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  • Writer's pictureMarco Zawar MBA (VWA)/ LLM (MCI, FSFM)

CRS amendments to be implemented by Financial Institutions by 2026

Updated: Nov 21

On Saturday I published a concerning the Commitment of "48 OECD Jurisdictions to Implement the Crypto Asset Reporting
Framework by 2027".

In the post it is briefly mentioned, that “the joint statement also commits applicable jurisdictions, to implement the amendments to the current Common Reporting Standard (CRS) to the same timeline”.

This post highlights the amendments to be considered by Reporting Financial Institutions (RFIs) to stay compliant with CRS.

New Products to be considered

The amendments bring certain electronic money products, central bank digital currencies, and indirect investments in crypto-assets through derivatives and investment in the scope of CRS.

Additional Information on Controlling Persons

Starting in 2027, RFIs must provide more detailed information on Controlling Persons' roles, allowing tax authorities to distinguish between those with ownership, control, or beneficiary interests, and those with managerial roles.

Enhanced information about Pre-Existing and new accounts

RFI’s shall furthermore provide information on whether a valid investor's self-certification has been obtained from pre-existing and new account holders. This information will help the tax authorities obtain information on the quality of the existing CRS due diligence procedures and on the reliability of the account information provided. 
Information to be provided related to jointly held accounts
The tax authorities expect the RFI to report information on whether the account is a joint account, and if yes to provide the number of joint account holders. 
Information about the Financial Account Type

RFIs are required to provide information that allows the distinction between Depository Accounts, Custodial Accounts, Equity and debt Interests, and Cash Value Insurance Contracts. The information provided allows the tax administrations a better understanding of the financial investments held/made by their taxpayers.
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