Understanding Common Reporting Standard Amendments Coming in 2026

CRS Amendments Coming in 2026

The Common Reporting Standard (CRS), developed by the Organisation for Economic Co-operation and Development (OECD), is a global standard for the automatic exchange of financial account information between jurisdictions. Since its inception in 2014, the CRS has played a crucial role in combating tax evasion and promoting tax transparency worldwide.

In response to evolving financial landscapes and emerging technologies such as crypto assets, the OECD has introduced significant amendments to the CRS, set to take effect on January 1, 2026. These amendments aim to enhance the scope and effectiveness of the CRS by incorporating new financial products, expanding definitions, and introducing additional reporting requirements. They are also intended to align with the new Crypto Asset Reporting Framework (CARF) which is a new reporting guideline for crypto related transactions.

Below are some questions we are hearing, and the answers to help you understand these upcoming changes.

What are the key changes to CRS effective from January 1, 2026?

The main amendments include:

• Inclusion of New Financial Products: The definition of Depository Accounts now encompasses electronic money (e-money) and Central Bank Digital Currencies (CBDCs). Entities holding e-money or CBDCs for customers will be classified as Depository Institutions under the CRS and account holders should be classified as having a Specified Electronic Money Product account.
• Expanded Definition of Investment Entities: The definition now includes entities investing in crypto assets:
  • Crypto-asset derivatives are considered Financial Assets
  • Certain assets that qualify both as relevant crypto assets under CARF and as financial assets under the CRS (e.g. shares issued in crypto form), CRS contains an optional provision to switch-off gross proceeds reporting under CRS if such information is reported under CARF.
• New Reporting Requirements: Financial institutions must report additional data elements, such as:
  • Whether the account holder has provided a valid self-certification.
  • If the account is held jointly, how many holders are there.
  • Whether the account is new or pre-existing.
  • The type of account (e.g., Depository Account, Custodial Account, Cash Value Insurance Contract, or Equity and debt Interest).
  • The role of a reportable person holding an equity interest in an investment entity, like a controlling person.
• Excluded Accounts: Capital contribution accounts used temporarily for company setup or capital increases are now classified as Excluded Accounts for up to 12 months, provided safeguards are in place.
• Non-Profit Entities: Genuine non-profit entities can now be categorized as Non-Reporting Financial Institutions, subject to conditions and verification by tax authorities.

How will these CRS changes impact financial institutions?

Financial institutions will need to:

• Update their IT systems to accommodate new reporting requirements.
• Reassess client records and documentation to ensure the availability of new reportable information, particularly valid self-certifications.
• Enhance AML/KYC procedures to comply with updated due diligence requirements.
• Train staff on the new CRS amendments to ensure compliance.

Early preparation is crucial to ensure a smooth transition and minimize disruptions.

What steps should financial institutions take to prepare for these CRS changes?

To prepare for the CRS amendments, financial institutions should:

• Conduct Impact Assessments: Evaluate current practices against upcoming requirements to identify gaps in data collection or storage.
• Implement IT System Updates: Modify onboarding and reporting solutions to capture and report new data elements.
• Review Client Artifacts: Ensure all necessary information, such as valid self-certifications, is collected and up to date.
• Enhance Governance and Procedures: Establish clear policies to manage new reporting obligations.
• Provide Training: Offer targeted training on the CRS amendments to relevant staff.
• Engage in Ongoing Compliance Management: Regularly monitor compliance and industry best practices to make necessary adjustments.

By taking these steps, institutions can ensure they remain compliant with the updated CRS requirements.

When will the first reports under the amended CRS be due?

The amended CRS provisions come into effect on January 1, 2026, with the first reports due in 2027. Financial institutions should use the lead time to implement necessary changes to ensure compliance.

How do these CRS changes align with other international tax reporting frameworks?

The CRS amendments align with the OECD's Crypto-Asset Reporting Framework (CARF) and the EU's DAC8 directive. Both initiatives aim to enhance tax transparency, particularly concerning digital and crypto assets. This alignment ensures consistency across international tax reporting standards.

For more detailed information, financial institutions should consult the official guidance provided by the OECD and their relevant tax authorities.

How can TAINA help? 

The changing legislation around CRS 2.0 paired with the increased CRS enforcement seen around the world has further increased the risk for financial institutions. It is more important now than ever to address your financial institution’s CRS validation process. The TAINA Platform takes care of your CRS self-certification compliance in a seamless end-to-end process whilst maintaining an up to date, robust and detailed CRS ruleset. 

TAINA’s fully automated FATCA and CRS Validation Platform can help financial institutions lighten their compliance burden whilst improving efficiency, reducing cost, mitigating risk, and improving their overall customer and investor experience. 

Using our flexible and lightweight platform you can automate and streamline your FATCA and CRS validation process whilst ensuring you have good year-end data that will result in clean FATCA and CRS reporting to tax authorities all year round.

We would love to talk to you more about your current documentation validation process and how our award-winning FATCA and CRS Validation platform may add value to your organisation.

For more information on how our fully automated FATCA and CRS Validation platform can add value to your business, get in touch or request a demo to see it in action.