What is FATCA reporting?
FATCA (Foreign Account Tax Compliance Act) requires financial institutions outside the United States to identify accounts held by US persons — or by entities controlled by US persons — and report those accounts to the IRS or to their local tax authority.
FATCA was enacted in 2010 as part of the US Hiring Incentives to Restore Employment (HIRE) Act. Its purpose is to prevent US taxpayers from using offshore accounts to evade US tax. Since 2014, more than 100 jurisdictions have signed intergovernmental agreements (IGAs) to implement FATCA reporting locally.
Under FATCA, financial institutions must:
- Register with the IRS and obtain a GIIN (Global Intermediary Identification Number) — verify it with our GIIN validation tool
- Apply due diligence procedures to identify US reportable accounts
- Report account holder and account data annually using a defined XML schema
- Report to their local tax authority (Model 1) or directly to the IRS via the IDES Gateway (Model 2)
Why FATCA reporting matters
Non-compliance carries real consequences. Financial institutions that fail to report — or that report incomplete or inaccurate data — risk:
- 30% withholding on US-source payments (dividends, interest, gross proceeds)
- Penalties under local implementing legislation, which vary by jurisdiction
- Reputational damage — especially for institutions with US correspondent relationships
- 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.
Who must file FATCA reports?
Reporting obligations fall on Foreign Financial Institutions (FFIs) and, in specific cases, on Non-Financial Foreign Entities (NFFEs). The table below summarises the entities that typically need to file.
| Entity Type | Reporting Obligation |
|---|---|
| Banks and depository institutions | Report US reportable accounts (individuals and entities) |
| Custodial institutions | Report accounts holding financial assets for US persons |
| Investment entities | Report US reportable accounts including fund investors, hedge fund interests, private equity interests |
| Specified insurance companies | Report cash value insurance contracts and annuity contracts held by US persons |
| Trusts | Depending on classification — trustee-documented trusts file on behalf of the trust |
| Direct Reporting NFFEs | Report directly to the IRS if they have US substantial owners |
| Sponsoring Entities | Report on behalf of sponsored FFIs and sponsored entities |
FATCA Model 1 vs Model 2 — which applies to you?
Not all Financial Institutions report directly to the IRS. Your reporting workflow depends on whether your jurisdiction signed a Model 1 or Model 2 IGA. For a deeper comparison, see our FATCA Model 1 vs Model 2 guide.
| Feature | FATCA Model 1 (IGA) | FATCA Model 2 |
|---|---|---|
| Reporting Destination | Local Tax Authority (e.g., CBDT in India, HMRC in UK) |
Directly to US IRS (via IDES Gateway) |
| Data Transmission | The Local Authority exchanges data with the IRS on your behalf. | The Financial Institution (FI) sends data directly to the IRS. |
| Typical Deadline | May – September (Varies by local country rules) |
March 31 (Fixed IRS deadline) |
| File Format & Security | Local XML Schema (May require local digital signature/encryption) |
IRS FATCA XML v2.0.1 (Requires IDES AES-256 Encryption) |
| Key Examples | India UK Luxembourg Canada Ireland | Switzerland Japan Hong Kong |
FATCA Model 1 (IGA)
Under a Model 1 Intergovernmental Agreement (IGA), Foreign Financial Institutions (FFIs) do not file directly with the IRS. Instead, they report to their own local tax authority.
- Who uses it? Most jurisdictions, including India, UK, Canada, Luxembourg, and the Cayman Islands.
- Process: You upload your XML report to your local government portal (e.g., Insight Portal in India, HMRC AEOI in the UK, ACD in Luxembourg).
- Novus support: We generate the specific XML format required by your local authority. Learn more →
FATCA Model 2
Under a Model 2 IGA, the local government directs FIs to register with the IRS and report directly to them. This is common in countries with strict banking privacy laws.
- Who uses it? Switzerland, Japan, and Hong Kong.
- Process: You must digitally sign, encrypt (AES-256), and upload the package to the IRS IDES Gateway.
- Novus support: We automate the complex IDES encryption and packaging process. Learn more →
FATCA reporting deadlines by jurisdiction
Deadlines vary significantly by jurisdiction. Model 2 filings to the IRS are due 31 March. Model 1 deadlines are set locally and range from May to September. The table below summarises the current deadlines for major jurisdictions — click any jurisdiction name to see jurisdiction-specific filing details.
| Jurisdiction | Model | Filing Deadline | Filing Authority |
|---|---|---|---|
| India | Model 1 | 30 June | Income Tax Department (Form 61B) |
| United Kingdom | Model 1 | 31 May | HMRC AEOI |
| Luxembourg | Model 1 | 30 June | ACD (SOFIE / FUNDSQUARE) |
| Ireland | Model 1 | 30 June | Revenue Commissioners (ROS) |
| Canada | Model 1 | End of June | CRA (Part XVIII) |
| Cayman Islands | Model 1 | 31 July | DITC Portal |
| Switzerland | Model 2 | 31 March | ESTV/AFC + IRS (via IDES) |
| Japan | Model 2 | 31 March | IRS (via IDES) |
| Hong Kong | Model 2 | 31 March | IRS (via IDES) |
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.
FATCA XML field reference
The tables below describe every field required in a FATCA XML report. Each section maps to a specific part of the schema — the Submitting Entity, Sponsor, Reporting Financial Institution, Account Holder, Financial Account, and Substantial Owners.
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. Usually this will be the Sponsoring Entity. | - |
| SE ID | Mandatory | GIIN of entity filing the XML report. | Verify GIIN |
2. Sponsor (SP)
| Field Name | Status | Description | Resources |
|---|---|---|---|
| SP Entity Name | Optional | Name of entity sponsoring the financial institution. | - |
| SP Entity Sponsor GIIN | Optional | Sponsor GIIN of the sponsoring entity. | Verify GIIN |
| SP Entity Address | Optional | Street address of the sponsoring entity. | - |
| SP Address City | Optional | City of the sponsoring entity. | - |
| SP Address County | Optional | County/state/province of the sponsoring entity. | - |
| SP Address Post Code | Optional | Post code of the sponsoring entity. | - |
| SP Address Country | Optional | Two-letter country code of the sponsoring entity. | ISO 3166-1 Alpha-2 |
| SP Filer Category | Optional | Dropdown value — select applicable (e.g., FATCA607). See Reference Data below. | See Ref Data |
3. "Reporting" Financial Institution (RFI)
| Field Name | Status | Description | Resources |
|---|---|---|---|
| RFI Name | Mandatory | Name of the Reporting Financial Institution (e.g., The ABC Trust, XYZ Limited). | - |
| RFI GIIN | Optional | GIIN of financial institution. | 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 financial institution is filing the XML report (where resident). | ISO 3166-1 Alpha-2 |
4. 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 — FATCA classification (e.g., FATCA102, FATCA104). | See Ref Data |
| AH TIN | Mandatory | Tax identification number of account holder. Use IRS Relief Codes (e.g., 222222222) if missing. | - |
| AH TIN Country | Mandatory | Two-letter country code that issued the TIN. | ISO 3166-1 Alpha-2 |
| AH Foreign TIN | Conditional | Foreign Tax Identification Number. Mandatory under IRS Notice 2024-78 if the US TIN is missing and an IRS relief code is used. |
- |
| 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 of the account holder. | - |
| AH Address City | Mandatory | City of the account holder. | - |
| AH Address County | Optional | County/state/province of the account holder. | - |
| AH Address Post Code | Optional | Post code of the account holder. | - |
| AH Address Country | Mandatory | Two-letter country code of the account holder. | ISO 3166-1 Alpha-2 |
| AH Account Type | Mandatory | Type of account holder (select from Ref Data list). | See Ref Data |
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). Must be base currency. | ISO 4217 Currency |
| FA Balance | Mandatory | Account balance as at 31 Dec. Format: 1000.00 (no commas). | - |
| FA Payments (Dividend) | Optional | Dividend payments made. No commas. | - |
| FA Payments (Interest) | Optional | Interest payments made. No commas. | - |
| FA Payments (Proceeds/Redemption) | Optional | Repayments/Proceeds made. No commas. | - |
| FA Payments (Other Income) | Optional | Other payments made. No commas. | - |
6. Substantial Owners (SO)
Note: These fields are only mandatory if the account holder is an Entity (Passive NFFE) with substantial US owner(s).| Field Name | Status | Description | Resources |
|---|---|---|---|
| SO ID Number | Optional | Unique ID for the Substantial Owner. | - |
| SO Given Name(s) | Optional | Given name of the Substantial Owner. | - |
| SO Family Name(s) | Optional | Family name of the Substantial Owner. | - |
| SO TIN | Optional | US Tax Identification Number. Use IRS Relief Codes (e.g., 222222222) if missing. | - |
| SO TIN Country | Optional | Country code of the TIN (usually US). | ISO 3166-1 Alpha-2 |
| SO Foreign TIN | Conditional | Foreign Tax Identification Number. Mandatory under IRS Notice 2024-78 if the US TIN is missing and an IRS relief code is used. |
- |
| SO Date of Birth | Optional | Format: YYYY-MM-DD. | - |
| SO Country of Birth | Optional | Two-letter country code. | ISO 3166-1 Alpha-2 |
| SO Address | Optional | Street address. | - |
| SO Address City | Optional | City. | - |
| SO Address Country | Optional | Two-letter country code. | ISO 3166-1 Alpha-2 |
7. Reference Data
SP Filer Category
- FATCA607: Sponsoring Entity of a Sponsored FFI
- FATCA609: Trustees of a Trustee Documented Trust (Model 1 IGA only)
AH Type
- FATCA102: Passive NFFE with substantial US owners (or Controlling Persons under IGA)
- FATCA104: Specified US Person
AH Account Type
Select one of the following roles:
Beneficiary Creditor Protector Settlor Shareholder Trustee Limited Partner General Partner Other*Or any other natural person exercising ultimate effective control over a trust.
Common FATCA reporting errors (and how to avoid them)
Most rejected FATCA 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 or malformed GIIN
A GIIN must be 19 characters in the format XXXXXX.XXXXX.XX.XXX. Common mistakes: lowercase letters, using the letter "O" (which is never valid), or truncating the country code. Verify your GIIN against the IRS FFI List before filing — and check the structure against our GIIN format guide. Use the GIIN validation tool for instant checks.
2. Missing TIN for US-resident account holders
Every US-resident account holder requires a TIN in the report. If the account holder doesn't have a US TIN, use the IRS relief codes (e.g., 222222222) — and, under IRS Notice 2024-78, you must also report the Foreign TIN in that case.
3. Wrong ConstitutionType or AH Type code
Entity classifications must match the enumeration values in the schema. Using I (Individual) for a legal entity, or omitting AH Type for an entity account holder, will fail validation.
4. Element ordering violations
The FATCA 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. Namespace mismatch
The root element must use the correct namespace for the target schema. FATCA XML v2.0.1 uses its own namespace — but jurisdiction-specific schemas (e.g., India's Form 61B, Germany's DIP) use their own. Using the wrong namespace is a common cause of rejection.
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.
How Novus Compliance helps
Novus takes your account data from Excel or CSV, validates it, and generates the XML for your local authority or the sealed IDES package for the IRS, ready for you to upload. See FATCA Reporting Services.
Frequently asked questions
What is FATCA reporting?
FATCA reporting is the annual process by which financial institutions outside the US report accounts held by US persons — or by entities controlled by US persons — to their local tax authority (Model 1) or directly to the IRS (Model 2). Reports cover the previous calendar year and are filed between March and September.
Who needs to file a FATCA report?
Financial institutions that fall under the FATCA definition — banks, custodial institutions, investment entities, specified insurance companies, and certain trusts. Some NFFEs also have reporting obligations if they have US substantial owners. Sponsoring entities file on behalf of their sponsored FFIs.
What's the difference between Model 1 and Model 2 IGA?
Under Model 1, financial institutions report to their local tax authority, which exchanges the data with the IRS. Under Model 2, financial institutions register with the IRS and file directly through the IDES Gateway. Most jurisdictions use Model 1. Japan and Hong Kong use Model 2, as does Switzerland until its Model 1 agreement takes effect in 2027. See our Model 1 vs Model 2 guide for a deeper comparison.
When is the FATCA filing deadline?
Model 2 filings to the IRS are due 31 March each year. Model 1 deadlines are set locally and range from May to September. For example: UK 31 May, India 30 June, Canada end of June, Cayman 31 July. Always confirm with your local authority.
What XML format does FATCA reporting require?
Model 2 filings use the IRS FATCA XML Schema v2.0.1. Model 1 filings use jurisdiction-specific schemas — for example, India uses Form61B.xsd, Germany uses dip.xsd, and the UK uses uk_aeoi_submission_v2.0.xsd. Each jurisdiction's schema has its own namespace and field variations. Start from our free Excel templates to structure your data correctly.
Is a GIIN required in every FATCA report?
In most jurisdictions, yes. The reporting FI's GIIN must appear in the report and be valid on the current IRS FFI List. For India's Form 61B, GIIN is mandatory for Report Type 01 (FATCA) and optional for Report Type 02 (CRS). Use our GIIN validation tool to verify before filing.
What happens if I file an invalid FATCA XML?
The submission is rejected by the tax authority's portal — either immediately (schema failure) or after processing (business rule failure). You'll receive error codes that must be resolved and refiled. Repeated rejections can delay your compliance timeline and, in some jurisdictions, trigger penalties.
How do I validate my FATCA 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 FATCA XML for me?
Yes. Novus automates the full workflow — you provide source data in Excel or CSV, and Novus generates the schema-valid XML for your jurisdiction. Book a demo to see it in action.
Do I need separate reports for FATCA and CRS?
Yes. FATCA and CRS are separate frameworks with different schemas and reporting rules. However, Novus generates both from the same source data — validating reportable accounts once and producing the correct XML for each framework. See CRS Reporting Services for details.