Amended CRS Quick Guide (2025-12-08)

Summary

This is a DITC "Quick Guide" explaining the Amended Common Reporting Standard (CRS) as it applies in the Cayman Islands, following the OECD's 2023 review of CRS and its new CARF (Crypto-Asset Reporting Framework). The amendments, implemented via the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025, come into force on 1 January 2026, with the first reporting for the 2026 calendar year due in 2027.

The guide is aimed at Cayman Financial Institutions (FIs) and summarises how the changes broaden CRS scope to capture Specified Electronic Money Products (SEMPs), Central Bank Digital Currencies (CBDCs), and indirect crypto-asset exposure via derivatives and investment vehicles, and how CRS interacts with the new CARF regime applicable to Reporting Crypto-Asset Service Providers (RCASPs).

Key Changes Covered

• Due diligence and reporting fields: New/expanded data fields are introduced, e.g. account type, self-certification confirmation, number of joint holders, and controlling person roles.
• Low-value exclusion: A new low-value exclusion applies for SEMPs.
• XML schema: A move to OECD CRS XML Schema v3.0.
• Transitional provisions: Transitional provisions apply for pre-existing accounts (as of 31 December 2025).
• Implementation timeline: Table C sets out a detailed implementation timeline of registration and reporting deadlines running from 2026 through 2028.
• CRS/CARF comparison: A comparison of similarities and differences between CRS and CARF obligations is provided for entities subject to both regimes.

Overall the guide is informational/explanatory in nature but embeds specific compliance deadlines and reporting requirements that FIs must observe under the underlying Amendment Regulations; it does not itself create new legal obligations beyond restating those imposed by the Regulations and prior CRS framework.

Key obligations

• FIs must comply with the Amended CRS legislation from 1 January 2026.
• Entities that became FIs in 2025 must register required information (including a Cayman-based Principal Point of Contact, PPoC) with the DITC by 30 April 2026.
• FIs must submit CRS Returns using OECD XML schema v2.0 (or Nil Returns and Filing Declaration) for the 2025 calendar year by 31 July 2026.
• FIs must submit the Compliance Form for the 2025 calendar year by 15 September 2026.
• New FIs arising from 2026 onwards must register required information with the DITC by 31 January of the following year.
• Cayman FIs registered before 1 January 2026 that have not notified the Authority of a Cayman-based PPoC must do so by 31 January 2027.
• FIs must submit CRS Returns for the 2026 calendar year using the updated OECD XML Schema v3.0 (or Nil returns, Declaration and Compliance form) by 30 June 2027.
• For reportable accounts maintained as at 31 December 2025, full reporting of controlling person/equity interest holder roles and all additional data fields becomes mandatory (where electronically available) for the 2027 calendar year, due by 30 June 2028.
• FIs must file a Change Notice with the DITC within 30 calendar days of any change in circumstances.

Applies to

Cayman Financial Institutions (FIs), Reporting Financial Institutions, Reporting Crypto-Asset Service Providers (RCASPs)

Deadlines

• 1 January 2026: Amended CRS Regulations come into force; FIs must comply with Amended CRS legislation.
• 30 April 2026: Registration deadline for entities which became FIs in 2025 — FIs must register required information with the DITC, including a Cayman-based PPoC.
• 31 July 2026: Reporting deadline for the 2025 calendar year — submit CRS Returns using OECD XML schema v2.0 or Nil Returns and Filing Declaration.
• 15 September 2026: Reporting deadline for the 2025 calendar year — submit Compliance Form.
• 31 January of the following year: Registration deadline for new FIs from 2026 onwards — must register required information with the DITC.
• 31 January 2027: Deadline for Cayman FIs registered before 1 January 2026 that have not notified a Cayman-based PPoC to do so.
• 30 June 2027: Reporting under Amended CRS for the 2026 calendar year — submit CRS Returns using updated OECD XML Schema v3.0, or Nil returns, Declaration and Compliance form.
• 30 June 2028: Reporting under Amended CRS for the 2027 calendar year — transitional period ends; full reporting of controlling person/equity interest holder roles and all additional data fields becomes mandatory for accounts maintained as at 31 December 2025, where electronically available.
• Within 30 calendar days: File a Change Notice with the DITC notifying of any change in circumstances.