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Sources last verified: 21 October 2026
Official sources cited at the end of this page.
Take a Canadian payments company that holds customer balances in a prepaid digital product. Today that balance sits outside Part XIX of the Income Tax Act, Canada’s Common Reporting Standard rules. Under Bill C-31, still before the House of Commons, the account would become a depository account from 1 January 2027 if the product is a specified electronic money product, and it would be excluded for a year only if its rolling 90-day average balance never exceeded USD 10,000 on any day of that year.
That is CRS 2.0 in Canada: the 2023 OECD amendments, proposed for 2027, not 2026 as an earlier Finance Canada draft had it. Our CRS 2.0 guide for financial institutions sets out what the amendments contain; this page sets out how the bill would apply them.
The failure point is the account opened in 2027 without a self-certification. Section 274 already requires one when a new individual account is opened, and from 2027 the return would also say whether each holder provided a valid one, so a gap the institution left at opening becomes a field the Canada Revenue Agency (CRA) reads.
There are two ways to meet the Canadian rules. The first collects forms at opening, then chases and remediates before the return is due. The second completes and tests the self-certification while the customer is still onboarding. One finds the gap in April; the other closes it the day the account opens.
01 · Canada CRS 2.0 at a Glance
| Point | Position as at 21 October 2026 |
| Status | Proposed: Bill C-31 at report stage in the House of Commons (committee report 30 October 2026); no royal assent |
| Start | 2027 and later calendar years for most amendments (Bill C-31, clauses 91 to 97) |
| Legal basis | Part XIX of the Income Tax Act (ss. 270 to 281), in force since 2017 |
| Authority | Canada Revenue Agency (CRA) / Agence du revenu du Canada |
| Return | Before 2 May each year, filed electronically (s. 278) |
| Self-certification | Obtained on opening a new account (ss. 274, 276); validated within 90 days (CRA guidance) |
| Records | At least six years (s. 279) |
| Penalties | Up to $2,500 per failure under s. 162(7); $500 per failure by a holder to give a TIN (s. 281(3)) |
Our regulatory compliance engine gets Canadian banks, dealers and funds ready for CRS 2.0 at onboarding. It gathers each self-certification as the account opens, validates the TIN, runs the reasonableness and indicia checks, resolves indicia automatically instead of by your team, and prepares the validated Part XIX return, with zero remediation.
02 · International Coordination and Policy Context
The CRS is the OECD’s model for exchanging financial account information, and the OECD lists 131 jurisdictions committed to it as at 30 September 2026; Canada began exchanging in 2018. The 2023 amendments were published with the Crypto-Asset Reporting Framework in a single OECD publication of 8 June 2023, and Canada signed the Addendum to the CRS multilateral agreement on 22 November 2024, the instrument for exchanging the expanded data.
Finance Canada’s draft of 13 August 2025 proposed the amendments from 2026. Bill C-31, the Budget 2025 Implementation Act, No. 2, tabled on 6 May 2026, moves them to 2027, and the bill would make the OECD Commentary an aid to reading Part XIX (s. 270(2)).
Others have already moved. The amended CRS has applied in the United Kingdom since 1 January 2026 (SI 2025/740), and DAC8 has applied in the EU since the same date, so a group’s UK and EU institutions within scope apply the amended rules a year before its Canadian ones would. Our DAC8 compliance software covers the EU side.
03 · Scope and Applicability
The bill would widen the defined terms in subsection 270(1). Each change below is proposed for 2027 and later.
| Term | Proposed change (Bill C-31, clause 91) |
| Depository account | Adds an account representing specified electronic money products, and one holding central bank digital currencies, for a customer |
| Excluded account | Adds an e-money account whose rolling 90-day average balance stays at or below USD 10,000, and a capital-contribution account meeting five conditions |
| Financial asset | Adds interests in relevant crypto-assets |
| Investment entity | Covers managing relevant crypto-assets for others, except through services effecting exchange transactions for customers |
| Controlling persons | Read with the 2012 FATF Recommendations |
| ACRS account | An account that is a financial account solely because of the 2023 amendments; pre-existing if held on 31 December 2026, new if opened after 2026 |
A specified electronic money product would be a digital representation of a single fiat currency, issued on receipt of funds, accepted by others and redeemable at par, and not a transfer-only product (s. 270(1) as proposed); a product whose funds are held more than 60 days would not count as transfer-only (s. 270(5) as proposed).
04 · Customer Due Diligence and Verification
For a new individual account the institution obtains a self-certification on opening and confirms its reasonableness against the account-opening information, including AML/KYC documentation (s. 274); where the holder is resident in a reportable jurisdiction it must include the TIN and date of birth. For a new entity account it establishes the entity’s residence and, for a passive non-financial entity, the controlling persons who are reportable persons (s. 276). An institution may not rely on a self-certification it knows or has reason to know is incorrect or unreliable (s. 277(1)).
CRA guidance says a self-certification obtained at opening but not yet validated should be validated within 90 days. The bill would add that, in exceptional circumstances where none can be obtained in time for the reporting period, the institution applies the pre-existing account procedures until it is obtained and validated (s. 277(1.1)).
For accounts in scope only because of the amendments, the reviews would have to be completed by the end of 2027 for high-value individual accounts (over USD 1 million) and by the end of 2028 for lower-value ones (s. 273(4)), and by the end of 2027 for entity accounts above USD 250,000 on 31 December 2026 (s. 275(5)).
05 · Transaction Capture and Reporting
The CRS reports balances and payments, not transactions. From the 2027 year the bill would add to the return whether each holder and each controlling person provided a valid self-certification, the controlling person’s role, the account type, whether it is new or pre-existing, whether it is joint and how many holders it has, and the role of an equity interest holder in a legal arrangement (clause 92).
For accounts held on 1 January 2027, roles would be reported for periods before 2029 only where they sit in electronically searchable data (s. 271(6)). Gross proceeds already reported under Part XXI, the proposed crypto-asset rules, would not need to be reported again under Part XIX unless the institution elects otherwise (s. 271(5)).
06 · CRS XML Schema
The Part XIX return is filed electronically before 2 May (s. 278). The CRA’s return page lists two routes: Web Forms, or Internet file transfer in the CRA’s XML specifications and schema. The CRA’s guidance lists new data elements starting with 2027, so a return format built for 2026 will not carry the 2027 fields.
07 · Operational and Compliance Requirements
Records, including self-certifications, are kept for at least six years, for a self-certification from the last day a related account is open (s. 279). An institution may use third-party service providers, but CRA guidance states that the obligations remain its own.
CRA guidance applies subsection 162(7): a failure to comply with an obligation such as a Part XIX due diligence duty may bring $25 a day for up to 100 days, up to $2,500 for each failure to obtain and validate a self-certification. A holder who does not give a TIN on request faces $500 per failure unless they apply for one within 90 days and pass it on within 15 days of receipt, or cannot obtain one (s. 281(3)). The bill would extend the anti-avoidance rule in section 280 to any individual or entity whose arrangement has the primary purpose of avoiding a Part XIX obligation.
08 · Integration with CARF and Global Reporting
The same bill adds Part XXI, Canada’s Crypto-Asset Reporting Framework, proposed from 2027, and the two Parts share definitions. An institution that is also a crypto-asset service provider would be able to rely on its due diligence under ss. 274 and 276 for Part XXI (s. 299(11) as proposed). More in our Canada CARF article and CARF compliance software.
09 · Two Ways to Meet Canada’s CRS 2.0
Before the return, by hand
Many institutions collect forms at opening and review before the return is due; each gap found later needs the customer again.
At onboarding, from Day 1
TaxDo runs CRS 2.0 due diligence inside onboarding, in five steps.
Step 1 · Collect the self-certification. Guided and jurisdiction-aware, with a digital signature; a passive entity’s controlling persons and roles in the same flow.
Step 2 · Validate the identity. Every TIN checked in real time against official sources in 130+ countries, and the business against registries in 120+.
Step 3 · Run forensic due diligence with Verify+. Our Verify+ forensic engine runs 20+ checks on an individual and 30+ tax-native checks across eight areas on an entity, including official TIN lookup in 130+ countries.
Step 4 · Cure the gaps, without the compliance team:
4a · New accounts. Reasonableness tested and discrepancies resolved in the same session.
4b · Existing accounts. One click starts a remediation campaign for the cohort, with guided questions through a link in your brand and every answer checked by Verify+. Each case closes with a signed self-certification and an audit-ready certificate.
Step 5 · Report, and keep the evidence. Schema-validated CRS data, prepared and validated for your institution to submit to the CRA. Our team can also submit it on your behalf on request, as an additional service.
From Day-1 self-certification to CRS XML reporting, with zero remediation.
Our CRS 2.0 compliance software · Solutions for financial institutions
Where this sits, and what it does not touch
It runs beside your KYC provider and core banking system. The reporting obligation, and the responsibility for what is reported, stays with your institution, including where TaxDo submits the report on its behalf at its request. TaxDo runs the due diligence and prepares and validates the report.
10 · Implementation Timeline
1 July 2017
Part XIX applies; accounts held on 30 June 2017 are pre-existing.
2018
Canada begins CRS exchanges.
22 November 2024
Canada signs the Addendum to the CRS multilateral agreement.
13 August 2025
Finance Canada’s draft proposes the amendments from 2026.
6 May 2026
Bill C-31 is tabled, moving the start to 2027; second reading follows on 3 June.
2 July 2026
The CRA revises its CRS guidance for the proposed amendments.
1 January 2027
Proposed start of the amended Part XIX and of Part XXI.
Before 2 May 2028
First return with the new fields, for 2027, if the bill is enacted as tabled.
End of 2027 and 2028
Proposed review deadlines for accounts in scope only because of the amendments: the end of 2027 for high-value individual accounts (over USD 1 million) and for entity accounts above USD 250,000 on 31 December 2026, and the end of 2028 for lower-value individual accounts (ss. 273(4), 275(5)). An entity account that first passes USD 250,000 at a later year-end is reviewed by the end of the following year.
Status on LEGISinfo as at 1 November 2026: at report stage in the House of Commons, after the Finance Committee reported it on 30 October, with a Senate pre-study; third reading and royal assent not reached.
11 · Related Reading
Framework articles: CRS 2.0 compliance for financial institutions · Self-certification under CRS 2.0, DAC8 and CARF · Canada and CARF · CRS 2.0 in the Bahamas · CRS 2.0 in Argentina · The Cayman Islands and CRS 2.0
Product: Regulatory compliance engine · Day 1 onboarding validation · TIN lookup · Business registry check
