Between 2018 and 2024, Argentina’s participation in the OECD’s Common Reporting Standard (CRS) framework enabled the exchange of 10.9 million financial account records across 78 partner jurisdictions, generating USD 4.83 billion in recovered tax revenue and USD 820 million in penalties for underreporting and false declarations.
On July 1, 2025, Argentina signed the CRS 2.0 Addendum, extending automatic exchange obligations to digital assets, tokenized instruments, and electronic money. This reform affects approximately 1,200 Reporting Financial Institutions (RFIs), including 41 banks, 19 custodians, 230 investment managers, and 27 digital-asset service providers, which collectively manage ARS 118 trillion in client assets.
Argentina is third in Latin America by CRS reporting volume and first in digital-asset readiness. Under CRS 2.0, the Administración Federal de Ingresos Públicos (AFIP) projects a 27 percent increase in reportable accounts and a 40 percent growth in data volume by the June 2027 filing cycle. AFIP aims to elevate reporting accuracy from 91.7 percent in 2024 to 98 percent or higher by 2026, relying on real-time TIN validation and automated XML schema verification. Legacy manual validation processes currently generate 8 percent rejection rates, which CRS 2.0 “reasonableness” checks are expected to eliminate.
Argentina’s CRS Implementation and AFIP Compliance Architecture
Since joining the Common Reporting Standard Multilateral Competent Authority Agreement (CRS MCAA) in December 2015, Argentina has systematically transformed its cross-border reporting infrastructure. By June 2018, domestic financial institutions had submitted information for over 1.3 million accounts, and by September 2018, AFIP had activated bilateral exchanges with more than 70 jurisdictions, including Switzerland, Panama, and Luxembourg.
The 2025 CRS 2.0 Addendum expands reporting obligations to include crypto-assets, electronic money, and tokenized investment products, marking a shift toward full digital-asset transparency. AFIP anticipates a 27 percent increase in reportable accounts and a 40 percent growth in data volume by the first broadened reporting cycle in June 2027.
To operationalize these obligations, AFIP has built a robust compliance architecture:
Legal Framework:
- Law 27.260 (2016) established self-certification and due diligence requirements for FIs.
- Resolution 5129/2022 integrated crypto-asset intermediaries and digital custodians.
- Resolution 5517/2024 updated XML submission standards to align with OECD v4.0 and the Crypto-Asset Reporting Framework (CARF).
Operational Requirements:
- Verified self-certifications for new accounts and periodic re-validation for existing accounts.
- Accurate TIN reporting using CUIT/CUIL/CDI formats, with automated checks recommended.
- Retention of audit-ready data for seven years.
- Submission via AFIP’s secure portal with built-in schema validation and rejection alerts.
Enforcement Outcomes:
Between 2018 and 2024, AFIP exchanged data on 1.8 million accounts annually, recovering USD 4.8 billion in taxes and fines. In 2023 alone, 12 banks were penalized for incomplete TIN reporting, highlighting the regulator’s growing reliance on data precision.
This framework positions Argentina as one of the most technologically integrated CRS jurisdictions in Latin America, emphasizing accuracy, automated validation, and audit-readiness.
CRS 2.0 Expansion: Digital Assets and E-Money
The 2025 Addendum significantly broadens the scope of reportable assets:
- Crypto-assets and non-custodial wallets: reportable above USD 1,000, with AFIP projecting USD 500 million in recoverable revenue between 2026 and 2028.
- Electronic Money Providers (EMPs): reportable above USD 500, with an estimated revenue impact of USD 120 million.
- Tokenized investment products / crypto ETFs: any underlying exposure, with USD 60 million projected recovery.
- Central Bank Digital Currency (CBDC) accounts: reporting rules under pilot for 2027.
Financial institutions must capture wallet custodians, ultimate beneficial owners (UBOs), and transaction indicia, submitting data via the XML v4.0 schema to ensure alignment with both CRS 2.0 and CARF standards.
The Critical Role of TIN Validation
TIN accuracy drives both CRS 2.0 and CARF compliance in Argentina. AFIP applies algorithmic “reasonableness” checks to identify malformed CUIT/CUIL numbers, missing identifiers, and inconsistent data. Legacy manual validation processes produce approximately 8% rejection rates, creating risks of delays, penalties, and reputational exposure for financial institutions and VASPs.
To address these challenges and ensure full compliance, TaxDo’s CRS 2.0 and CARF Compliance Suite provides multiple precision-driven layers:
- Global TIN Syntax Verification (GSV): Validates structure, format, and checksum across 195 jurisdictions, reducing errors to below 2%.
- Global Real-Time Lookup (GTL): Confirms TIN existence and status against 130 official tax registries within seconds.
- Due Diligence and Ongoing Monitoring: Continuous account-holder screening against over 290 global watchlists—including AML, PEP, and sanctions lists—ensures any changes in account status are flagged in real time.
- Form Collection & E-Signature: Streamlines the collection and electronic signing of all required declarations.
- Domestic XML Reporting: Automatically generates and submits CARF- and CRS 2.0-compliant XML reports to AFIP, ensuring accurate, timely, and audit-ready reporting.
Financial institutions adopting TaxDo gain measurable operational advantages: fewer rejected filings, reduced manual overhead, and enhanced compliance accuracy. With up to 90% of TIN validation automated, institutions can ensure accurate digital-asset reporting while fully adhering to AFIP’s evolving regulatory standards.
Conclusion
Argentina’s CRS 2.0 regime is technology-driven, data-intensive, and enforceable. For Reporting Financial Institutions, success requires precise TIN validation, advanced digital-asset tracking, and full XML schema alignment.
Integration with the Crypto-Asset Reporting Framework (CARF) positions Argentina as a model for mid-income economies leveraging data automation to recover fiscal revenue and strengthen financial transparency.
With TaxDo, institutions can transform compliance into a strategic capability, achieving accuracy, scalability, and resilience in an increasingly data-driven regulatory environment.