What is CRS reporting?
The Common Reporting Standard (CRS) is the global standard for automatic exchange of financial account information between tax authorities. Developed by the OECD in 2014, CRS requires financial institutions to identify accounts held by non-residents and report those accounts to their local tax authority — which then exchanges the data with the account holder's country of residence.
More than 100 jurisdictions have committed to CRS. It's the global equivalent of FATCA, but broader in scope: while FATCA targets US persons, CRS covers residents of every participating jurisdiction. Most financial institutions file both FATCA and CRS returns — from the same source data.
Under CRS, financial institutions must:
- Identify reportable accounts held by non-resident individuals and entities
- Apply due diligence rules — including self-certification and reasonableness checks
- Validate TINs against the account holder's jurisdiction of residence
- Report account holder and account data annually using the OECD CRS XML schema
- Submit to the local tax authority via the prescribed portal and schema
Why CRS reporting matters
Non-compliance carries escalating consequences. Financial institutions that fail to report — or that report incomplete or inaccurate data — risk:
- Penalties under local implementing legislation — these vary widely by jurisdiction
- Reputational damage — CRS compliance is a standard expectation for correspondent banks and counterparties
- Rejection by tax authorities — most portals return invalid XML with error codes that require re-filing. Use our XML validation tool to catch errors before submission.
- Enhanced regulatory scrutiny — repeated failures can trigger audits
Who must file CRS reports?
CRS reporting obligations fall on Reporting Financial Institutions (RFIs) — the CRS definition of entities that hold, manage, or administer financial accounts. The categories are broadly similar to FATCA's FFI definition, with a few jurisdictional variations.
| Entity Type | Reporting Obligation |
|---|---|
| Depository institutions | Report non-resident accounts — banks, credit unions, savings institutions |
| Custodial institutions | Report accounts holding financial assets for non-residents |
| Investment entities | Report non-resident investors — funds, hedge funds, private equity, trusts with investment activity |
| Specified insurance companies | Report cash value insurance and annuity contracts held by non-residents |
| Trusts (as Investment Entities) | Report when classified as Investment Entities under CRS rules |
What changes under CRS 2.0?
CRS 2.0 is the OECD's 2023 update to the Common Reporting Standard. It expands the scope of reportable accounts, updates the schema, and aligns CRS more closely with the Crypto-Asset Reporting Framework (CARF) and the EU's DAC8 directive.
What CRS 2.0 changes
- Digital assets: Certain crypto-asset holdings become reportable — including Central Bank Digital Currencies (CBDCs) and relevant digital financial products
- Self-certification: Additional fields required for tax residency and controlling person data
- Zero and negative balances: Clarifications on how (and whether) these accounts must be reported
- Expanded account scope: Broader definitions for certain investment entities and trusts
- Schema update: New XSD version (commonly referred to as CRS 3.0) with added elements for digital assets and updated data types
- TIN validation: Stricter requirements for validating TIN formats against the account holder's jurisdiction of residence
CRS 2.0 timeline
- 2026 reporting year: First year of CRS 2.0 reporting for most early-adopting jurisdictions
- 1 January 2027: Schema v3.0 becomes mandatory in Luxembourg, Ireland, and other EU jurisdictions
- 2027 reporting year: Widespread adoption across CRS-participating jurisdictions
How CRS 2.0 interacts with CARF and DAC8
CRS 2.0 is designed to work alongside two related frameworks:
- CARF (Crypto-Asset Reporting Framework): OECD framework for reporting crypto-asset transactions, filed alongside CRS in most jurisdictions
- DAC8 (EU Directive on Administrative Cooperation 8): EU-specific rules that incorporate both CRS 2.0 and CARF into a single reporting obligation for EU member states
Novus supports CRS today, including the CRS 2.0 schema. See our CRS Reporting Services for details.
CRS reporting deadlines by jurisdiction
CRS deadlines vary by jurisdiction, but most fall between May and September each year. The table below summarises current deadlines for major jurisdictions — click any jurisdiction to see jurisdiction-specific filing details.
| Jurisdiction | Filing Deadline | Filing Authority |
|---|---|---|
| India | 30 June | Income Tax Department (Form 61B, Report Type 02) |
| United Kingdom | 31 May | HMRC AEOI |
| Luxembourg | 30 June | ACD (SOFIE / FUNDSQUARE) |
| Ireland | 30 June | Revenue Commissioners (ROS) |
| Canada | End of June | CRA (Part XIX) |
| Switzerland | 30 June | ESTV/AFC |
| Cayman Islands | 31 July | DITC Portal |
Deadlines shown are based on current published guidance. Local authorities may extend or vary deadlines — always confirm with your jurisdiction's tax portal before filing.
CRS XML field reference
The tables below describe every field required in a CRS XML report. Each section maps to a specific part of the schema — the Submitting Entity, Reporting Financial Institution, Account Holder, Report Destination, Financial Account, and Controlling Persons.
Note: All field headers in your Excel file must match the "Field Name" column below exactly. Use the Reference Data section for coded values.1. Submitting Entity (SE)
| Field Name | Status | Description | Resources |
|---|---|---|---|
| SE Name | Mandatory | Name of entity registered on the reporting portal filing the XML report. | - |
| SE ID | Mandatory | Registration number or ID of the entity filing the report. | - |
2. "Reporting" Financial Institution (RFI)
| Field Name | Status | Description | Resources |
|---|---|---|---|
| RFI Name | Mandatory | Name of the Reporting Financial Institution. | - |
| RFI Code | Optional | Identification code of the financial institution (e.g. GIIN). | Verify GIIN |
| RFI Address | Mandatory | Street address of the financial institution. | - |
| RFI Address City | Mandatory | City of the financial institution. | - |
| RFI Address County | Optional | County/state/province of the financial institution. | - |
| RFI Address Post Code | Optional | Post code of the financial institution. | - |
| RFI Address Country | Mandatory | Two-letter country code of the financial institution. | ISO 3166-1 Alpha-2 |
| RFI Reporting from Country | Mandatory | Two-letter country code from where the FI is filing the report. | ISO 3166-1 Alpha-2 |
3. Account Holder (AH)
| Field Name | Status | Description | Resources |
|---|---|---|---|
| AH Given Name(s) | Optional | Mandatory if individual — name of individual account holder. | - |
| AH Family Name(s) | Optional | Mandatory if individual — name of individual account holder. | - |
| AH Entity Name(s) | Optional | Mandatory if entity — name of entity account holder. | - |
| AH Type | Optional | Mandatory if entity — CRS classification (e.g. CRS101, CRS102). | See Ref Data |
| AH TIN | Mandatory | Tax identification number of account holder. | - |
| AH TIN Country | Mandatory | Two-letter country code that issued the TIN. | ISO 3166-1 Alpha-2 |
| AH Date of Birth | Optional | Mandatory if individual — YYYY-MM-DD. | - |
| AH Country of Birth | Optional | Mandatory if individual — two-letter country code. | ISO 3166-1 Alpha-2 |
| AH Address | Mandatory | Street address. | - |
| AH Address City | Mandatory | City. | - |
| AH Address Country | Mandatory | Two-letter country code. | ISO 3166-1 Alpha-2 |
| AH Account Type | Mandatory | Type of account holder (select from Ref Data). | See Ref Data |
4. Report Destination
| Field Name | Status | Description | Resources |
|---|---|---|---|
| Report Destination Country | Mandatory | The two-letter country code of the tax authority where this report is being sent (e.g. DE for Germany). | ISO 3166-1 Alpha-2 |
5. Financial Account Details (FA)
| Field Name | Status | Description | Resources |
|---|---|---|---|
| FA Closed? | Mandatory | TRUE or FALSE. | - |
| FA Number | Mandatory | Free text field — unique account number. | - |
| FA Currency | Mandatory | Three-letter currency code (e.g., USD, EUR). | ISO 4217 Currency |
| FA Balance | Mandatory | Account balance as at 31 Dec. Format: 1000.00 (no commas). | - |
| FA Payments (Dividend) | Optional | Dividend payments made. | - |
| FA Payments (Interest) | Optional | Interest payments made. | - |
| FA Payments (Gross Proceeds) | Optional | Gross proceeds/redemption payments made. | - |
6. Controlling Persons (CP)
Note: Mandatory only if the account holder is a Passive NFE with Controlling Persons.| Field Name | Status | Description | Resources |
|---|---|---|---|
| CP Given Name(s) | Optional | Given name of the Controlling Person. | - |
| CP Family Name(s) | Optional | Family name of the Controlling Person. | - |
| CP TIN | Optional | Tax Identification Number. | - |
| CP TIN Country | Optional | Country code of the TIN. | ISO 3166-1 Alpha-2 |
| CP Type | Optional | Controlling Person Type Code (e.g. CRS801). | See Ref Data |
| CP Address Country | Optional | Two-letter country code. | - |
7. Reference Data
AH Type (Entity)
- CRS101: Passive Non-Financial Entity
- CRS102: Active Non-Financial Entity
- CRS103: Financial Institution — Investment Entity
CP Type
- CRS801: CP of Legal Person — Ownership
- CRS802: CP of Legal Person — Other means
- CRS803: CP of Legal Person — Senior Management
- CRS804: CP of Legal Arrangement — Settlor
- CRS805: CP of Legal Arrangement — Trustee
Common CRS reporting errors (and how to avoid them)
Most rejected CRS XML submissions fail for the same handful of reasons. The list below covers the errors we see most often in support — and how to prevent them.
1. Invalid TIN format for the account holder's jurisdiction
CRS requires the account holder's TIN to match the format expected by their country of residence. A US SSN doesn't validate as a UK UTR, and vice versa. Validate TIN formats before filing — mismatches trigger portal rejections in most jurisdictions.
2. Missing or incorrect Report Destination Country
The Report Destination Country element tells the receiving authority which jurisdiction to exchange the data with. If it's wrong, the report is filed against the wrong jurisdiction — a compliance failure even if the schema passes.
3. Wrong AH Type or CP Type codes
Entity classifications must match the enumeration values in the schema. Using CRS101 (Passive NFE) for an active entity, or omitting the CP Type for a controlling person, will fail validation.
4. Element ordering violations
The CRS XSD uses xs:sequence, which requires child elements in a specific order. Even if your data is correct, mis-ordered elements (e.g., Address fields before Name fields) will fail validation.
5. CRS 2.0 schema mismatch
If you're filing for the 2026 reporting year or later and your jurisdiction has moved to the CRS 3.0 schema, submitting against the older schema will fail. Confirm the schema version with your local authority — and validate against the correct XSD.
6. Numeric formatting errors
Account balances and payments must use a period as the decimal separator and no thousands separators. 1000.00 is valid; 1,000.00 and 1000,00 will fail.
7. DocRefID and CorrDocRefID issues on corrections
When correcting an earlier filing, the DocRefID must be unique and the CorrDocRefID must point to the exact original document being corrected. Mismatched references are a common cause of correction rejections.
How Novus Compliance helps
Novus takes your account data from Excel or CSV, validates it against the CRS v3.0 schema and business rules, and generates the XML for each jurisdiction you report to, ready for you to upload to its portal. See CRS Reporting Services.
Frequently asked questions
What is CRS reporting?
CRS (Common Reporting Standard) reporting is the annual process by which financial institutions identify accounts held by non-residents and report them to their local tax authority, which exchanges the data with the account holder's country of residence. Over 100 jurisdictions participate.
What's the difference between CRS and FATCA?
FATCA targets US persons and is a US law. CRS targets residents of every participating jurisdiction and is a global standard developed by the OECD. Most financial institutions file both — from the same source data but with different schemas and reporting rules.
Who needs to file a CRS report?
Reporting Financial Institutions — depository institutions, custodial institutions, investment entities, specified insurance companies, and certain trusts. The obligation applies if you hold reportable accounts for non-residents in participating jurisdictions.
When is the CRS filing deadline?
Deadlines vary by jurisdiction but typically fall between May and September. For example: UK 31 May, Ireland 30 June, India 30 June, Luxembourg 30 June, Cayman 31 July. Always confirm with your local authority.
What changes under CRS 2.0?
CRS 2.0 expands the scope of reportable accounts (including certain digital assets), strengthens self-certification requirements, clarifies zero/negative balance reporting, and introduces a new schema (CRS 3.0). Most jurisdictions adopt it from the 2026 reporting year, with schema v3.0 mandatory from 1 January 2027.
Does CRS use a GIIN like FATCA?
No. CRS does not use the GIIN. Reporting FIs are identified by local tax registration numbers or an equivalent identifier set by each jurisdiction. If you also file FATCA, you can validate your GIIN before submission.
What XML format does CRS reporting use?
CRS uses the OECD CRS XML Schema — currently version 3.0 for CRS 2.0 filings, with version 2.0 still accepted in some jurisdictions during the transition. Each jurisdiction may also apply local file naming conventions.
How do I validate CRS XML before submitting?
Use our free XML validation tool to check your file against the correct schema. The tool reports errors with line numbers so you can fix them before submission.
Can Novus generate CRS XML for me?
Yes. You provide your source data in Excel or CSV, and Novus generates and validates the XML for your jurisdiction. Book a demo to see it in action.
How does CRS relate to DAC8 and CARF?
DAC8 is the EU directive that incorporates CRS 2.0 and CARF into a single reporting obligation for EU member states. CARF is the OECD framework for reporting crypto-asset transactions. Novus supports CRS reporting today. If CARF or DAC8 reporting is on your roadmap, talk to us.