CRS 2.0 Compliance Software

CRS 2.0 is the amended OECD Common Reporting Standard — the global framework under which financial institutions identify the tax residency of their account holders and report those accounts to their own tax authority for automatic exchange with other jurisdictions. The amendments were approved by the OECD Council in August 2023, and apply in the EU from 1 January 2026 through DAC8; other jurisdictions set their own start dates. Against CRS 1.0 it makes TIN validation mandatory rather than best efforts, strengthens the Reasonableness Test, requires CBI/RBI enhanced due diligence, and brings digital assets — crypto, e-money and CBDCs — explicitly into scope.

An account is reportable when a financial institution maintains it and it is held by a Reportable Person, meaning someone tax resident in a Reportable Jurisdiction, or by a passive non-financial entity with a controlling person who is one. Financial accounts cover depository and custodial accounts, equity and debt interests in investment entities, and cash value insurance and annuity contracts. Excluded accounts, such as qualifying retirement and pension accounts, are out of scope, and listed companies, governments and financial institutions are not Reportable Persons. TaxDo runs indicia detection and controlling person look-through at onboarding so each account is classified before reporting.

Reporting Financial Institutions do: any financial institution in a participating jurisdiction that is not a Non-Reporting Financial Institution. Under the standard a financial institution is a custodial institution, depository institution, investment entity or specified insurance company, so it covers banks, brokers and custodians, funds, and insurers that issue cash value or annuity contracts. CRS 2.0 also treats institutions holding e-money products or central bank digital currencies for customers as depository institutions. Governmental entities, central banks and certain pension funds are Non-Reporting. Reporting is annual, in the calendar year after the one the information relates to. TaxDo covers self-certification, TIN validation and CRS XML v3.0 reporting.

The amendments were approved by the OECD Council in August 2023. CRS 2.0 introduces mandatory TIN validation (replacing best efforts), a strengthened Reasonableness Test requiring cross-checks against all information on file, mandatory CBI/RBI enhanced due diligence, explicit inclusion of digital assets (crypto, e-money, CBDCs), new account type flags, specified controlling person roles, new/pre-existing account status requirements, 5-year data retention, and a backward-incompatible CRS XML Schema v3.0.

Yes. CRS 1.0 allowed best-efforts TIN collection. Under CRS 2.0, TIN validation is mandatory. Financial institutions must validate every TIN against the issuing jurisdiction's format and issuance rules. Syntax-only checks are no longer sufficient — official lookup is required where available. Institutions cannot accept self-certifications with TINs that are known or reasonably suspected to be invalid.

Under CRS 2.0, the Reasonableness Test requires financial institutions to cross-check every self-certification against all information held on file — not just a subset of fields. Institutions cannot accept self-certifications that are known or reasonably suspected to be incorrect or unreliable. This is a significant upgrade from CRS 1.0, which allowed more limited cross-referencing.

CRS 2.0 mandates enhanced due diligence for account holders who obtained citizenship or residence through investment programmes (CBI/RBI). Financial institutions must systematically identify high-risk schemes, flag accounts linked to CBI/RBI jurisdictions, and apply additional scrutiny to self-certifications and tax residency claims from these account holders.

Yes. CRS 2.0 explicitly brings crypto-assets, e-money products, and central bank digital currencies (CBDCs) into scope. Investment entities, e-money institutions, and platforms dealing in digital assets are now reporting entities under CRS with the same self-certification, TIN validation, and due diligence requirements as traditional financial institutions.

CRS XML Schema v3.0 was published by the OECD alongside the amended CRS standard. It is backward incompatible with CRS XML v2.0, introducing backward-incompatible changes to the header structure, adding mandatory NewOrPreExistingAccountType and AccountType elements, and requiring controlling person role specification. Additional mandatory fields include account type flags (Depository, Custodial, DebtEq, CashValue, Other) and new/pre-existing account status. Existing reporting infrastructure requires migration.

The OECD publishes the authoritative list. Its status of commitments groups participating jurisdictions by the year they committed to start exchanging financial account information, from 2017 onward, and it is updated as new jurisdictions join. The countries you report on depend on the Reportable Jurisdictions list your own jurisdiction publishes. The United States is not on the OECD commitments list: it has exchanged account information under FATCA since 2015 through intergovernmental agreements instead. Check the OECD automatic exchange of information portal for the current list. TaxDo validates TINs against official issuing-country sources at self-certification.

As of 30 September 2026, 130+ jurisdictions have committed to CRS exchanges (OECD Global Forum). In 2022, information on over 123 million financial accounts, covering around €12 trillion in assets, was exchanged automatically (OECD Global Forum). The OECD list has five jurisdictions committed to start exchanges by 2025: Armenia, Morocco, Rwanda, Senegal, and Uganda. The CRS 2.0 amendments apply in the EU from 1 January 2026 through DAC8; other jurisdictions bring them in through their own legislation and timetable, with jurisdiction-specific penalty frameworks and reporting variations.

A CRS self-certification is a statement from the account holder that gives their tax residence and the other details the institution needs for due diligence and reporting. Institutions usually collect it on a self-certification form, often as part of account opening, and must check it for reasonableness against the other information they hold. For a new individual account it is valid only if signed or positively affirmed, dated, and showing name, residence address, tax residence, TIN for each Reportable Jurisdiction (unless an exception applies) and date of birth. The OECD publishes sample forms, but none is mandatory. TaxDo provides guided digital self-certification for individuals and entities.