Greece CRS 2.0: A Strategic Compliance Guide for Banks and RFIs

Greek financial institutions are entering a decisive phase in the evolution of cross-border tax reporting. Beginning 1 January 2026, the OECD’s revised Common Reporting Standard—widely referred to as CRS 2.0—extends mandatory reporting to electronic money instruments, central bank digital currencies (CBDCs), and indirect exposures to crypto-assets.

This shift complements the EU’s Directive on Administrative Cooperation (DAC8) on crypto-asset transparency, which Greece has implemented through Law 5193/2025. Oversight lies with the Independent Authority for Public Revenue (AADE) and the Hellenic Capital Market Commission (HCMC). The coming framework demands tighter due diligence, stronger data validation, and more resilient reporting infrastructures from all Reporting Financial Institutions (RFIs). For banks, custodians, fintechs, and digital-asset operators, understanding the new landscape is essential to maintaining compliance and avoiding penalties.

What CRS 2.0 Changes

The original CRS, introduced by the OECD in 2014, created a unified system for the automatic exchange of financial account information among more than 120 jurisdictions. Greece joined the framework in 2017 and began its first exchanges in 2018 through AADE, reporting millions of accounts annually.

The updated version—based on the OECD’s consolidated text released 2 June 2025—closes gaps exposed by recent financial innovation. Among the most significant upgrades are:

• Inclusion of electronic money products and CBDC accounts
• Reinforced due diligence aligned with FATF standards
• Anti-avoidance provisions targeting circumvention schemes
• Integration with the Crypto-Asset Reporting Framework (CARF) under DAC8

For Greek RFIs, the result is far more granular reporting involving account holders, controlling persons, and transactional flows. Data reported for 2026 will form the basis of international exchanges commencing in 2027. The objective is a stronger, more future-proof reporting ecosystem that reflects the rise of digital finance without compromising transparency.

Greece’s Regulatory Roadmap

Within the EU, CRS is implemented through DAC2 (Directive 2014/107/EU), which Greece incorporated via Law 4378/2016. Ongoing amendments are coordinated by AADE. While the EU prepares broader CRS-related changes (expected under DAC9), the immediate overhaul concerns DAC8, adopted by the EU in October 2023 and transposed into Greek law through Law 5193/2025 after consultations in mid-2025.

AADE’s June 2025 guidance updated the list of reportable jurisdictions and stressed enhanced due diligence obligations. The HCMC continues to regulate investment entities under MiFID II and AML legislation.

Key dates include:

• 1 January 2026: CRS 2.0 due diligence rules take effect in Greece
• 31 July 2027: First CRS 2.0 / DAC8 submissions for 2026 data
• Penalties: €10,000–€100,000 per violation under Law 5073/2023, with higher fines for repeated or systemic breaches

Banks and RFIs must adjust onboarding, verify tax residencies, track changes in account status, and identify any link to crypto-based assets.

Who Falls Under CRS 2.0 in Greece

The updated framework expands coverage across Greece’s financial ecosystem to include traditional institutions and emerging digital-asset operators. The aim is uniform transparency across increasingly interconnected markets.

Affected entities include:

Depository Institutions

Commercial banks and e-money issuers must implement mandatory self-certification and digital verification from 2026, covering balances and income generated.

Custodial Institutions

Brokers, private wealth managers, and crypto custodians face obligations to classify and report securities, funds, tokenized assets, and especially stablecoins or indirect crypto exposures.

Investment Entities

Fund managers, asset management companies, and family offices must monitor controlling persons in cross-border structures and track tax residency revisions.

Specified Insurance Companies

Providers of cash-value or investment-linked policies will align their due diligence procedures with banking-level standards.

Crypto-Asset Service Providers (CASPs)

Operators handling cryptocurrencies, NFTs, or DeFi activity—newly in scope via DAC8—must run full KYC, report user transactions, and integrate with AADE’s exchange systems.

Passive Non-Financial Entities

Trusts and foundations are subject to intensified UBO identification, including verification of TINs and cross-referencing corporate and regulatory databases to ensure traceability.

Across the market, Greek institutions are consolidating data from banking, investment, and blockchain sources to meet the unified requirements of CRS 2.0 and DAC8.

How Reporting Will Operate

Data is collected and submitted under AADE’s supervision using the OECD’s updated XML schema (October 2024). RFIs must prepare:

TINs are compulsory for all new accounts. For pre-existing accounts, institutions must make “reasonable efforts” to obtain them within two years. Reports must remain audit-ready, feeding into the EU’s Central Directory for exchange with partner countries.

Digital-Asset Compliance Under CRS 2.0

Greece has aligned CRS 2.0 with DAC8 to cover cryptocurrencies, stablecoins, NFTs, and DeFi arrangements where an intermediary facilitates transactions.

RFIs offering digital services must classify crypto holdings accurately and convert values into fiat equivalents for reporting. Banks providing custody will need to validate tax residencies, while CASPs are integrating APIs for blockchain-based transaction monitoring. These efforts are guided by AADE’s June 2025 updates and HCMC’s AML framework.

This integration positions Greece among the most proactive jurisdictions in regulating digital finance within the EU.

TaxDo: Infrastructure for Scalable CRS 2.0 Compliance

With CRS 2.0 generating significantly denser datasets, automation becomes indispensable. TaxDo offers a purpose-built technical stack for global AEOI regimes:

• Global Tax Ledger (GTL): Real-time TIN verification across 130+ jurisdictions and automated CRS-ready XML generation
• Global Identity Verification (GSV): Syntax and structural validation for TINs in 195 jurisdictions, supporting CRS 2.0 reasonableness standards
• Global Identity Intelligence Engine (GIIE): Ongoing AML, PEP, and sanctions screening across more than 290 watchlists, alerting institutions to status changes

The platform unifies onboarding, self-certification, e-signatures, due-diligence workflows, remediation procedures, and XML filing—reducing errors and strengthening governance across cross-border compliance.

Practical Measures for RFIs

Institutions preparing for the 2026 start date should prioritize:

• Long-term record retention (minimum six years in Greece)
• Updated self-certification processes
• Automated monitoring for high-value accounts
• Staff training on DAC8 obligations
• Internal audits to identify gaps before filings begin
• Adoption of scalable compliance software suited to multi-asset reporting

Global Benchmarks and Implementation Timelines

These benchmarks illustrate Greece’s relatively early alignment and its intention to position itself competitively in transparent global finance.

Key Takeaways for Greek RFIs

As the 1 January 2026 deadline approaches, institutions should concentrate on four priorities:

1. Stronger Onboarding & KYC – Expand data capture to meet CRS 2.0 and DAC8 requirements.
2. Real-Time Data Validation – Ensure accurate TINs and identifiers across jurisdictions.
3. Digital-Asset Integration – Implement systems capable of reporting tokenized and crypto holdings.
4. Training & Internal Audits – Build internal expertise to sustain long-term compliance.

Proactive preparation will reduce operational risk and reinforce Greece’s reliability in international tax cooperation.

Conclusion

CRS 2.0 marks a turning point in Greece’s engagement with global tax transparency. By adopting advanced due-diligence practices, validating identifiers thoroughly, and incorporating digital-asset oversight, Greek RFIs can meet the 2026 standards with confidence. Early adaptation not only mitigates regulatory exposure but strengthens institutional resilience in an increasingly digitized financial landscape.