enough, to spot that kind of shift coming before it turns into an enquiry letter.

Platforms that don't comply face fines of up to £300 per user, so the incentive to report accurately sits with the platform as much as the individual. James Murray, the Financial Secretary to the Treasury, made the government's position plain. Tax is due on crypto assets under the same principles as any other capital gain, no special treatment, no grey area, no benefit of the doubt.

Our client had already worked that out for herself, before her own accountant flagged it. She wasn't ringing in a panic about her own tax position. What she actually wanted to know was whether her finance team, and one particular finance manager in it, had the judgement to spot exposure like this before HMRC's data-matching found it for them.

A Compliance Function Built for Filing, Not for Watching

Most finance functions we come across were built to close the books and file the return on time. That's still most of the job, most of the time, and there's nothing wrong with it as a baseline.

But a business with directors, senior staff or even long-standing shareholders who've dabbled in crypto now has a live compliance question sitting somewhere in its accounts. Someone needs to be curious enough, and senior enough, to go looking for it rather than wait for a letter to arrive.

Spotting that isn't really a bookkeeping skill.

It sits closer to leadership. We see the gap most clearly at financial controller and finance director level. A controller who only reconciles what's already been declared will miss this every time, because by definition it isn't in the numbers they're checking. One who asks sharper questions of the board, who's properly curious about what sits off the standard reporting lines, generally won't.

What Does A Compliance-Literate Finance Hire Actually Look Like?

It's rarely about deep technical crypto knowledge. But very few businesses need someone who can price a DeFi position either.

What they need is a financial controller or finance director who treats regulatory change as part of the job rather than an interruption to it. Someone who reads something like the CARF rollout and immediately asks who on the board or in the senior team it might touch, rather than filing the story away as somebody else's problem.

Interviewing for that instinct is surprisingly hard. CVs don't show it. Most candidates can talk fluently about the technical side of a finance role and go quiet the moment you ask what they'd have done differently on something like this, a year before it became urgent.

Where This Bites Hardest

Owner-managed businesses feel this more than most. A £30 million turnover manufacturer with a finance director who's been there fifteen years often has less structured oversight of directors' personal financial arrangements than a listed company with a compliance department three layers deep.

Not a criticism. Just how smaller, founder-led businesses tend to work. The finance function grows to match the size of the problems it's already solving, and a problem like CARF hasn't existed before, so nobody built for it.

Or a family business where a couple of directors have quietly built up crypto positions over the past five years, entirely legally, and you've got exactly the kind of exposure that sat invisible until now. From 2027 it won't stay invisible.

What This Means If You're Hiring Right Now

If you're looking at your finance team and can't honestly say who would have caught this before the letters start landing in 2027, it's worth taking seriously.

It doesn't mean panic-hiring a specialist tax manager tomorrow morning. For most of the businesses we work with, it means making sure the next financial controller or finance director you bring in has real advisory instinct, not just technical competence with the numbers you already know about.

And it means being honest about whether your current team has the seniority, or the headroom, to go looking for problems nobody's flagged for them yet.

Assessing that in an interview is much harder than checking whether someone can close a set of month-end accounts. But it's the difference that actually shows up three years later, usually at the worst possible moment.

Getting Ahead of It Rather Than Reacting to It

We've written before about the part of the accountant shortage most recruiters miss, and this is really the same problem wearing a different coat.

Scarcity alone doesn't make a finance hire valuable. Spotting what's coming before it lands does, and that's a different skill entirely to processing what's already happened.

If reading HMRC's numbers made you think of a gap in your own finance leadership, it's a conversation worth having before 2027, not after. We work across finance recruitment at financial controller, finance director and interim CFO level, and we'd rather talk to you now, while there's no fire to put out, than take the call once one has already started.

And if you're a finance professional reading this and recognising yourself as the sort who'd have spotted this early, it's worth a look at what's currently live on our jobs page.