CRS2 Reporting
CRS2 is the updated OECD Common Reporting Standard, implemented in the EU through DAC8. It requires reporting financial institutions including banks, PIs, and EMIs to enhance tax transparency.
Under CRS2, firms must capture and validate customer tax residency at onboarding, monitor changes in circumstances, and submit an annual return reporting relevant account data in XML format.
The regime expands scope to cover newly in-scope e-money and digital products, strengthens due diligence requirements, and ensures more complete and accurate tax residency reporting.
What’s the scope?
Entities in scope
Reporting financial institutions under CRS include banks, PIs and EMIs where product meets CRS “financial account” test.
Activity
Offering CRS financial accounts (if customers can hold stored value like an account assume it’s reportable)
Nexus
Account holder tax residency (global) – you may need to report non-EU tax residents too, because CRS is a global AEOI standard (e.g. an Irish EMI may report Canadian tax resident customer under CRS.)
Deadline
Collect data from 1 Jan 2026. Submit in 2027 (exact deadline set by each member state)
Reporting frequency
Annual reporting
File format
Generate XML using the OECD schema and submit it to your local EU member state tax authority.
Data fields needed
Accounts: Account ID/ref, product type, open/close status, reportable balance/value (year-end) and reportable income (where applicable)
- Individuals: Name, address, DOB (and POB where required), tax self-cert, all tax residences + TIN per country (or reason if unavailable)
- Corporates: Entity name, address, tax self-cert + entity CRS classification, plus controlling persons (name, address, DOB, tax residences + TINs) where required
Reporting considerations to keep in mind
2026 is the "data year"
Firms must collect customer and account data in line with CRS2. You may need to update onboarding forms and expand data capture.
2027 is the “reporting year”
Firms must report using the new CRS2 standards, relying on the data collected in 2026.
Steps to submission
A step-by-step overview of how to implement CRS2 requirements across classification, data capture, monitoring, and reporting.
Confirm scope
Classify accounts/wallets to identify which are CRS-reportable accounts.
Fix onboarding
Capture all tax residences + self-cert + TIN per country (or reason if missing) from day one.
Ongoing monitoring
Cross-check tax data vs KYC and track changes in circumstances that might prompt you to ask the customer to refresh their tax info.