Following the OECD’s significant update to the Common Reporting Standard (“CRS 2.0”) and Guernsey’s recent implementation announcements, now is a critical time for Financial Institutions (“FIs”), Trustees, Fund Administrators and Corporate Service Providers to revisit their FATCA and CRS classifications, governance frameworks and reporting processes.
What has changed under CRS 2.0?
Expanded scope of financial institutions and accounts
CRS 2.0 significantly broadens the scope of entities and products within the regime, including:
- Depository Accounts now include electronic money (e-money) and Central Bank Digital Currencies (CBDCs). Entities holding these products for customers may now be classified as Depository Institutions.
- Investment Entities are expanded to include those investing in crypto-assets, with crypto-asset derivatives now treated as Financial Assets.
Enhanced due diligence and reporting requirements
Key reporting and due diligence changes include:
- Annual CRS reports must now confirm whether valid self-certifications are on file.
- Mandatory reporting of Controlling Person roles for Equity Interests in legal arrangements
- Identification and reporting of joint accounts and the number of account holders.
- Clear identification of new versus pre-existing accounts for due diligence purposes.
- Mandatory categorisation of account types in CRS reporting.
Changes to CRS reportable jurisdictions
In addition to changes introduced through CRS 2.0, Reporting Guernsey Financial Institutions must ensure alignment with the published CRS jurisdiction lists to avoid non‑compliance and enforcement action.
For the CRS 2025 Reportable Period, Cameroon and Qatar were added, and Tunisia was removed from the list of reportable jurisdictions, respectively. In addition, Papua New Guinea and Paraguay were provisionally added to the 2026 Reportable Period.
Strengthened penalty regime in Guernsey
A key practical change is the introduction of a new penalty basis. Guernsey Financial Institutions that do not submit their 2025 FATCA and/or CRS reports by 30 June 2026 will receive an initial £300 penalty (per report) issued on 1 July 2026.
If reports remain outstanding, daily penalties of £50 will apply for 30 days. Continued non‑compliance will see penalties escalate monthly per report as follows:
- From 2 August 2026: £100 per day
- From 1 September 2026: £250 per day
- From 1 October 2026: £500 per day
- From 1 November 2026: £750 per day
- From 1 December 2026: £1,000 per day
What this means for you
These changes introduce both compliance risk and planning opportunity:
Time to review:
- Entity classifications (FI vs NFE, Active vs Passive, Trusts, Sponsor arrangements, etc.)
- Internal policies and onboarding processes
- Self‑certification forms and data validation processes
- Reporting systems and data governance frameworks
Our standard services include:
- Assessing and confirming entity and structure classifications under FATCA and CRS
- Reviewing reporting obligations under the updated regime
- Supporting remediation and clean‑up projects ahead of the 2026 reporting cycle
Bespoke support for Corporate Service Providers
We also offer bespoke advisory and project‑based assistance, including:
- Classification support across complex client portfolios
- Review of onboarding/Self‑Cert templates
- Reporting file checks (XML reasonableness and compliance)
- Remediation of historical reporting or documentation gaps
Next steps
With CRS 2.0 now in effect and updated Guernsey guidance issued, we recommend undertaking a CRS/FATCA Health Check ahead of the next reporting cycle to ensure compliance and mitigate penalty risk.
We are here to help you navigate these changes with clarity and confidence.
Please get in touch if you would like to discuss a review or require tailored support.
