Guidance Notes on the Common Reporting Standard (CRS)

Summary

These are the ITA's Guidance Notes explaining how the Common Reporting Standard (CRS) operates in the Virgin Islands under the Mutual Legal Assistance (Tax Matters) Act, 2003 (as amended). The notes are not law themselves but explain registration, due diligence, reporting and other obligations imposed on Virgin Islands Financial Institutions (VIFIs) by the CRS law, and describe recent amendments (including a 2026 update, CRS 2.0, effective 1 January 2026) covering e-money, CBDCs and crypto-linked financial instruments.

• Who is covered: All Financial Institutions resident in the Virgin Islands (VIFIs), including custodial institutions, depository institutions, investment entities, specified insurance companies, and non-reporting financial institutions such as certain pension funds, government entities and exempt collective investment vehicles.
• Registration and reporting: VIFIs must register and report through the BVIFARs portal to the ITA, which acts as the Competent Authority; a NIL return must be filed where a VIFI has no reportable accounts.
• Wider approach due diligence: Due diligence procedures must be applied to all account holders, not just those resident in current Reportable Jurisdictions, though returns are only required for accounts held by Reportable Persons.
• Written policies and procedures: VIFIs are expected to maintain written CRS compliance policies and procedures.
• New residence rules (2026 amendment): A statutory definition of Virgin Islands residence for Financial Institutions has been introduced; VIFIs that are tax resident elsewhere must register in BVIFARs, disclose their jurisdiction of tax residence, and provide evidence they are meeting CRS obligations there to avoid duplicate filing.
• Scope expansion: Depository institution and investment entity definitions now capture specified e-money products, CBDCs, and indirect holdings of crypto-assets through derivatives or investment vehicles (CRS 2.0), ahead of the separate Crypto Asset Reporting Framework (CARF) expected in 2027/2028.
• Additional information filing: All VIFIs must file a CRS Additional Information Form via BVIFARs to help the ITA meet its compliance obligations.
• Undocumented accounts: Where residence cannot be confirmed for pre-existing individual accounts (only a hold-mail or in-care-of address found), the VIFI must follow prescribed search steps and, if unsuccessful, report the account as undocumented, applying enhanced review for high value accounts.

The Virgin Islands does not require local filing for BVI tax residents; the ITA is used as receiving jurisdiction only for NIL filings and undocumented accounts. The ITA notes it is developing a further compliance manual and has published a BVIFARs user guide.

Key obligations

• All VIFIs must register with the ITA via the BVIFARs portal and report information on Reportable Accounts, filing a NIL return where there are no reportable accounts.
• VIFIs must apply CRS due diligence procedures to all accounts under the wider approach, not limited to accounts held by residents of current Reportable Jurisdictions.
• VIFIs must maintain written policies and procedures for CRS compliance.
• VIFIs that are tax resident in another jurisdiction must register in BVIFARs, disclose that jurisdiction of tax residence in their authorisation letter, and provide evidence to the ITA that they are meeting CRS obligations (filings) there.
• All VIFIs must file a CRS Additional Information Form through BVIFARs within 9 months following the end of the relevant financial year.
• VIFIs must follow the prescribed search and reporting procedure for undocumented accounts where residence of a pre-existing individual account holder cannot be confirmed, and apply enhanced review to undocumented high value accounts.
• Central Banks that have declared NRFI status must review whether they still qualify as NRFIs following the 2026 amendment clarifying treatment of CBDC holdings.

Applies to

Virgin Islands Financial Institutions (VIFIs), Custodial Institutions, Depository Institutions, Investment Entities, Specified Insurance Companies, Non-Reporting Financial Institutions (including retirement/pension funds, government entities, exempt collective investment vehicles), Trusts acting as Financial Institutions

Deadlines

• within 9 months following the end of the relevant financial year: Deadline for VIFIs to file the CRS Additional Information Form via BVIFARs.
• 1 January 2026: Effective date of the 2026 amendment to the Common Reporting Standard (CRS 2.0) in the Virgin Islands.
• September 2025: Due date by which the first CRS Additional Information Form filings were required.