Effective 1 March 2026, South Africa will implement the OECD’s enhanced Common Reporting Standard (CRS 2.0). This represents the most significant expansion of the country’s automatic exchange of information (AEOI) obligations since CRS was first introduced. The update brings electronic money products, central bank digital currencies, and indirect crypto exposure into scope, while introducing a far more rigorous framework for controlling person verification, risk based reviews, and XML reporting.
For South African financial institutions, CRS 2.0 alters the entire compliance lifecycle. Due diligence, onboarding, remediation, account classification, and annual reporting must now operate under a more granular and digitally intensive standard. The first international exchanges will take place in 2027, covering the 2026–2027 reporting periods, giving institutions limited time to upgrade their systems and governance models.
International Coordination and Policy Context
South Africa’s adoption of CRS 2.0 forms part of a coordinated international shift between 2022 and 2025, as the OECD consolidated and modernized the standard. The global objectives are clear: to broaden reporting rules to include newly relevant financial products, strengthen the accuracy of controlling person identification, and ensure consistent technical reporting through an updated XML Schema V.3.
More than 120 jurisdictions have already aligned with the new framework. This collective movement reflects a decade of digital transformation in both financial and payments markets, where products such as e-money and tokenized instruments have become mainstream channels for value storage and cross border movement. South Africa’s alignment maintains consistency with G20 expectations and prepares the country for more demanding multilateral audits and data reconciliation exercises.
Scope and Applicability
CRS 2.0 applies to all South African Reporting Financial Institutions holding accounts for nonresidents, entities with foreign controlling persons, or structures with offshore linkages.
The scope of reportable information has expanded significantly. Institutions must now report traditional financial account data, but also electronic money accounts, CBDC balances, and indirect crypto linked exposures that arise through derivatives, structured notes, or investment vehicles with digital asset portfolios.
The due diligence model has also changed. Controlling person verification must now use both documentary and non-documentary evidence. Continuous risk based monitoring replaces the periodic review approach used in earlier CRS cycles, and joint accounts along with layered structures face heightened scrutiny. These reforms are designed to reduce the misclassification of entities, improve data accuracy, and strengthen cross border traceability.
Customer Due Diligence and Verification
CRS 2.0 raises expectations across all onboarding and KYC functions. Institutions must validate tax residency and associated TINs for account holders and controlling persons, confirm the reasonableness of self-certifications against internal and external information sources, and implement document light verification processes suitable for digital onboarding without sacrificing compliance integrity.
High risk clients and complex cross border structures require enhanced review. Failure to conduct adequate due diligence may trigger SARS inquiries, follow up requests from foreign authorities, or penalties under the Tax Administration Act. Under CRS 2.0, the quality of due diligence has a direct impact on the credibility of a financial institution’s international reporting profile.
Transaction Capture and Reporting
Financial institutions must maintain complete, structured, and audit ready records of all reportable accounts. This includes end of year balances, income, redemption and disposal proceeds, controlling person data, and all relevant CBDC, e money, and digital asset exposure metrics. Data must be compiled and validated within the CRS XML Schema V.3, which enforces strict formatting and content rules.
South Africa’s use of the OECD AEOI exchange infrastructure means that incomplete or inconsistent submissions will no longer be tolerated. A data model that was previously sufficient for legacy CRS cycles must now support far more granular reconciliations across multiple jurisdictions.
CRS XML Schema Requirements
The updated XML schema is central to CRS 2.0 compliance. It standardizes the structure of message headers, identifies the sending and receiving authorities, and defines how account holder information, controlling person details, entity classifications, income categories, and digital asset linkages must be presented. These specifications reduce the likelihood of file rejection during SARS submission and simplify the process of international exchange.
The schema is also designed for interoperability. Once a financial institution’s systems are upgraded to support Schema V.3, the same technical foundations will support CARF and future OECD reporting modules.
Implementation Timeline
South Africa’s CRS 2.0 implementation follows a defined schedule. Draft regulations were released in September 2025 and finalized after consultation in October. The updated AEOI BRS and XML Schema V.3 were issued shortly thereafter. From 1 March 2026, institutions must begin collecting CRS 2.0 compliant data, with the first XML submissions due by 31 May 2027. Automatic exchanges through the OECD network will occur between 2027 and 2028.
The strictness of the timeline means that March 2026 is a hard operational pivot. Institutions that delay remediation into 2026 will face significant backlogs once reporting deadlines arrive.
Operational and Compliance Requirements
CRS 2.0 requires institutions to redesign their operational workflows. Onboarding journeys must incorporate modernized self-certification processes, improved controls for identifying indirect ownership, and tighter verification of TINs and tax residency. Data aggregation and validation must move toward automated models able to manage volume, complexity, and evolving regulatory specifications.
Institutions must also integrate new data sources capturing e money, CBDCs, and crypto linked derivatives. Manual processes will not scale under the new regime. Institutions that continue to rely on spreadsheets or fragmented systems will struggle with accuracy, timeliness, and audit defensibility.
TaxDo: Technical Infrastructure for CRS 2.0 Compliance
CRS 2.0 introduces a data dense reporting environment that makes automation a strategic necessity. TaxDo provides a regulatory grade infrastructure designed specifically for global AEOI regimes.
The Global Tax Ledger (GTL) enables real time TIN validation against official databases in more than 130 jurisdictions and automatically generates CRS ready XML files.
The Global Identity Verification (GSV) engine checks TIN syntax and structure across 195 jurisdictions and satisfies the CRS 2.0 reasonableness requirements in cases where direct authority verification is unavailable.
The Global Identity Intelligence Engine (GIIE) conducts continuous AML, PEP, and sanctions screening across more than 290 watchlists, automatically flagging changes in status for controlling persons and high risk clients.
TaxDo integrates onboarding, self-certification capture, e signatures, due diligence workflows, remediation cycles, and XML filing. This reduces reporting errors, improves governance, and stabilizes cross border compliance under the expanded CRS framework.
Conclusion
CRS 2.0 represents a structural evolution in South Africa’s approach to cross border financial transparency. Its expanded asset coverage, more demanding due diligence framework, and updated XML taxonomy require institutions to strengthen their data governance and upgrade their systems before the 2026 effective date.
Institutions that adopt modernized workflows and automation platforms such as TaxDo will be better positioned to manage the operational complexity of CRS 2.0 and deliver accurate, audit ready reporting across the OECD AEOI network.