Tax Information Authority (International Tax Compliance) (Crypto-Asset Reporting Framework) Regulations, 2025 (SL 51 of 2025)

Summary

These Regulations implement the OECD's Crypto-Asset Reporting Framework (CARF) in the Cayman Islands, made under the Tax Information Authority Act. They require entities and individuals that qualify as "Cayman Reporting Crypto-Asset Service Providers" (CRCASPs) — broadly, crypto-asset service providers resident in or with a branch in the Islands — to conduct due diligence on their crypto-asset users and controlling persons, collect tax residency self-certifications, and report specified information annually to the Cayman Islands Tax Information Authority (DITC) for automatic exchange with partner/reportable jurisdictions, mirroring the existing CRS/FATCA framework but applied to crypto-assets.

Core Obligations

• Registration: Notifying the Authority of CRCASP status and designating a principal point of contact.
• Due diligence and self-certification: Meeting specified timelines for conducting due diligence on users and controlling persons and collecting self-certifications.
• Annual returns: Submitting annual returns, nil returns, or declarations as applicable.
• Electronic portal: Using the Authority's electronic portal for required submissions.
• Record-keeping: Maintaining records in accordance with prescribed duties.
• Anti-avoidance: Complying with an anti-avoidance provision.

Compliance Regime

The Regulations also establish a detailed compliance regime.

• Criminal offences: Including false self-certification, obstructing the Authority, tampering, and unauthorised access to confidential information.
• Director/officer liability: Personal liability may attach to directors and officers.
• Civil administrative penalties: A regime involving breach notices, penalty notices, and a right of appeal.

The Regulations came into force on 1 January 2026. The Schedule reproduces the substantive OECD CARF standard (definitions of Reporting Crypto-Asset Service Provider, Crypto-Asset User, Controlling Person, due diligence procedures, reportable transactions, etc.), which is incorporated as Cayman law.

Key obligations

• Cayman Reporting Crypto-Asset Service Providers (CRCASPs) must establish, maintain and implement written policies and procedures to comply with the CARF reporting and due diligence requirements, and keep records of steps taken and evidence relied on.
• CRCASPs must identify each jurisdiction in which a Crypto-Asset User or Controlling Person is tax resident and apply the due diligence procedures in Section III of the CARF Schedule.
• CRCASPs must collect a compliant self-certification from Pre-existing Individual and Entity Crypto-Asset Users within twelve months of the Regulations coming into force.
• CRCASPs must collect a compliant self-certification from new Individual and Entity Crypto-Asset Users on or before establishing a relationship with the user.
• An Entity or individual that was a CRCASP before commencement (other than an exempted body) must submit a registration form with required information to the Authority on or before 30th April 2026.
• An Entity or individual that becomes a CRCASP on or after commencement must submit a registration form on or before 31 January following the year it became a CRCASP.
• CRCASPs must notify the Authority of any change to previously notified required information (a change notice) within thirty days after the change occurs.
• Registration forms and change notices must be given electronically in the manner/form specified by the Authority and must contain adequate, accurate and current information.
• CRCASPs must submit returns, nil returns, or declarations to the Authority as required under regulation 9, using the manner and form prescribed (including via the electronic portal).
• CRCASPs may be required to appoint an agent as provided in regulation 11.
• The Authority must publish, at least once each calendar year, a Gazette notice listing Partner Jurisdictions and Reportable Jurisdictions.

Applies to

Cayman Reporting Crypto-Asset Service Providers, Reporting Crypto-Asset Service Providers, Crypto-Asset Users, Controlling Persons, directors and officers of Cayman Reporting Crypto-Asset Service Providers

Deadlines

• 1st January, 2026: Commencement date of the Regulations.
• within twelve months of these Regulations coming into force: Deadline for CRCASPs to collect self-certifications from Pre-existing Individual and Entity Crypto-Asset Users.
• on or before the establishment of a relationship with the user: Deadline for CRCASPs to collect self-certification from Individual and Entity Crypto-Asset Users established after commencement.
• 30th April, 2026: Deadline for entities/individuals who were CRCASPs prior to commencement (other than exempted bodies) to submit a registration form to the Authority.
• 31st January following the year in which the Entity or individual became a Cayman Reporting Crypto-Asset Service Provider: Deadline for new CRCASPs (becoming such on or after commencement) to submit a registration form.
• within thirty days after the change occurs: Deadline to submit a change notice if previously notified required information changes.
• at least once every calendar year: Authority's obligation to publish by Gazette Notice a list of Partner Jurisdictions and Reportable Jurisdictions.

Related documents

• This document is made under Tax Information Authority Act (2021 Revision)