Bitkom generally agrees with the provided framework set out in the OECD’s public consultation for the development of the Crypto-Asset Reporting Framework and the Amendments to the Common Report Standard. However, Bitkom wants to raise awareness regarding some issues where the current draft needs clarification. For example, regarding the similar treatment of Crypto-Asset payments to cash payments and the need for proportionality. Further, we urge to create homogeneous reporting standards across different jurisdictions. Bitkom cautions to not implement too many pre-rules for different blockchains, which cannot feasibly be implemented by Reporting Crypto-Asset Service Providers.