These amendments, finalised in 2023 and effective from 1 January 2026 in most jurisdictions, will impact the information financial institutions (FIs) collect in 2025 and exchange in 2026–2027.
The new framework aims to close emerging gaps in global reporting, especially those linked to digital assets, multi-jurisdictional residency, and residence-by-investment (RBI/CBI) schemes, while improving the accuracy and usefulness of exchanged data.
1. A Broader Scope: Inclusion of Digital Assets and E-Money
CRS 2.0 formally expands the definition of Financial Institutions and Financial Accounts to include emerging digital asset classes.- Electronic Money and CBDCs:
Digital wallets, central bank digital currencies (CBDCs), and other Specified Electronic Money Products are now treated as Depository Accounts under CRS. Providers of such products, often fintechs and payment firms, will fall within the definition of a Depository Institution. Low-risk e-money accounts under a de minimis balance (e.g. under USD 10,000 over 90 days) may be excluded. - Crypto-Asset Investments:
The definition of a Financial Asset now covers interests in Relevant Crypto-Assets, such as units in crypto funds or derivatives referencing crypto. Funds, trusts, or investment vehicles holding crypto will qualify as Investment Entities, requiring CRS registration and reporting.
2. Strengthened Due Diligence and Self-Certification Rules
The revised CRS places renewed emphasis on the validity and plausibility of self-certifications and aligns verification duties more closely with AML/KYC standards.
Multiple Tax Residencies
From 2026 onwards, all jurisdictions of residence must be reported for dual or multi-resident account holders. The old “tie-breaker” approach based on tax treaties will no longer apply. FIs must report each declared tax residency.
High-Risk CBI/RBI Schemes
Financial institutions must perform enhanced due diligence when account holders claim residency in jurisdictions identified as high-risk under OECD’s CBI/RBI guidance.
If doubts arise, the FI must ask additional questions—such as whether the individual:
If doubts arise, the FI must ask additional questions—such as whether the individual:
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spent more than 90 days in another country, or
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filed a tax return elsewhere during the year.
These questions, newly included in the OECD’s model self-certification form, are due diligence tools only, not reportable data. Their purpose is to verify the accuracy of the declared tax residencies.
If inconsistencies remain unresolved, the FI must obtain an updated self-certification or report the account as potentially linked to multiple jurisdictions.
If inconsistencies remain unresolved, the FI must obtain an updated self-certification or report the account as potentially linked to multiple jurisdictions.
TIN Collection
Institutions must make ongoing efforts to obtain missing Tax Identification Numbers (TINs) whenever client information is updated—not only in the first two years after account opening.
3. Clarified Entity Classifications and New Exemptions
The OECD has refined several definitions to ensure consistency and prevent circumvention:
- Depository Institution: Now explicitly includes fintech and payment service providers managing e-money or CBDCs.
- Investment Entity: Broadens to include entities investing in crypto-assets on behalf of others.
- Active vs Passive Entities: Clarified to ensure entities licensed for financial activities (e.g. certain fintechs) are properly classified as financial institutions.
- Non-Profit Carve-Out: Jurisdictions may now exempt qualifying non-profit organisations as Non-Reporting Financial Institutions, provided they meet strict criteria to avoid misuse.
4. New Data Fields in CRS Reporting (XML Schema v4.0)
To enhance the quality and context of exchanged information, the OECD has added several mandatory fields to CRS filings.These apply to all accounts reported for the 2026 period onward.
| New Reporting Field | Purpose / Description |
| Account Tenure | Indicates whether the account is Pre-existing or New under CRS timelines. |
| Self-Certification Status | Flags whether a valid self-certification is on file. |
| Joint Account Indicator | Specifies if an account is joint and how many holders exist. |
| Account Type | Clarifies whether it is a Depository, Custodial, Insurance, Annuity, or Equity/Debt Interest account. |
| Controlling Person Role | Identifies the nature of the controlling person (e.g. settlor, trustee, beneficiary, director). |
| Source of Self-Certification | Specifies whether tax residency data came from the individual or via an entity’s controlling person. |
These data points provide tax authorities with richer context, helping detect shared accounts, intermediated holdings, and beneficial ownership chains.
Financial institutions will need to update internal data capture forms, onboarding questionnaires, and IT systems to collect these elements systematically.
5. Updated Self-Certification Forms (2023)
The OECD’s revised model self-certification forms (2023 edition) include expanded questions designed to test the credibility of declared tax residencies—especially for clients with residence-by-investment links.Key additions:
- Questions on time spent (over 90 days) in other jurisdictions.
- Questions on foreign tax filings in the past year.
This strengthens the “reasonableness test” and helps prevent misuse of investment residency programs to obscure true tax residency.
6. Implementation Timeline and Transitional Measures
Most jurisdictions aim to implement CRS 2.0 by 1 January 2026, with the first exchanges due in 2027 for 2026 data. However, adoption dates may vary across jurisdictions, depending on legislative progress.
Key Milestones
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October 2024: OECD released the new CRS XML Schema (v4.0) and updated User Guide.
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2025: FIs must adapt data systems and forms for compliance.
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1 January 2026: New definitions, data fields, and due diligence rules take effect.
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June-September 2027: First exchanges of 2026 data under CRS 2.0.
Transitional Relief
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Controlling Person Roles: Transitional period for accounts open before 31 December 2025, if data on controlling person roles are not electronically available, reporting can be deferred until 2028.
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Dual-Residence Rule: Until end-2025, tie-breaker rules may still apply; from 2026, all residencies must be disclosed.
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Exceptional Procedure: For new accounts lacking a self-cert at reporting time, FIs may use AML/KYC data temporarily to report while obtaining the form.
These transitional measures are designed to ease operational rollout without undermining compliance expectations. Monaco
Brief country CRS 2.0 adoption summary for selected jurisdictions
Monaco has formally adopted CRS 2.0 by signing a protocol with the EU in October 2025, aligning its reporting obligations with the amended OECD standard. The updated rules take effect from 1 January 2026, covering financial account data collected throughout 2026. Uniquely, Monaco’s first CRS 2.0 exchange will occur in 2026, not 2027, because it will report on 2025 data, making it an early adopter. The protocol incorporates key changes such as reporting of digital assets, enhanced due diligence for self-certification, and the inclusion of fintech and e-money providers as financial institutions. While no local transitional guidance has been issued, Monaco is expected to follow OECD standards, allowing a grace period for reporting certain new data fields if not electronically available. Financial institutions must ensure systems and forms are updated in 2025 to collect the new data in 2026, with reporting obligations using the new XML schema (v4.0) starting that same year.
See our article here on the adoption process in Monaco https://rosemont-int.com/en/article/news/monaco-and-the-eu-strengthen-tax-transparency-with-a-new-protocol
Mauritius is expected to adopt CRS 2.0 in alignment with the global implementation timeline, although formal legislation is pending. As a participant in the OECD’s Crypto-Asset Reporting Framework (CARF), Mauritius has committed to implementing both CARF and the revised CRS by 1 January 2026. Financial institutions will need to start collecting the expanded data points, such as account type, self-certification status, and crypto-linked holdings, from the start of 2026. The first CRS 2.0 reports are anticipated to be filed in 2027, covering the 2026 calendar year. While local transitional guidance is not yet issued, Mauritius is expected to follow OECD norms, allowing flexibility on certain data elements not readily available in existing records. The Mauritius Revenue Authority (MRA) is preparing updates to the CRS reporting portal and guidance materials, and the CRS XML Schema v4.0 will be adopted for 2027 filings. FIs should proactively update onboarding and compliance systems throughout 2025 to ensure readiness.
Malta. As an EU Member State, Malta will implement CRS 2.0 through the transposition of DAC8 by 31 December 2025, making the amended rules effective 1 January 2026. Financial institutions in Malta must collect new data fields, such as controlling person roles, account type, and self-certification flags, throughout 2026. The first CRS 2.0 reports will be filed by 30 June 2027, in accordance with EU timelines. Malta’s Commissioner for Revenue is expected to issue updated guidance and validation rules aligned with OECD commentary and EU-level clarifications. While detailed transitional guidance is pending, Malta will likely allow relief for certain fields (e.g. controlling person roles) if not in searchable electronic form for pre-2026 accounts. Reporting institutions should ensure systems are updated to adopt the OECD’s amended XML Schema (v4.0) and that due diligence processes are enhanced to capture tax residency risks, including Citizenship/Residence by Investment indicators. Preparation in 2025 is essential for full compliance in 2026.
Singapore has committed to adopting CRS 2.0 and has signed the amended CRS Multilateral Competent Authority Agreement (MCAA). However, it has opted for a longer runway: the new rules will take effect on 1 January 2027, with financial institutions beginning to collect the additional data throughout that year. The first CRS 2.0 reports will be filed in 2028, covering 2027 data. Singapore’s Inland Revenue Authority (IRAS) plans to issue updated legislation, e-Tax guides, and XML schema user manuals ahead of the transition. No transitional relief or mandatory steps have been imposed yet, but IRAS encourages financial institutions to begin internal system upgrades and form revisions now. Singapore will adopt the OECD’s amended XML Schema (v4.0) for the 2028 reporting cycle. FIs should use 2025–2026 to update client onboarding forms, improve self-certification review processes, and prepare for enhanced due diligence, particularly for clients linked to CBI/RBI jurisdictions or digital assets.
Hong Kong is preparing to adopt CRS 2.0 by 1 January 2026, with the first CRS reports under the revised framework due in 2027 for the 2026 reporting year. While formal legislative amendments are expected in 2025 to update the Inland Revenue Ordinance, Hong Kong has already confirmed its commitment to implementing the OECD’s updated standard. Financial institutions will need to start collecting expanded CRS data, including joint account indicators, self-certification flags, and digital asset-related information, from 2026 onward. The Hong Kong Inland Revenue Department (IRD) will update its AEOI guidance and XML schema validation rules in line with the OECD’s CRS v4.0 schema. Although Hong Kong hasn’t issued transitional guidance yet, it is expected to follow OECD recommendations allowing flexibility on certain fields for pre-existing accounts until 2028. FIs should upgrade onboarding systems and train compliance staff in 2025 to ensure data collection procedures are fully aligned with CRS 2.0 standards starting 2026.
See our article here on the adoption process in Monaco https://rosemont-int.com/en/article/news/monaco-and-the-eu-strengthen-tax-transparency-with-a-new-protocol
Mauritius is expected to adopt CRS 2.0 in alignment with the global implementation timeline, although formal legislation is pending. As a participant in the OECD’s Crypto-Asset Reporting Framework (CARF), Mauritius has committed to implementing both CARF and the revised CRS by 1 January 2026. Financial institutions will need to start collecting the expanded data points, such as account type, self-certification status, and crypto-linked holdings, from the start of 2026. The first CRS 2.0 reports are anticipated to be filed in 2027, covering the 2026 calendar year. While local transitional guidance is not yet issued, Mauritius is expected to follow OECD norms, allowing flexibility on certain data elements not readily available in existing records. The Mauritius Revenue Authority (MRA) is preparing updates to the CRS reporting portal and guidance materials, and the CRS XML Schema v4.0 will be adopted for 2027 filings. FIs should proactively update onboarding and compliance systems throughout 2025 to ensure readiness.
Malta. As an EU Member State, Malta will implement CRS 2.0 through the transposition of DAC8 by 31 December 2025, making the amended rules effective 1 January 2026. Financial institutions in Malta must collect new data fields, such as controlling person roles, account type, and self-certification flags, throughout 2026. The first CRS 2.0 reports will be filed by 30 June 2027, in accordance with EU timelines. Malta’s Commissioner for Revenue is expected to issue updated guidance and validation rules aligned with OECD commentary and EU-level clarifications. While detailed transitional guidance is pending, Malta will likely allow relief for certain fields (e.g. controlling person roles) if not in searchable electronic form for pre-2026 accounts. Reporting institutions should ensure systems are updated to adopt the OECD’s amended XML Schema (v4.0) and that due diligence processes are enhanced to capture tax residency risks, including Citizenship/Residence by Investment indicators. Preparation in 2025 is essential for full compliance in 2026.
Singapore has committed to adopting CRS 2.0 and has signed the amended CRS Multilateral Competent Authority Agreement (MCAA). However, it has opted for a longer runway: the new rules will take effect on 1 January 2027, with financial institutions beginning to collect the additional data throughout that year. The first CRS 2.0 reports will be filed in 2028, covering 2027 data. Singapore’s Inland Revenue Authority (IRAS) plans to issue updated legislation, e-Tax guides, and XML schema user manuals ahead of the transition. No transitional relief or mandatory steps have been imposed yet, but IRAS encourages financial institutions to begin internal system upgrades and form revisions now. Singapore will adopt the OECD’s amended XML Schema (v4.0) for the 2028 reporting cycle. FIs should use 2025–2026 to update client onboarding forms, improve self-certification review processes, and prepare for enhanced due diligence, particularly for clients linked to CBI/RBI jurisdictions or digital assets.
Hong Kong is preparing to adopt CRS 2.0 by 1 January 2026, with the first CRS reports under the revised framework due in 2027 for the 2026 reporting year. While formal legislative amendments are expected in 2025 to update the Inland Revenue Ordinance, Hong Kong has already confirmed its commitment to implementing the OECD’s updated standard. Financial institutions will need to start collecting expanded CRS data, including joint account indicators, self-certification flags, and digital asset-related information, from 2026 onward. The Hong Kong Inland Revenue Department (IRD) will update its AEOI guidance and XML schema validation rules in line with the OECD’s CRS v4.0 schema. Although Hong Kong hasn’t issued transitional guidance yet, it is expected to follow OECD recommendations allowing flexibility on certain fields for pre-existing accounts until 2028. FIs should upgrade onboarding systems and train compliance staff in 2025 to ensure data collection procedures are fully aligned with CRS 2.0 standards starting 2026.
7. Compliance and Operational Implications
The CRS 2026 update will require comprehensive operational alignment across compliance, IT, and client-onboarding teams.Key actions for FIs:
- Update onboarding and self-certification forms to align with new OECD models.
- Map and capture new reportable fields in client databases and reporting systems.
- Enhance due diligence frameworks to include CBI/RBI risk questions and 90-day/tax filing checks.
- Train compliance staff to identify and resolve inconsistent or incomplete tax residency claims.
- Review non-profit and fintech client classifications to apply the correct CRS entity definitions.
- Conduct system testing using OECD’s XML Schema v4.0 well before 2026 reporting starts.
8. Broader Significance: CRS 2.0 and the Future of Tax Transparency
The CRS amendments mark a strategic evolution in global tax transparency:- Bridging the gap between traditional finance and digital assets;
- Aligning due diligence with AML/KYC expectations;
- Ensuring multi-residency transparency and better identification of beneficial owners;
- Improving the data quality of exchanged information to support tax authorities’ risk assessments.
9. Practical Guidance for Financial Institutions and Advisors
For banks, wealth managers, trust and corporate service providers, and family offices, the months ahead are a crucial preparation window.Practical steps include:
- Gap Analysis: Identify where current data systems or client files lack the new mandatory fields.
- Policy Updates: Revise CRS manuals, onboarding checklists, and escalation protocols.
- Communication with Clients: Notify clients of upcoming changes and the need for refreshed self-certifications by 2026.
- Coordination with IT and Vendors: Ensure reporting software is compatible with the new XML schema and controlled-person mapping fields.
- Documentation: Maintain written evidence of any due diligence performed in response to CBI/RBI indicators.
The OECD’s 2023-2026 CRS reforms represent a critical modernization of the global tax reporting ecosystem.
By integrating digital assets, tightening self-certification checks, and expanding data granularity, CRS 2.0 ensures that automatic exchange of information remains robust in a rapidly evolving financial landscape.
For financial institutions, these changes demand proactive system upgrades, renewed client engagement, and enhanced compliance oversight.
Those who prepare early, updating procedures, retraining teams, and testing new reporting formats, will be best positioned to ensure compliance and maintain the trust of regulators and clients alike.
Rosemont International assists financial institutions, trust companies, and private clients worldwide in adapting to evolving cross-border reporting standards.
Our compliance and structuring teams can help review your CRS policies, update self-certification frameworks, and ensure readiness for the 2026 exchange cycle.
For more information, contact our CRS & Tax Transparency team at Rosemont International: consulting@rosemont.mc
(Summary based on OECD CRS 2023–2025 updates and commentary, including official OECD guidance, CRS XML Schema v4.0, and publications by Carey Olsen, KPMG, PQS, and PwC.)