Starting in 2026, Finnish financial institutions will face the full implementation of the OECD’s Common Reporting Standard (CRS) 2.0, marking a major evolution in cross-border tax transparency. CRS 2.0 strengthens due diligence, expands reportable assets, and enforces stricter standards for validating tax residency and Tax Identification Numbers (TINs). For banks, investment firms, and fund managers operating in Finland, this transition is more than regulatory formality—it is a fundamental shift in operational compliance.
With over 100 jurisdictions participating in CRS, and Finland fully aligned under EU DAC2 directives, financial institutions must prepare for a comprehensive review of account holder information, including electronic money products, crypto-linked investments, and central bank digital currencies. Failure to comply carries not only fines but reputational and operational risk.
Expanded Scope Under CRS 2.0
CRS 2.0 expands the range of reportable accounts. Finnish financial institutions must now include electronic money products, indirect crypto exposures via derivatives or fund vehicles, and certain pre-existing accounts with updated due diligence checks. Both individual and entity accounts are impacted. For entities, passive Non-Financial Entities (NFEs) and their controlling persons—such as trustees, settlors, and beneficiaries—must be identified and reported.
Institutions must collect accurate account holder information, including name, address, jurisdiction of tax residence, TINs, date and place of birth for individuals, and relevant entity details for corporate clients. Income reporting includes balances, interest, dividends, and gross proceeds from sales of assets held in custody. The reporting framework demands annual submission in a standardized XML format to the Finnish Tax Administration via Ilmoitin.fi, with records retained for at least five to ten years.
Key Challenges for Finnish Financial Institutions
Implementing CRS 2.0 is operationally complex. Many legacy accounts lack complete TINs or proper documentation of tax residence, particularly for accounts opened before 2016. Crypto-linked accounts introduce additional complexity due to the need to map indirect holdings and fund-based exposures to reportable jurisdictions. Incomplete or inaccurate TINs can lead to rejected reports, penalties, and potential audits by the Finnish Tax Administration.
Ensuring ongoing compliance requires not only initial data collection but continuous monitoring of account holders’ status. Any change in residency, legal structure, or risk profile must be captured in real time to avoid non-compliance.
Operational Compliance: Advanced Tools to Solve the CRS 2.0 Challenge
Global TIN Lookup (GTL) enables real-time validation of business TINs directly against official tax authority databases in over 130 countries, offering the highest assurance for reporting accuracy.
Global TIN Syntax Verification (GSV) complements GTL by checking the format, structure, and checksum of TINs for individuals and businesses across 195+ jurisdictions, aligning with CRS 2.0 “reasonableness” checks. This ensures that all TINs meet international standards, even when direct authority verification is unavailable.
Global Identity Intelligence Engine (GIIE) provides continuous screening against more than 290 global watchlists, including AML, PEP, and sanctions databases, enabling proactive detection of changes in risk status or compliance flags.
By integrating GTL, GSV, and GIIE, Finnish institutions can automate onboarding, verification, and ongoing monitoring, reducing manual errors, improving data quality, and maintaining audit-ready reporting. These tools also streamline XML report generation for submission to Ilmoitin.fi, ensuring timely and accurate compliance under CRS 2.0.
Practical Compliance Measures
Financial institutions in Finland should implement a structured CRS 2.0 workflow that begins with onboarding and TIN verification, extends through periodic reviews of pre-existing accounts, and maintains continuous monitoring of account holders and controlling persons. Consolidating account data, mapping indirect crypto exposures, and validating TINs at both onboarding and annual intervals ensures seamless reporting.
Ongoing due diligence must include updating residency information, verifying controlling persons for entities, and screening against global watchlists. XML reporting processes should be fully automated to reduce operational burden and prevent errors in transmission to the Tax Administration.
Preparing for 2026: Timeline and Action Points
Finnish financial institutions should anticipate the following milestones:
- January 1, 2026: CRS 2.0 rules come into effect for new accounts and ongoing compliance obligations.
- Throughout 2026: Pre-existing account reviews and updates of TINs, residency data, and controlling persons for entities.
- January 2027: First CRS 2.0 reports must be submitted via Ilmoitin.fi.
- Ongoing: Continuous monitoring and annual compliance verification to ensure audit readiness.
By adhering to these timelines and integrating advanced tools such as GTL, GSV, and GIIE, Finnish institutions can minimize regulatory risk, streamline reporting, and maintain full compliance with international CRS 2.0 standards.
Conclusion
CRS 2.0 represents a fundamental evolution in Finland’s approach to cross-border tax transparency. Accurate TIN validation, complete account information, and ongoing due diligence are no longer optional; they are essential operational practices. Financial institutions that proactively implement automated verification tools, monitor account changes in real time, and maintain audit-ready records will not only meet compliance requirements but also reduce operational risk and strengthen their global reputation.