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Sources last verified: 20 October 2026
Official sources cited at the end of this page.
Is India part of CRS 2.0? In its own law, yes. Since 1 January 2026 the rules binding Indian reporting financial institutions carry the OECD’s 2023 amendments to the Common Reporting Standard, and since 1 April 2026 they sit in rules 238 to 240 of the Income-tax Rules, 2026, under section 508 of the Income-tax Act, 2025. Banks, custodians, funds and insurers now report whether each holder gave a valid self-certification, each controlling person’s role, the account type and joint holders. More in our CRS 2.0 guide for financial institutions.
India has exchanged CRS information since 2017, but on the OECD’s list as at 30 October 2026 it is not among the 87 signatories of the Addendum to the multilateral agreement, the instrument for exchanging the expanded data. The domestic duty does not depend on it: rules 238 to 240 apply to the 2026 year, reported by 31 May 2027.
The failure point is the opening form. Rule 240 requires a self-certification at opening, tested for reasonableness against the KYC records, and Form No. 166 now shows which holders never gave a valid one.
There are two ways to meet the amended Indian rules. The first collects forms at onboarding, then chases and remediates before the 31 May statement. The second completes and tests the self-certification while the customer is still onboarding, so the statement is built from data that was clean on Day 1. One finds the gap in May; the other closes it the day the account opens.
01 · India CRS 2.0 at a Glance
| Point | Position as at 20 October 2026 |
| Filing | Form No. 166 for each calendar year, by 31 May of the following year; a nil statement where no account is reportable (rule 239(8) and (9)) |
| Legal basis | Income-tax Act, 2025, section 508; Income-tax Rules, 2026, rules 238 to 240 (from 1 April 2026) |
| Who reports | Banks, custodians, investment entities and specified insurance companies resident in India, and Indian branches of foreign ones (rule 238(3), (8)) |
| Authority | Income Tax Department, under the Central Board of Direct Taxes (CBDT) |
| Registration | Designated Director and Principal Officer notified to the Principal Director General of Income-tax (Systems) for a registration number (rule 239(11)) |
| Fees and penalties | Fee of INR 200 a day late (s. 427(3)); INR 1,000 a day after a notice (s. 454), each capped at INR 1,00,000; INR 50,000 for an inaccurate statement or a due diligence failure (s. 455(1)) |
| Due diligence from | New accounts from 1 January 2016; accounts added by the amendments, new from 1 January 2026 (rule 240(2)(d)) |
| TIN rule | Foreign TIN and date of birth in the self-certification, unless the country issues none or does not require it (rules 239(5), 240(4)(c)) |
| Transmission | Online to the Director of Income-tax (Intelligence and Criminal Investigation), under the Designated Director’s digital signature (rule 239(10), (11)) |
| First amended period | Calendar year 2026, reported by 31 May 2027 |
| Records | Kept as the institution’s regulator specifies (rule 239(12)) |
| Exchange | CRS exchanges since 2017; Addendum not signed (1 October 2026); no CARF commitment |
Our regulatory compliance engine applies India’s amended CRS rules from Day 1. It gathers each self-certification at opening, with a passive entity’s controlling persons and roles, validates the TIN, runs rule 240’s reasonableness and indicia checks, resolves indicia automatically instead of by your team, and prepares the validated Form No. 166 statement, with zero remediation, as section 08 shows.
02 · Understanding CRS 2.0 and Its Significance
The Common Reporting Standard is the OECD’s model for exchanging financial account information; the OECD lists 131 jurisdictions committed to it as at 30 September 2026. CRS 2.0 is its 2023 update, published with the Crypto-Asset Reporting Framework in a consolidated text on 8 June 2023.
India’s rule 238 carries the changes. Accounts holding central bank digital currencies (CBDC) or specified e-money products become depository accounts, but an e-money account whose 90-day average never exceeded USD 10,000 is excluded. Derivatives on relevant crypto-assets count as financial assets; a relevant crypto-asset, defined in rule 241(9) and applied here by rule 238(7), excludes central bank digital currencies, specified e-money products and crypto-assets the service provider has adequately determined cannot be used for payment or investment. An equity or debt interest in a financial institution whose class was established to avoid reporting is itself a financial account (rule 238(1)(iv)). Crypto-assets held directly are generally reported under CARF, though an asset that is also a financial asset, such as a share issued in crypto form, can fall under both.
03 · Who Must Report Under CRS 2.0 in India
| Question | What it means for you (rule 238(1), (3)) |
| A bank or co-operative bank taking deposits? | A depository institution, reporting unless exempt. |
| Holding CBDC or specified e-money for customers? | Those accounts are depository accounts from 2026, subject to the USD 10,000 e-money exclusion. |
| A broker, custodian or depository participant? | Generally a custodial institution. |
| An asset manager, mutual fund or portfolio manager? | Generally an investment entity. |
| An insurer selling cash-value or annuity contracts? | A specified insurance company. |
| A crypto exchange or wallet service? | Generally outside the CRS for crypto held directly; India’s separate crypto-asset reporting sits in section 509. |
An Indian branch of a foreign institution reports in India; an Indian institution’s branch abroad does not (rule 238(8)). For crypto, see India and CARF.
04 · India’s Regulatory Framework for CRS 2.0
From 2015 until 31 March 2026, the CRS ran under section 285BA of the Income-tax Act, 1961, rules 114F to 114H and Form 61B. The Income-tax Act, 2025 replaced that Act on 1 April 2026. Section 508 now requires the statement and lets the government set registration, records and due diligence by rule; rules 238 to 240 replace rules 114F to 114H.
Rule 239(12) also has each institution’s regulator issue instructions incorporating rules 238 to 240, and the institution keep account information as that regulator specifies.
05 · Key Compliance Requirements in Practice
Rule 240 sets the due diligence by account type, with balances converted to US dollars at the Reserve Bank of India’s reference rates (rule 240(7)(c)).
New Individual Accounts
On opening, the institution obtains a self-certification, which may be part of the opening documents, and confirms its reasonableness against what it collected, including records kept under the Prevention of Money-laundering (Maintenance of Records) Rules, 2005 (rule 240(4)(b)). A customer resident abroad gives the foreign TIN and date of birth (rule 240(4)(c)). If, in exceptional circumstances, one cannot be obtained in time for the reporting period, the pre-existing account procedures apply until it is obtained and validated (rule 240(7)(a)).
Preexisting Individual Accounts
Lower value accounts, at or below USD 1 million, are searched electronically for indicia such as residence abroad, a current address abroad, a foreign telephone number with no Indian one, standing instructions to transfer funds abroad (other than from a depository account), or a power of attorney granted to a person with an address abroad (rule 240(3)(b)). High value accounts add a paper record search where electronic records are incomplete, and the relationship manager’s actual knowledge (rule 240(3)(c)). When a pre-existing record is updated under the anti-money-laundering rules, the TIN and date of birth must be obtained (rule 239(4)(b)).
Entity Accounts
A new entity account needs a self-certification establishing residence. For a passive non-financial entity, controlling persons may be identified from anti-money-laundering records, are tested for reportable status by self-certification, and are now reported with their roles; an institution outside those rules applies substantially similar procedures (rules 240(6), 239(1)(b)). Pre-existing entity accounts above USD 250,000 are reviewed (rule 240(5)). For accounts held on 31 December 2025, roles are reported only if electronically searchable, for reporting periods ending by 2027 (rule 239(13)).
Ongoing Account-Holder Due Diligence
Reliance ends when the institution knows, or has reason to know, that the declaration is incorrect or unreliable. After a change of circumstances it must obtain a valid one; if it cannot, the account is reported for every country where an indicium points (rule 240(7)(a), (4)(d)).
06 · The Importance of TIN Validation, Ongoing Due Diligence, and Advanced Compliance Tools
Indian rules require the TIN to be collected (rules 239(5), 240(4)(c)), not validated. The OECD’s amended Commentary (Section VII, paragraph 4bis) does not mandate a format or authenticity check either. It adds that a blank TIN, where the jurisdiction issues TINs to all residents, gives reason to know the self-certification is unreliable.
Validation is still where accuracy is won at scale: a well-formed number can belong to nobody, and once filed it is exchanged abroad. Our TIN lookup tool checks numbers in real time against official sources in 130+ countries, and format across 210+. More in TIN validation under CRS 2.0.
07 · Deadlines, Fees and Penalties
| Income-tax Act, 2025 | Amount | For |
| Section 427(3) | INR 200 a day, at most INR 1,00,000 | Statement not furnished by 31 May |
| Section 454 | INR 1,000 a day, at most INR 1,00,000 | Still not furnished after a section 508(7) notice period of up to 30 days |
| Section 455(1) | INR 50,000 | Inaccurate information, or not correcting it within ten days of discovery, or due diligence not carried out (at the authority’s direction) |
| Section 455(2) | INR 5,000 per account | An inaccurate reportable account caused by false information from the holder, recoverable from that holder |
A fictional Pune asset manager files its 2026 statement 50 days late, 20 of them after a notice period expired. The fee is 50 × INR 200, or INR 10,000; the penalty 20 × INR 1,000, or INR 20,000. Section 427(3) applies “without prejudice to the provisions of this Act”, so both can be charged.
08 · Challenges and Best Practices for Indian RFIs: Two Ways to Meet CRS 2.0
At year-end, by hand
Many Indian institutions collect forms at opening and review before May. The weakness is timing: each gap found later needs the customer again, and an invalid self-certification now shows in the statement.
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 Designated Director to sign, verify and furnish as Form No. 166, as rule 239 requires.
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, whose Designated Director furnishes the statement under a digital signature. TaxDo runs the due diligence and prepares and validates the report.
09 · Recent Changes and What’s Next
| Jurisdiction | Amended CRS applies from |
| India | 1 January 2026 |
| Japan | 2026, with first reports under it in 2027 |
| Singapore | 1 January 2027 |
21 August 2025
The Income-tax Act, 2025 receives assent, after Parliament passed it on 12 August.
5 and 20 March 2026
Notification No. 19/2026 writes the amendments into the old rules from 1 January 2026; the Income-tax Rules, 2026 carry them forward.
1 April 2026
The new Act and Rules take effect, with Form No. 166 and, under Act No. 4 of 2026, a fee replacing the old INR 500 daily penalty.
31 May 2027
The first statement covering a full year under the amended rules, calendar year 2026, falls due.
Not yet done
India had not signed the Addendum as at 1 October 2026, and the OECD lists it as expecting to commit to CARF in due course (14 September 2026).
10 · Related Reading
Framework articles: CRS 2.0 compliance for financial institutions · CARF and crypto tax transparency · Self-certification under CRS 2.0, DAC8 and CARF · India and CARF
Product: Regulatory compliance engine · Day 1 onboarding validation · Business registry check · CRS 2.0 compliance software
