Further to our recent update, the DITC has issued an updated CRS Entity Self-Certification Form and Individual Self-Certification Form to reflect the recent amendments to the CRS as implemented in the Cayman Islands. Our full advisory on the recent amendments to the CRS can be accessed on our website.
Whilst each FI is still able to use its own CRS self-certification form (even if this is online), going forward FIs need to ensure their self-certification forms capture all of the new data points included in the DITC's updated self-certification form.
Key changes are that the updated self-certification forms require confirmation of (i) whether there is more than one jurisdiction of tax residence for the Account Holder, and (ii) the mandatory provision of a Tax Identification Number (TIN) in respect of each such jurisdiction (or an adequate reason for an Account Holder not having one). FIs may not have always required this information in the self-certification form before, based on the previous drafting of the DITC's template CRS self-certification form.
Finally, self-certification forms still require an appropriate signature or attestation, but this requirement has been crystallised in the new regulations.
The new data points are required from 1 January 2026, and will need to be included by FIs in their updated CRS annual returns for 2026 in respect of each Account Holder. FIs may need to request this new top-up data from Account Holders onboarded from 1 January 2026 but prior to the new self-certification forms being implemented.
We would be happy to review your CRS self-certification forms to ensure the necessary information is collected.
Focus on data quality
The DITC has recently had a greater focus on data quality. The DITC has been reaching out to FIs regarding data quality issues identified in 2024 CRS reporting, with the expectation that these are remediated ahead of the upcoming reporting cycle. Based on the DITC correspondence, key areas of concern include:
- Missing or invalid TINs
o No TIN or functional equivalent provided for the account holder and/or controlling persons.
o Alternatively, the TIN provided does not follow the correct jurisdictional format. FIs can use the OECD AEOI Implementation Portal as a source for validating TIN formats.
- Missing date of birth
o No date of birth provided for reportable individuals or controlling persons.
- Address information deficiencies
o Full residential address not provided. A complete residential address is required, including postal code.
o Alternatively, the residential address does not align with the declared jurisdiction of tax residence. In these circumstances, FIs should ensure there is documentation explaining the apparent discrepancy.
Upcoming reporting deadline and DITC portal closure
The DITC issued an advisory on [DATE] informing industry that following the 31 July 2026 deadline for submitting CRS returns in relation to the 2025 reporting period, the DITC Portal will be closed for the submission of CRS XMLs and Filing Declaration in early August 2026. This is to enable the DITC Portal to be updated such that the CRS XML Schema version 3.0 can be filed in future reporting periods.
The submission of any new CRS XML files, or amendments to previously submitted files, will not be possible until the functionality is reinstated on the DITC Portal, which is anticipated to be in early 2027. This does not constitute an extension to the 31 July 2026 deadline. As such, it is important that all Reporting FIs have procedures in place to meet the 31 July 2026 deadline in respect of the 2025 reporting period.
Once the DITC Portal reopens in early 2027, all FIs will be required to submit any new Reportable Accounts, corrections, or deletions using XML Schema v3.0, which includes the new reporting fields captured by the updated self-certification forms referred to above.
The DITC has also confirmed that the CRS XML Generator Tool currently available on the DITC website will no longer be available after 31 July 2026. Any FIs that use this tool currently will need to find an alternative solution for next year's reporting deadline.
How we can help
Our teams support clients with a full suite of AEOI services, including entity classification analysis, GIIN registrations, DITC notifications, CRS and FATCA reporting, CRS Compliance Form submissions, policies and procedures, training, assistance with enforcement action and ongoing compliance support.
