Switzerland CRS 2.0: Essential Compliance Guide for Banks and RFIs 

Swiss financial institutions face a landmark compliance shift. From 1 January 2026, CRS 2.0 broadens cross-border reporting to cover digital assets, requiring precise account identification, TIN validation, and continuous monitoring. The Federal Council’s September 2024 rules and SIF’s May 2025 CARF guidance provide the legal and technical framework, making a clear understanding of CRS 2.0 essential for operational readiness. 

Understanding CRS 2.0 

Originally launched in 2014, the CRS established a global mechanism for automatic exchange of financial-account information among over 120 jurisdictions. CRS 2.0, effective 1 January 2026, closes gaps by capturing electronic money, CBDCs, and tokenized assets, while introducing tighter due-diligence and anti-avoidance rules. The June 2025 consolidated OECD text integrates these revisions with the Crypto-Asset Reporting Framework, aligning crypto transparency with traditional finance and expanding obligations for Reporting Financial Institutions to ensure accurate identification, TIN validation, and cross-border reporting. 

Switzerland’s Regulatory Path 

Switzerland finalized its CRS 2.0 implementation package in September 2024, updating the Ordinance on the International Automatic Exchange of Information in Tax Matters and related guidance. The May 2025 CARF circular from SIF clarified tokenized-asset treatment, linking virtual-asset service providers (VASPs) and banks under a unified compliance perimeter. 

The Federal Tax Administration (FTA) will require first reports by 31 May 2027 for the 2026 reporting year. From 2026, all Swiss RFIs must collect enhanced self-certifications, verify Tax Identification Numbers (TINs), and monitor accounts for any change in tax residency or asset type, including crypto-linked instruments. 

Who Is Affected 

CRS 2.0 expands the reporting perimeter across the Swiss financial ecosystem. No longer limited to traditional deposit and investment accounts, the new framework captures digital-asset service providers and insurance-linked investment products under a single compliance umbrella. 

The categories under Swiss CRS 2.0 obligations are: 

• Depository Institutions including Swiss banks, cantonal banks, and e-money issuers. These institutions face enhanced onboarding requirements with mandatory self-certifications and digital TIN verification for all new accounts opened from 2026. 

• Custodial Institutions such as brokers, private banks, and crypto custodians. They must report traditional securities, funds, and tokenized assets held in custody. A Swiss private bank offering digital-asset custody must classify and report stablecoin holdings under CARF-aligned fields. 

• Investment Entities including fund managers, asset managers, and family offices. Institutions must verify controlling persons for every structure under management, including cross-border SPVs, and perform ongoing due diligence for changes in tax residency or ownership. 

• Specified Insurance Companies providing cash-value and investment-linked products. These institutions perform due diligence similar to banks, extending reporting to policyholders with embedded investment components. 

• VASPs and Digital-Asset Custodians newly incorporated via CARF alignment. They must apply the same KYC, TIN, and reporting standards as banks. Wallets, exchanges, and token-issuance platforms fall under the FTA’s automatic exchange scope. 

Passive Non-Financial Entities, such as trusts and foundations, are subject to heightened scrutiny. Institutions must identify every controlling person, verify each TIN, and record roles within the entity. This ensures traceability across multi-layered ownership structures. 

Swiss financial institutions must integrate multiple data streams including banking, investment, and blockchain into a single audit-proof reporting pipeline.  

How Reporting Works 

Swiss RFIs must collect, validate, and transmit the following data to the FTA for exchange with partner jurisdictions: 

TINs are mandatory for new accounts and must be pursued for legacy accounts within two years. Institutions must demonstrate documented “reasonable efforts” for any missing identifiers.

For a detailed walkthrough of reporting obligations, data formats, and compliance best practices, refer to CRS 2.0 Compliance Guide for Banks & FIs

Integrating Digital-Asset Compliance 

Switzerland’s CRS 2.0 regime merges seamlessly with CARF, covering tokenized securities, stablecoins, and indirect crypto exposures. RFIs offering custody or investment services through distributed-ledger platforms must classify such holdings and report proceeds accordingly. 
Private banks are integrating API-based crypto-asset discovery tools, while cantonal banks and fintechs are aligning blockchain-based client onboarding with CRS 2.0 self-certification fields. These steps ensure parity between traditional and digital portfolios — a hallmark of Swiss regulatory precision. 

TIN Validation, Ongoing Due Diligence, and Advanced Compliance Tools with TaxDo 

Accurate Tax Identification Number (TIN) reporting is central to CRS 2.0 compliance. Invalid or missing TINs can result in rejected filings, penalties, and delays in cross-border data exchange. Under CRS 2.0, all Reporting Financial Institutions (RFIs)—banks, custodians, insurers, and digital-asset platforms—must verify TIN syntax, structure, and authenticity across jurisdictions to ensure precise, auditable reporting. 

TaxDo provides a comprehensive solution to streamline the compliance process with a full suite of services: 

• TIN Verification 
  Automated, real-time TIN validation checks against global tax authority databases in over 130 countries, ensuring accuracy for compliance with Swiss CRS 2.0 standards. 

• Global Real-Time TIN Lookup (GTL): Validates TINs directly against official tax authority databases in 130+ countries. 

• Global TIN Syntax Verification (GSV): Checks TIN format, structure, and checksum across 195+ jurisdictions, ensuring accuracy for both individuals and entities. 

• Due Diligence and Ongoing Monitoring 
  Continuous account-holder screening against over 290 global watchlists, including AML, PEP, and sanctions lists, ensuring that changes in account holder status are flagged in real time. This automated process minimizes human errors and ensures timely action to maintain compliance. 

TaxDo’s solution automates key aspects of CRS 2.0 compliance for Swiss financial institutions, including: 

• Form Collection & E-signature 
  Collect all required self-certification forms and ensure they are properly e-signed, streamlining the documentation process. 

• TIN Validation 
  Conduct real-time TIN checks using GTL and GSV, ensuring that all records align with Swiss tax compliance requirements. 

• Due Diligence (GIIE Screening) 
  Perform ongoing due diligence with TaxDo’s Global Identity Intelligence Engine (GIIE) to screen account holders against international sanctions, PEPs, and other relevant databases. 

• Automated CRS Reporting 
  Generate and submit CRS-compliant XML reports to the Federal Tax Administration (FTA), ensuring accurate and timely reporting. 

These tools streamline workflows, reduce manual errors, minimize regulatory risk, and ensure audit readiness. Integration of automated TIN validation and monitoring tools such as TaxDo ensures reporting obligations are met efficiently, errors are minimized, and compliance with CRS 2.0 is maintained. 

Practical Compliance Measures for Financial Institutions 

Financial institutions should implement robust recordkeeping, maintain updated self-certifications, continuously monitor account holder status, and leverage automation for due diligence and reporting. Using TaxDo, Swiss institutions can ensure precise compliance with AEOIA, CRS 2.0, and related international standards while minimizing operational risk. 

Global Benchmarks and Timelines 

As CRS 2.0 and CARF transform global financial reporting, timing and precision are essential. The table below shows Switzerland’s milestones alongside other key jurisdictions, highlighting readiness, gaps, and the competitive advantage of early compliance. These alignments position Switzerland at the forefront of CRS 2.0, setting a benchmark for transparency and early CARF integration. 

These alignments position Switzerland at the forefront of CRS 2.0 readiness, setting a benchmark for precision, transparency, and early CARF integration. 

Compliance Takeaway

Swiss RFIs face a decisive compliance milestone by 1 January 2026. To stay ahead, institutions must ensure they are fully prepared across people, processes, and technology: 

1. Enhanced Onboarding and KYC: Upgrade systems to collect expanded self-certifications and capture new account-holder data required under CRS 2.0. 

2. TIN and Data-Quality Validation: Embed real-time checks into reporting pipelines to ensure accurate, audit-ready submissions. 

3. Automated Crypto and Tokenized Asset Discovery: Align discovery and reporting tools with CARF to cover the full spectrum of digital assets. 

4. Internal Audit and Training: Equip teams with the knowledge and processes to meet the June 2025 OECD standards, ensuring ongoing compliance. 

Swiss RFIs that tackle these four areas now will reduce reporting risk, stay ahead of regulators, and maintain competitive trust with international partners. 

Conclusion 

CRS 2.0 establishes a new framework for Switzerland’s financial transparency and cross-border CRS 2.0 establishes Switzerland as a global benchmark for financial transparency. Reporting Financial Institutions must enhance due diligence, validate tax identifiers, and monitor both traditional and tokenized assets. Institutions implementing these measures before 2026 will ensure accurate reporting, audit readiness, and full compliance with international standards.