The Common Reporting Standard (CRS) is the OECD framework under which Reporting Financial Institutions identify an account holder’s tax residence, determine whether an account is reportable and, where required, report specified information to their local tax authority for annual exchange with the relevant partner jurisdictions.
Reporting Financial Institutions carry out this reporting. Account holders and controlling persons do not normally submit the institution’s CRS return themselves, but they may be required to provide a valid self-certification when requested by a financial institution. Some readers will separately need to register an LEI for reasons unconnected to CRS, such as transaction reporting or fund administration; where CRS and LEIs actually intersect is covered later in this article, and it is not the case that an LEI is generally required for CRS compliance.
What Is the Common Reporting Standard (CRS)?
CRS is the OECD standard for the automatic exchange of financial account information between the tax authorities of participating jurisdictions. The OECD Council approved the standard in 2014 at the request of the G20, and it now underpins information exchange between more than 115 jurisdictions.
Its purpose is to tackle offshore tax evasion by removing the advantage of holding undeclared accounts outside an individual’s or entity’s home jurisdiction. To do this, each participating jurisdiction requires its Reporting Financial Institutions to identify Reportable Accounts linked to persons tax-resident in other reportable jurisdictions, including relevant controlling persons of certain entity account holders, and to collect the specified data. Once a jurisdiction’s tax authority has gathered this information from its financial institutions, it exchanges it automatically, on an annual cycle, with the tax authorities of the other jurisdictions where those account holders are resident.
Who Must Report Under CRS?
CRS does not place a personal filing obligation on most readers. The entity that submits a CRS return is the Reporting Financial Institution, not the customer; whether information about an individual is reportable depends on both the institution and the account being in scope.
Reporting Financial Institutions
Reporting Financial Institutions are the entities that carry the CRS reporting obligation. The category covers:
- Banks
- Custodians
- Investment entities
- Certain insurance companies
- From 2026, certain electronic money businesses whose products fall within the expanded CRS definitions
A Reporting Financial Institution carries out CRS due diligence, collects and reviews self-certifications from its account holders, identifies which accounts are reportable, and submits the CRS return to the relevant tax authority. Not every payment institution is automatically brought into scope by the 2026 changes; whether a particular electronic money institution is caught depends on whether its products meet the specific definitions for specified electronic money products.
Account Holders and Controlling Persons
Account holders and controlling persons may be required to provide a valid self-certification when a financial institution requests one, confirming details such as tax residence. They do not normally submit the financial institution’s CRS return themselves; that filing obligation sits with the institution, as part of its wider regulatory reporting responsibilities.
How Does CRS Work?
CRS reporting generally follows this sequence at a Reporting Financial Institution:
- The financial institution identifies the account holder’s tax residence.
- It collects and reviews a CRS self-certification.
- It determines whether the account is reportable.
- It reports the required information to its local tax authority.
- The tax authority exchanges the information with other participating jurisdictions.
This sequence is why tax residency sits at the centre of CRS reporting: everything downstream, from due diligence to the exchange itself, depends on the institution establishing where the account holder is resident for tax purposes.
What Is a CRS Self-Certification?
A CRS self-certification is a declaration in which an account holder states their tax residence and, usually, the applicable taxpayer identification number for that jurisdiction. The financial institution does not simply accept the form at face value. It checks the declaration against the information and records it already holds on the account holder, and follows up if the two do not match.
If a bank, investment platform or other financial institution has asked for a completed CRS form, this is the document in question. Complete every field the institution requests accurately, including your tax residence jurisdiction or jurisdictions and applicable taxpayer identification numbers, and sign or affirm the declaration as instructed.
What Information Is Reported Under CRS?
Where applicable, a reportable account generates the following information:
- Account holder’s name
- Address
- Jurisdiction of tax residence
- Taxpayer identification number
- Date of birth
- Place of birth, where required
- Account number
- Account balance or value
- Relevant income
- Gross proceeds
- Applicable controlling-person information
- The Reporting Financial Institution’s name and identifying number, if any
For reporting periods beginning on or after 1 January 2026, UK CRS reporting also includes whether a valid self-certification was provided, whether the account is new or pre-existing, whether it is jointly held, and which controlling-person and beneficial-owner roles apply. These additions follow the OECD’s amended CRS data fields, published as part of its CRS review. For pre-existing accounts, the controlling-person point is phased in: during 2026 and 2027, controlling-person and equity-interest-holder roles need only be reported where the information is already held in electronically searchable records. Full role reporting becomes mandatory for all pre-existing accounts from 2028.
CRS Reporting in the UK: HMRC Rules and Deadlines
CRS operates in the UK under the International Tax Compliance Regulations 2015, as amended, and financial institutions interact with HMRC through its Automatic Exchange of Information (AEOI) service. Registration and annual reporting are two separate obligations with two separate deadlines, and it is worth keeping them apart.
Registration
Registration is a one-off requirement. Reporting Financial Institutions and Trustee-Documented Trusts that were already within scope and had not previously registered were required to register with HMRC by 31 December 2025; entities already registered for HMRC’s AEOI service did not need to register again. An entity that first enters scope later must generally register by 31 January following that calendar year.
Registration is required even where an entity has no reportable accounts. HMRC does not normally require a nil return, although a report should still be submitted where the nil position results from applying the relevant de minimis thresholds to pre-existing accounts.
Annual Reporting
Annual CRS reports covering the previous calendar year are generally due by 31 May. This is distinct from the registration deadline: registration happens once, while CRS reporting recurs every year for as long as the institution holds reportable accounts.
CRS 2.0 in the UK: What Changed from 1 January 2026
A set of CRS amendments, generally referred to as CRS 2.0, took effect in the UK on 1 January 2026. The changes extend the scope of what counts as a reportable account and add to the information a Reporting Financial Institution must collect.
The main changes include:
- Expanded treatment of specified electronic money products, bringing certain e-money balances within CRS where they meet the relevant thresholds and account characteristics
- Inclusion of central bank digital currencies, where these are issued and operational
- Coverage of certain indirect investments in crypto-assets through derivatives and investment vehicles
- Additional reported data fields, including the account type, whether the account is new or pre-existing, joint-account and self-certification information, and relevant controlling-person or equity-interest-holder roles
- Strengthened due-diligence requirements around verifying self-certifications against records the institution already holds
CRS 2.0 sits alongside, rather than inside, the Crypto-Asset Reporting Framework (CARF). CARF is a separate OECD framework aimed specifically at crypto-asset service providers and the transactions they process, distinct from the crypto-asset regulation that applies to how those providers operate.
The first amended UK CRS reports cover the 2026 calendar year and are due by 31 May 2027.
CRS vs FATCA: What’s the Difference?
A Common Reporting Standard FATCA comparison starts from one key distinction: the two are related but separate financial account reporting frameworks, and it helps to be clear about where they diverge before assuming one covers the other. CRS is a multilateral OECD standard used by participating jurisdictions and is based primarily on tax residence. FATCA is a US reporting regime, closely connected to US citizenship and US tax status, and it targets accounts connected to US taxpayers specifically rather than tax residents generally.
| CRS | FATCA | |
| Origin | OECD, multilateral | United States, unilateral (with intergovernmental agreements) |
| Basis for reporting | Tax residence | US citizenship and US tax status |
| Participating jurisdictions | 115+ | US, via bilateral IGAs |
| Exchange model | Multilateral, annual | Bilateral, annual |
In practice, a financial institution can have obligations under both frameworks at once, since holding a US-connected account does not exempt an institution from also checking a customer’s tax residence under CRS. Institutions with international customer bases, and those managing wider financial compliance programmes, typically run CRS and FATCA due diligence side by side rather than treating them as interchangeable.
Does CRS Require an LEI?
CRS does not create a standalone requirement for account holders, controlling persons or organisations to obtain a Legal Entity Identifier solely to comply with it. Whether an organisation needs an LEI usually turns on separate financial-market, transaction or regulatory obligations, such as those that determine who needs an LEI number in the first place, rather than anything in the CRS rules themselves.
The one place CRS and LEIs meet is narrower than most expect: the OECD recognises an LEI as one possible identifying number a Reporting Financial Institution can use for itself, alongside identifiers such as a tax identification number. This is not a requirement placed on all Reporting Financial Institutions, and it does not extend to account holders or controlling persons. Organisations that need an LEI for one of those separate reasons can follow the how to get an LEI number process through a Registration Agent such as LEI24, which collects the required entity information and coordinates validation with an accredited LEI issuer. Once issued, the LEI record must generally be renewed annually to keep its reference data current.
Common Reporting Standard: Frequently Asked Questions
Which Countries Take Part in CRS?
More than 115 jurisdictions currently exchange or are committed to exchanging financial account information under CRS, including the UK. The OECD maintains the current jurisdiction list, since participation can change.
What Happens If a Financial Institution Does Not Comply with CRS?
Non-compliance can lead to penalties from the relevant tax authority, plus the cost of correcting inaccurate data afterwards. HMRC can penalise late registration and late or incorrect reporting.
Do I Need an LEI to Meet CRS Obligations?
No. CRS does not require account holders or controlling persons to obtain an LEI. Businesses that may need an LEI for other reasons can search the Global LEI Index to check whether they already have one.
