Bermuda CRS: CITA steps up supervision and information requests

A more active supervisory environment

The Corporate Income Tax Agency (CITA) became Bermuda’s competent authority for CRS reporting with effect from 13 March 2026. CITA has since begun exercising that role through targeted compliance activity which has led to a significant amount of increased outreach across Bermuda.

In April 2026, Walkers reported that CITA had commenced issuing notices to selected Bermuda Reporting Financial Institutions (RFIs) requiring CRS compliance reviews. Our advisory can be found here.  A recipient must either appoint a CITA-approved independent reviewer or elect for CITA to conduct the review. The notices issued by CITA typically require acknowledgment within 10 days and submission of the independent report within 90 days.

CITA has also publicly emphasised that CRS compliance will be monitored. Its current CRS published materials encourage RFIs to correct historically submitted filings and highlight data quality, account due diligence, portal administration and entity-classification issues that may lead to follow-up or additional compliance reviews.

Against that background, CITA’s requests for information about the CRS status of Bermuda entities should be viewed as part of a broader shift toward active supervision, testing and remediation, not merely as administrative confirmation exercises.

Why CRS status requests can be complex

CRS status is a legal classification which depends on the entity’s factual circumstances. It cannot safely be determined from an entity’s name, regulatory label, FATCA status or Global Intermediary Identification Number alone. 

Depending on the entity and the period in question, the analysis may require consideration of:

• the entity’s residence and the jurisdiction whose rules determine its CRS status;
• whether it accepts deposits, holds Financial Assets on account of others, engages in certain insurance business or invests on behalf of others;
• the nature and source of its gross income and the assets or activities that generate that income;
• whether the entity is 'managed by' another Financial Institution for CRS purposes;
• whether it maintains Financial Accounts, including equity or debt interests that are treated as Financial Accounts in certain circumstances;
• whether changes in activities, management, residence, liquidation status or ownership affected the classification during the period under review;
• whether it is entitled to a Non-Reporting Financial Institution status or another relevant exclusion; and
• its historic registrations, nil returns, annual reports, compliance forms, policies and underlying due diligence records.

The analysis may therefore require input from directors, investment managers, administrators, trustees, insurers, corporate service providers and other delegates. Outsourcing does not transfer ultimate CRS responsibility away from the Bermuda Financial Institution.

Exemptions and other relief may be relevant

A CITA request should not be approached on the assumption that every Bermuda entity previously treated as a Reporting Financial Institution must remain a Reporting Financial Institution. 

Recommended response steps

1. Triage the request immediately. Confirm the legal entity, period, scope, response deadline, required format and whether CITA is seeking a status confirmation, documents, remediation or an independent review.
2. Preserve the record. Collect portal correspondence, registrations, prior filings, annual compliance forms, written CRS policies, self-certifications, due diligence files and advice supporting the historic classification.
3. Reperform the classification analysis. Test the entity’s status against its actual activities and arrangements for each relevant period, rather than relying on a historic label, FATCA classification or service-provider assumption.
4. Identify reporting exceptions precisely. Determine whether the position concerns entity status, Non-Reporting Financial Institution treatment, absence of Financial Accounts, an Excluded Account or threshold relief, and document each condition.
5. Reconcile the answer with filings. Check whether portal registrations, reports, nil returns, annual compliance forms and underlying records are consistent with the proposed response. Identify any correction, deactivation or remediation that may be required.
6. Coordinate a controlled response. Use a clear factual narrative, provide only responsive and verified materials, explain any judgment calls, and maintain an audit trail of the analysis and approvals. Legal advice should be considered where classification or remediation is not straightforward.

How Walkers can help

We can assist Bermuda entities, boards and service providers with:

• acting as an independent reviewer in relation to any CITA required independent CRS compliance audit,
• reviewing and responding to CITA information requests and compliance-review notices;
• preparing or refreshing entity-level CRS classification analyses;
• assessing potential Non-Reporting Financial Institution treatment, account exclusions and threshold relief;
• testing historic filings and governance records against the legal analysis;
• supporting remediation, correction and portal deactivation strategies; and
• coordinating with administrators, managers, trustees, insurers and independent reviewers.

For further information or assistance in respect of a CRS information request, please contact a member of our Bermuda office's Regulatory & Risk Advisory team.