You are correct that there will be activity that will not be reported on the new form. Understanding Your Form 1099-DA states:
For 2025, the Form 1099-DA filing requirements generally apply to U.S. brokers. This means that taxpayers transacting with foreign brokers, such as exchanges based outside the United States, may not receive a Form 1099-DA from that foreign broker. Any taxable transactions using foreign brokers must still be reported on your tax return.
We will learn more about how these transactions will be reported as the 1099-DA form implementation is rolled out.
@Ulianovsky
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