Koinly Cost Basis: Complete Honest 2026 Per-Wallet Guide

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If your Koinly gains figures for 2025 look different from what you expected — or if you have heard about the new IRS per-wallet cost basis requirement and are not sure what it means for your account — this guide covers exactly what changed, why it matters, and what you need to do in Koinly to stay compliant.

I am Andreas Maratheftis — thirty years in professional finance — and Koinly cost basis tracking is one of the most consequential settings in your account. Getting it wrong for 2025 does not just affect your tax report. It can affect every calculation Koinly makes going forward.

This is a US-specific requirement. If you file crypto taxes outside the United States, the per-wallet tracking rule from IRS Revenue Procedure 2024-28 does not apply to you directly — though similar frameworks are emerging in other jurisdictions. Non-US investors should confirm their local cost basis requirements with a qualified tax professional.

If you have not yet set up Koinly and want to check your current cost basis position before making any changes, the free plan lets you see everything before purchasing: start with Koinly free here.

Koinly Cost Basis: Quick Answer

From 1 January 2025, US crypto investors can no longer rely on universal cost basis pooling for 2025 transactions and must track basis by wallet or account — this is the per-wallet cost basis rule under IRS Revenue Procedure 2024-28. Koinly has built a migration tool to handle this transition — it is in Settings → Cost basis → Migrations tab.

If you have not yet run the migration, your 2025 Koinly figures may be calculated under the old universal method, which is no longer permitted for 2025 transactions. Run the migration before filing your 2025 tax return. The safe harbor deadline for selecting your allocation method was 1 January 2025 — if you have not yet acted, consult a tax professional about your options before filing.

What Changed: Universal vs Per-Wallet Cost Basis

Before 2025, US crypto investors were permitted to track cost basis using a universal pool — treating all holdings of the same cryptocurrency across all exchanges and wallets as a single merged lot. Under FIFO applied universally, if you bought Bitcoin on Coinbase in January and on Binance in March, the universal method would treat the Coinbase purchase as the oldest lot regardless of which exchange you later sold from. The cost basis calculation ignored which wallet the asset physically sat in.

From 1 January 2025, the universal method is no longer permitted under IRS final regulations T.D. 10000. Each wallet or account must now be treated as an independent ledger. If you hold Bitcoin on Coinbase and on Binance, those are now two separate pools with separate cost basis records. A sale on Coinbase uses only the cost basis of Bitcoin held in your Coinbase account — not a blended average or a universally ordered lot from your entire portfolio.

Feature	Before 2025 (Universal)	From 2025 (Per-Wallet)
How holdings are pooled	All wallets combined into one pool	Each wallet or account is a separate pool
Example: BTC on Coinbase + Binance	Treated as one merged BTC pool	Treated as two separate BTC pools
Cost basis on sale from Binance	Calculated from combined portfolio history	Calculated only from Binance holdings
FIFO ordering	Applied across all wallets globally	Applied independently within each wallet
IRS status	No longer permitted from 2025 onwards	Required from 1 January 2025

This change has direct practical consequences. The same number of transactions can produce meaningfully different gain and loss figures under per-wallet tracking versus universal tracking, depending on how your assets are distributed across wallets and the price history of your acquisitions.

Worked Example: How the Rule Changes Your Gain Calculation

You bought 1 BTC on Coinbase in 2023 for $20,000. You bought another 1 BTC on Binance in 2024 for $40,000. In 2025, you sell the 1 BTC on Binance for $50,000.

Under the old universal method (FIFO across all wallets): Your oldest lot is the $20,000 Coinbase purchase. FIFO treats that as the lot sold. Capital gain = $50,000 − $20,000 = $30,000.

Under the new per-wallet method (FIFO within each wallet): The Binance wallet only has the $40,000 purchase. FIFO within Binance uses that lot. Capital gain = $50,000 − $40,000 = $10,000.

In this example the new rule actually produces a lower gain — because the higher-cost lot happened to be in the wallet you sold from. The result can equally go the other way depending on your portfolio structure. The key point is that the two methods can produce meaningfully different figures, and the universal method is no longer permitted for 2025 transactions regardless of which result it would produce.

The IRS Delay Only Applies to Brokers — Not to Taxpayers

One of the most common misunderstandings about the 2025 cost basis rule is the confusion between two separate announcements from the IRS. In late 2024, the IRS announced a delay in requiring exchanges and brokers to report cost basis on Form 1099-DA — cost basis reporting by brokers does not begin until transactions from 2026 onward. Many investors read this as meaning the per-wallet rule itself was delayed.

It was not. The delay applies only to broker reporting obligations — what exchanges must tell the IRS. The taxpayer’s obligation to use per-wallet cost basis tracking for their own returns has not been delayed. From 1 January 2025, US investors are required to track and report on a per-wallet basis regardless of what their exchange’s 1099-DA shows. Koinly’s own support team and IRS guidance confirm this distinction clearly. If you relied on the delay announcement to postpone your migration in Koinly, your 2025 figures may be calculated incorrectly.

The Safe Harbor Under Rev. Proc. 2024-28

Revenue Procedure 2024-28 also provides a safe harbor for investors transitioning from universal to per-wallet tracking. The safe harbor allows investors to make a reasonable allocation of their unused cost basis to specific wallets as of 1 January 2025 — effectively distributing their historical lot history across wallets in a defined, documented way — rather than requiring a perfectly reconstructed wallet-by-wallet purchase history going back to the beginning of their crypto activity.

To qualify for the safe harbor, investors need to meet several requirements confirmed in Rev. Proc. 2024-28:

• You must hold digital asset units and have unused basis as of 1 January 2025
• The allocation must be a reasonable allocation — documented clearly
• The safe harbor cannot be used for assets acquired or transferred on or after 1 January 2025 — it applies only to the transition of pre-existing holdings
• The allocation method must have been selected before 1 January 2025 — though Koinly confirmed the actual migration execution can be completed before you file your 2025 return
• You must maintain records showing how the allocation was made

Notice 2025-07 provides additional temporary relief for eligible taxpayers on adequate identification methods during a defined relief period. The safe harbor does not eliminate your recordkeeping obligations — it provides a practical method for allocating historical basis, but you must maintain clear documentation showing how the allocation was made and which method you selected.

If you are unsure whether the safe harbor or Notice 2025-07 relief applies to your specific situation, this is exactly the type of question that requires a qualified crypto tax professional’s review — the stakes of getting it wrong affect your entire 2025 filing.

How to Run the Koinly Cost Basis Migration

Koinly built a migration tool specifically for the Rev. Proc. 2024-28 transition. Before running the migration, download a copy of your current tax reports and transaction exports as a backup — this gives you a record of your pre-migration figures if you need to refer to them later. The migration converts your Koinly account from universal tracking to wallet-based tracking, applying the new per-wallet method to 2025 transactions onwards while keeping your pre-2025 calculations under the universal method.

The step-by-step process in Koinly:

1. Go to Settings in your Koinly account — the gear icon in the navigation.
2. Select the Cost basis section — this is where your cost basis method and tracking settings are managed.
3. Switch to the Migrations tab — this is separate from your cost basis method (FIFO/LIFO/HIFO) settings.
4. Create a new migration — set the migration date to 1 January 2025. This tells Koinly to apply universal tracking for all transactions before that date and wallet-based tracking for all transactions from that date onward.
5. Review the allocation method — Koinly currently supports one allocation method: Lowest Cost → Biggest Wallet. This assigns your lowest-cost tax lots to the wallets with the highest balances as of the migration date, on the assumption that higher-balance wallets are long-term holding wallets.
6. Download the allocation report — once the migration is active, you can download a report from the Migrations tab showing which lots were allocated to which wallets. Keep this report as part of your tax records — it documents the allocation method you used.

One important technical note confirmed by Koinly: the migration re-runs automatically whenever you add transactions to earlier years. If you continue adding or correcting pre-2025 transaction data after running the migration, the allocation will update to reflect those changes. The migration is also currently one-way — Koinly does not currently provide a supported way to revert from wallet-based tracking back to universal tracking after the migration is run.

Cost Basis Method vs Cost Tracking Method — An Important Distinction

Koinly has two separate settings that are often confused with each other, and understanding the difference is critical before making any changes.

Cost basis method (FIFO, LIFO, HIFO, OpHIFO) determines the order in which your lots are treated as sold when you make a disposal. FIFO sells the oldest lots first. HIFO sells the highest-cost lots first. This setting determines your gain or loss on each individual sale.

Cost tracking method (universal vs wallet-based) determines whether your lots are pooled across all wallets or tracked separately per wallet. This is the setting affected by Rev. Proc. 2024-28. The per-wallet requirement does not change which cost basis method you use — you can continue using FIFO, LIFO, or HIFO. It changes how the lots are pooled before that ordering is applied.

In practical terms: switching to wallet-based tracking does not force you to switch to FIFO. You can continue using HIFO under the new rules, applied per wallet rather than universally. Some investors have incorrectly assumed the per-wallet rule requires FIFO specifically — it does not. Confirm your preferred cost basis method is still set correctly in Koinly after completing the migration, and confirm with a tax professional that your chosen method is appropriate for your situation.

Why Your 2025 Koinly Figures May Look Different

If you have run the migration and your 2025 gains figures look significantly different from what you expected based on prior years, this is usually the migration working as designed rather than an error. Under per-wallet tracking, the cost basis of each disposal is determined only by what is in that specific wallet — not by your overall portfolio average or your globally oldest lots.

Common reasons 2025 figures may look higher than expected after migration:

• Lot history differs by wallet — if the wallet you sold from contains different acquisition lots than your overall portfolio, the gain can change significantly. A wallet containing lower-cost lots may show higher gains under per-wallet tracking; a wallet containing higher-cost lots may show lower gains. The result depends entirely on which lots are actually available inside the selling wallet — not your blended portfolio average.
• Missing transaction history on specific wallets — if Koinly has incomplete import history for a wallet, it may not have the full acquisition record for that wallet’s holdings, causing Koinly to assume a zero or estimated cost basis for some lots. This is a data completeness issue, not a migration error.
• The allocation method assigned lower-cost lots elsewhere — the Lowest Cost → Biggest Wallet allocation method places lower-cost lots in the wallets with the largest balances. If you sold from a smaller wallet, those lots may have been allocated higher costs under the migration, producing higher apparent gains.

If your figures look unexpectedly high, check your connected wallets for data completeness before assuming the migration result is wrong. See our guide on fixing wrong gains in Koinly and our guide on Koinly missing transactions for the step-by-step data resolution process.

What To Do Next

If you are a US investor and have not yet run the Koinly cost basis migration, do this before filing your 2025 return. Go to Settings → Cost basis → Migrations tab and create a migration with a date of 1 January 2025. Download and keep the allocation report. Review your 2025 transactions after the migration to confirm the figures look correct. If your gains look significantly different from what you expected, resolve any missing transaction data before purchasing a report.

If you are unsure whether the safe harbor applies to your specific situation, or if you have a complex portfolio with assets spread across many wallets and exchanges, this is the right time to engage a qualified crypto tax professional before filing. The per-wallet rule is new territory for most investors and the interaction with your specific lot history is genuinely complex.

For a complete overview of Koinly’s features, see our full Koinly review. For plan costs, see our Koinly pricing guide. For the 1099-DA reconciliation workflow, see our guide on Koinly and Form 1099-DA.

Start with Koinly free here — check your current cost basis position and review your 2025 figures before committing to any plan.

Frequently Asked Questions

What is the IRS per-wallet cost basis rule?

From 1 January 2025, IRS Revenue Procedure 2024-28 requires US crypto investors to track cost basis per wallet rather than using a single universal pool across all accounts. Each exchange account or wallet must now be treated as an independent ledger with its own separate cost basis history. The universal tracking method — where all holdings of the same cryptocurrency across all wallets were treated as a single merged lot — is no longer permitted for 2025 transactions and beyond.

How do I update my Koinly cost basis settings for the 2025 rule?

Go to Settings in your Koinly account, select the Cost basis section, and switch to the Migrations tab. Create a new migration with a date of 1 January 2025. Koinly’s migration tool applies universal tracking to all transactions before that date and wallet-based tracking from that date onward, using the Lowest Cost → Biggest Wallet allocation method to distribute your existing lots across wallets. Download the allocation report from the Migrations tab and keep it with your tax records.

Does the IRS cost basis delay mean I don’t need to migrate in Koinly?

No. The IRS delay announced in 2024 applies only to broker reporting obligations — the requirement for exchanges to report cost basis on Form 1099-DA. That reporting delay does not apply to taxpayers’ own obligations. US investors are still required to use per-wallet cost basis tracking for their own 2025 tax returns regardless of what their exchange’s 1099-DA shows. Koinly’s own support team confirmed this distinction explicitly.

What is the safe harbor under Rev. Proc. 2024-28?

The safe harbor allows eligible investors to make a reasonable allocation of their unused pre-2025 cost basis to specific wallets as of 1 January 2025, rather than reconstructing a perfect wallet-by-wallet purchase history. To qualify, the allocation must be reasonable and documented, you must have held digital assets with unused basis as of 1 January 2025, and the allocation method must have been selected before 1 January 2025. The safe harbor does not apply to assets acquired or transferred on or after 1 January 2025. Notice 2025-07 provides additional temporary relief during a defined period. Confirm whether the safe harbor applies to your situation with a qualified tax professional.

Does per-wallet tracking force me to use FIFO?

No. The per-wallet rule changes how your lots are pooled — per wallet rather than universally — but it does not change which cost basis method you use within each wallet. You can continue using FIFO, LIFO, HIFO, or OpHIFO applied on a per-wallet basis. The cost tracking method and the cost basis method are two separate settings in Koinly. Confirm your preferred cost basis method is still correctly set after completing the migration, and confirm with a tax professional that your chosen method is appropriate for your situation and the current IRS guidance.

Will the migration change my pre-2025 Koinly figures?

No. Koinly’s migration tool is designed to apply wallet-based tracking from 1 January 2025 onwards while keeping pre-2025 calculations under the universal method. Your historical tax figures for 2024 and earlier should not change as a result of running the migration. If your pre-2025 figures do change after migration, check whether you have added or modified pre-2025 transaction data recently — the migration re-runs automatically when transactions are added to earlier years.

Can I choose a different allocation method later?

This depends on whether you qualified for the safe harbor and what you documented before 1 January 2025. Rev. Proc. 2024-28 requires that the allocation method be selected before 1 January 2025, and IRS guidance indicates that taxpayers should not change the method they selected. Koinly currently supports only one allocation method — Lowest Cost → Biggest Wallet — so in practice there is no alternative method available within Koinly at this time. If you believe a different allocation method would better reflect your situation, discuss this with a qualified crypto tax professional before making any changes.

Does the Koinly cost basis per-wallet rule apply to non-US investors?

No. The per-wallet cost basis requirement from IRS Revenue Procedure 2024-28 is a US-specific IRS rule. Investors filing crypto taxes in the UK, Australia, Germany, or other jurisdictions use their local cost basis rules — UK share pooling, Australian FIFO, German FIFO — which Koinly applies automatically based on your home country setting. If you are a non-US investor, you do not need to run the per-wallet migration unless you file US taxes. Confirm your home country is correctly set in Koinly Settings to ensure the correct rules are applied to your account.

The Bottom Line

The IRS per-wallet Koinly cost basis rule is one of the most significant changes to US crypto tax reporting in years — and one of the most widely misunderstood. Universal tracking is gone for 2025 onwards. The broker reporting delay does not change your taxpayer obligation. If you have not yet run the migration in Koinly, do it before filing your 2025 return, download the allocation report, and review your figures for anything that looks unexpectedly different.

Complex portfolio situations — many wallets, years of mixed history, assets moved between exchanges at different price points — are exactly where professional review adds the most value. Koinly handles the mechanical transition. A crypto tax professional handles the judgment on whether your specific situation qualifies for the safe harbor and whether your allocation approach is defensible.

Ready to check your figures? Start with Koinly free here — review your 2025 cost basis position before purchasing any report.

Related reading:

• Koinly Form 1099-DA: The Honest 2026 Answer for Investors
• Does Koinly Report to the IRS? Honest Answer for Crypto Investors (2026)
• Koinly Showing Wrong Gains? How to Fix Cost Basis Errors
• Koinly Missing Transactions: Complete Fix Guide (2026)
• Koinly Review: Is It the Best Crypto Tax Software in 2026?