Explanatory Note – CRS Compliance Form Bulk Upload Template

Summary

This is DITC guidance explaining how to prepare the CRS Compliance Form using the new bulk upload template, rather than the smartform already on the DITC Portal. It is aimed at Users/FIs (or their portal Users) who need to submit compliance information for a large number of Financial Institutions (FIs) at once.

The CRS (Amendment) Regulations, in force since 16 April 2020, amended Regulation 9 to require FIs to annually provide additional information to the Cayman Islands Tax Information Authority confirming compliance with CRS reporting and due diligence procedures. The CRS Compliance Form is the mechanism for collecting this information via the DITC Portal.

• Format: The bulk upload template can be prepared in Excel but must be submitted as a CSV file via the Portal.
• Questions: Questions mirror the smartform/CRS Guidelines, though some are abbreviated.
• Answers: Answers must use codes, 'n/a', and country/currency codes rather than free text.
• Column order: Users must keep columns in the template's original order and avoid adding extra columns or comments.
• FI details: FI names and numbers must exactly match Portal records.
• Avoiding errors: Users must avoid blank cells, columns or rows to prevent validation errors.
• Upload functionality: Portal upload functionality was expected to become available in July, with the User Guide to be updated accordingly.

The deadline for submitting the 2019 and 2020 CRS Compliance Forms on the DITC Portal is 15 September 2021. FIs are encouraged to check the updated CRS Compliance Form FAQs before emailing the DITC Portal Team with questions.

Key obligations

• FIs must submit the 2019 and 2020 CRS Compliance Forms via the DITC Portal by 15 September 2021.
• Reporting Financial Institutions must annually provide additional compliance information to the Authority under amended Reg.9 of the CRS Regulations, via the CRS Compliance Form.
• When using the bulk upload template, Users must keep columns in the same order as the template and not add additional columns.
• When using the bulk upload template, Users must enter only the data listed on the template and avoid additional comments to prevent validation errors.
• When using the bulk upload template, Users must ensure FI names and numbers exactly match the data listed on the DITC Portal.
• When using the bulk upload template, Users must not leave any blank cells, columns or rows.
• The completed bulk upload template must be submitted on the Portal as a CSV file.

Applies to

Financial Institutions (FIs), Reporting Financial Institutions

Deadlines

• 15 September 2021: Deadline for submission of the 2019 and 2020 CRS Compliance Forms on the DITC Portal.