Common Reporting Standard and Economic Substance updates

Following the introduction of CRS 2.0 since 1 January 2026, the Department for International Tax Cooperation (DITC) has issued a few practical updates to Common Reporting Standard (CRS) and Economic Substance (ES). This update provides a summary of these changes.

CRS and FATCA deadlines 

The current deadlines for FATCA and CRS Reporting are:

• 31 July 2026 – FATCA and CRS Reporting for the 2025 reporting year
• 15 September 2026 – CRS Compliance Form for the 2025 reporting year

The DITC has issued a reminder of this upcoming deadline, however, Financial Institutions (FI) should be aware upcoming changes to these deadlines.

• The registration deadline for entities which became FIs during 2026 will now be 31 January 2027. This has moved from 30 April of the following year that an entity became an FI.
• The FATCA Reporting, CRS Reporting and CRS Compliance Form deadlines will all move to 30 June 2027 from the deadlines mentioned above.

Our Tax Reporting team in Mourant Governance Services is using this year as a transitional period by using the 2025 Reporting year as a trial run for the 30 June deadline. FIs should be aware that these changes in deadline may cause some significant pressure points particularly given the proximity to audit sign offs and Fund Annual Returns (FARs).

Closure of the DITC Portal for the submission of CRS XMLs

Since the introduction of CRS 2.0, which came into law from 1 January 2026, an updated XML Schema was due to be put into use. DITC has also informed Portal users that as a result of the change to CRS XML Schema version 3.0 (XML v3.0) the DITC Portal will be closed for the submission of CRS XMLs and Filing Declarations in early August 2026.

This will allow the DITC to make the necessary amendments to the Portal to allow for the new Schema. FIs should not see this as an extension of the reporting deadline and should ensure that reports are filed in a timely manner.

FIs should consider entities in their structure which have liquidated or struck off during 2026 and if they would like to get these filings in along with the FI Deactivation request before the portal is shut down.

Further support

• The updated OECD CRS XML Schema User Guide (v 4.0) and XML Schema v3.0 XSD files can be found on the OECD Tax Transparency Resource Centre.
• Review our update for more information on CRS 2.0 and its introduction.

CRS XML generator tool

The DITC has confirmed that with the transition to CRS XML Schema v3.0, the DITC will no longer be providing an XML generator tool. FIs should look to make the necessary arrangements to source a CRS XML Generator Tool.

Our Tax Reporting team has the necessary tools to prepare XMLs under the new schema so if you need assistance with this, please reach out to any of the contacts listed on this page.

Updated CRS self-certification forms 

On 19 May 2026, the DITC issued new Self-Certification Forms that were effective from 1 January 2026 to align with the new CRS 2.0 regulations that came into effect. The new forms are available from the DITC website.

On the face of it, the updates look minimal. There have been some guidance notes added to the beginning of the forms and a number of asterisks added to required fields. The required fields are listed below:

Individual

1. Name
2. Permanent residence address
3. Jurisdiction(s) of residence for tax purposes
4. Tax Identification Number or functional equivalent for all jurisdictions of residence
5. Date of birth
6. Place of birth
7. Signature or attestation of the form
8. Date of signature or attestation

Entity

1. Name
2. Registered or Residence address
3. Jurisdiction(s) of residence for tax purposes
4. Tax Identification Number or functional equivalent for all jurisdictions of residence
5. The type of Reporting Financial Institution, Non-Reporting Financial Institution or Non-Financial Entity, the entity is
6. Signature or attestation of the form
7. Date of signature or attestation

Controlling person

1. Name
2. Permanent residence address
3. Jurisdiction(s) of residence for tax purposes
4. Tax Identification Number or functional equivalent for all jurisdictions of residence
5. Date of birth
6. Place of birth
7. Signature or attestation of the form
8. Date of signature or attestation

The biggest practical implication of these changes can be seen in the example of where a person from a non-participating jurisdiction under CRS was previously able to not provide their Place of Birth (PoB), Date of Birth (DoB) and Tax Identification Number (TIN).

Historically, a US Controlling Person would have been able to omit their PoB, DoB, and Social Security Number but this is no longer the case as the footnotes excluding these have been removed.

FIs should understand that the expectation is that these will be collected for all account holders who open accounts or who need to recertify their self-certificates due to a change in circumstance from 1 January 2026.

Updated CRS administration forms and CRS guidelines 

The DITC has advised that they are currently working on the administration forms on the DITC Portal. They will be aligned to the amended regulations and expect that these will be released in Q3 of 2026.

The DITC has also confirmed that they expect to release updated CRS 2.0 guidelines to industry in Q3 of 2026. FIs should ensure these guidelines are reviewed and considered ahead of completing reporting for the 2026 Reporting period.

Updated DITC Portal security

The DITC has also advised that to improve security of user information on the DITC, they will be introducing two-factor authentication (2FA) for accessing the DITC Portal. 2FA is currently in place for account activation.

FIs should ensure security around their logins and be aware that the new 2FA will be required for accessing their accounts. Do not get locked out of your account on reporting deadline day!

Economic substance communication

The DITC has confirmed that they will no longer be issuing courtesy emails to Responsible Persons (RPs) of entities with ES filing obligations ahead of the deadlines. The ES Act came into force in the Cayman Islands on 1 January 2019 outlining filing requirements.

Entities which have a filing obligation, have 12 months from their year-end to complete their ES Return.

Our Tax Reporting team will reach out if they have been designated as the Responsible Person for an Entity to confirm what is required for an approaching filing. These reach outs are generally done in Q3 of each year.