Mandatory Adoption of CRS XML Schema 3.0 from 1 January 2027 (2026-10-16)

Summary

The British Virgin Islands International Tax Authority (ITA) has issued a notice to Reporting Financial Institutions (RFIs) confirming that the BVIFARS Portal will stop accepting CRS reports in older XML Schema formats from 1 January 2027. From that date, all CRS reports must be submitted using CRS XML Schema 3.0, reflecting the move to the Amended CRS already in effect in the BVI since 1 January 2026.

• Schema upgrade: RFIs must ensure reporting systems, software vendors and internal IT teams can generate CRS XML Schema 3.0 compliant reports before the 2027 reporting cycle begins.
• Additional data under Amended CRS: RFIs may need to collect and report additional information, including the role/capacity of Controlling Persons of Entity Account Holders, details of Electronic Money Products and Central Bank Digital Currency Products, new Schema 3.0 data elements, and information needed to meet revised due diligence requirements.
• Process review: RFIs should review account opening documentation, customer due diligence processes, policies and procedures, and reporting systems to ensure they can capture the required Amended CRS information.
• Corrections deadline: RFIs are encouraged to review historical CRS filings for errors or previously omitted Reportable Accounts and submit any corrections through the BVIFARS Portal no later than 30 November 2026, ahead of the schema transition.

The ITA indicates it will continue issuing guidance on both the Amended CRS and the Schema 3.0 transition as the 2027 deadline approaches.

Key obligations

• From 1 January 2027, all CRS reports submitted through the BVIFARS Portal must be prepared using CRS XML Schema 3.0; earlier schema versions will no longer be accepted.
• RFIs must upgrade their reporting systems (via software vendors, service providers, or internal IT) to generate CRS XML Schema 3.0 compliant reports before the 2027 reporting cycle.
• RFIs must review and update account opening documentation, customer due diligence processes, and reporting systems to collect and maintain additional information required under the Amended CRS.
• Corrections to existing CRS filings, including previously omitted Reportable Accounts, should be submitted through the BVIFARS Portal no later than 30 November 2026.

Applies to

Reporting Financial Institutions (RFIs)

Deadlines

• 1 January 2027: BVIFARS Portal will only accept CRS reports prepared using CRS XML Schema 3.0; earlier schema versions rejected.
• 30 November 2026: Deadline to submit corrections to existing CRS filings or previously omitted Reportable Accounts through the BVIFARS Portal.
• 1 January 2026: Date from which the Amended CRS has been in effect in the British Virgin Islands, introducing additional reporting requirements.