Preparing for compliance with CRS 2.0, the OECD's updated Common Reporting Standard
The Common Reporting Standard (CRS), the OECD's global standard for automatically exchanging financial account information, has applied in over 120 jurisdictions since 2014. It's set by the OECD and G20 countries, with implementation monitored through the Global Forum on Transparency and Exchange of Information for Tax Purposes. New digital products, e-money, CBDCs, and crypto-linked investments, along with practical feedback from
participating jurisdictions, prompted the OECD's first comprehensive review of CRS. The resulting amendments were adopted in August 2022 and finalized in June 2023. The industry calls this update "CRS 2.0," one of the most significant rewrites to automatic exchange obligations since CRS began.
CRS 2.0 is the updated version of the OECD's Common Reporting Standard (CRS), the global framework that enables the automatic exchange of financial account information between participating tax authorities. The amendments strengthen existing due diligence and reporting requirements while updating the framework to address developments in the digital economy, including certain electronic money products, central bank digital currencies (CBDCs), and crypto-related investments.
In practice, CRS 2.0 requires Financial Institutions to identify account holders who are tax resident outside the institution's home jurisdiction, as well as any Controlling Persons of entity account holders who are tax resident abroad. This determination is based on
self-certifications collected from customers and verified against other information and documentation already held by the institution.
Once an account is identified as reportable, the Financial Institution submits an annual report to its domestic tax authority. The domestic tax authority then automatically exchanges this information with the tax authority in the jurisdiction where the account holder or Controlling Person is tax resident. This enables tax authorities to verify information relating to cross-border financial accounts and related income, supporting greater tax transparency and compliance.
CRS 2.0 closes two gaps: the rise of digital financial products that function like traditional accounts, and shortcomings in due diligence and data quality identified since 2014. Its main changes include:
All financial institutions currently reporting under CRS are impacted, including banks, investment firms, insurance companies, and other financial institutions. They must comply with CRS reporting requirements, including identifying and reporting financial accounts held by foreign tax residents.
Automatic Exchange of Information (AEOI) is the delivery mechanism that allows tax authorities in different jurisdictions to share financial account data on a regular schedule, rather than case by case on request. That sharing is governed by agreements between jurisdictions, most commonly the Multilateral Competent Authority Agreement (MCAA), which sets out what's exchanged, how, and by which authorities.
CRS 2.0 is the substantive content flowing through that pipeline: it tells Financial Institutions what to collect and report, while AEOI is the legal and technical channel moving that data from a Financial Institution's home tax authority to the authority where the account holder is actually resident.
CRS 2.0 and Crypto-Asset Reporting Framework (CARF) were developed side by side but serve different purposes: CRS 2.0 tracks account holdings, while CARF tracks crypto-asset transactions themselves.
| CRS 2.0 | CARF | |
|---|---|---|
| Who reports | Reportable Financial Institutions (RFIs) | Reporting Crypto-Asset Service Providers (RCASPs), including individuals acting as a business |
| What's tracked | Account holdings, balances and income, now extended to e-money, CBDCs, and crypto-linked derivatives or funds | Individual crypto-asset transactions: fiat-to-crypto, crypto-to-crypto exchanges, and transfers, including reportable retail payments |
| What falls outside its scope | Direct crypto-asset holdings, which are CARF's domain instead, aside from certain tokenized securities | CBDCs and specified e-money, which are CRS 2.0's domain instead, along with crypto-assets that aren't used for investment or payment |
| How overlap is avoided | Explicit provisions in the standard that exclude holdings already captured under CARF, together with an updated CRS XML schema | A new CARF XML schema, harmonized with CRS, backed by OECD guidance that aligns CASP onboarding and classification with CRS |
The amendments adopted by the OECD, known as CRS 2.0, entered into force on 1 January 2026 in most participating jurisdictions, alongside the separate Crypto-Asset Reporting Framework (CARF) covering crypto-asset transactions. Together, the two regimes affect Financial Institutions already reporting under CRS and extend reporting requirements to additional entities, including certain investment funds, trusts, and e-money or digital wallet providers. As both frameworks were developed as part of the same OECD package, they are being rolled out on broadly aligned timelines across most major jurisdictions.
Most CRS 2.0 risk sits in operational readiness, not legal interpretation. The immediate priorities are clear: close the gap between existing CRS processes and the amended scope and data fields, refresh self-certifications and controlling-person records across the back book, and migrate reporting systems to the new XML schema before validation failures surface at the point of greatest scrutiny, the tax authority's own portal.
The harder challenge is consistency at scale. CRS 2.0, CARF, DAC8, and Form 1099-DA are four distinct regimes with different schemas, scopes. Firms that address each regime in isolation end up rebuilding the same due-diligence and reporting logic repeatedly, and re-testing it every time a jurisdiction updates its rules. The firms best positioned for digital asset tax compliance are treating this as one data and controls challenge rather than four separate projects, which is exactly the gap a unified compliance platform is built to close.
E-book
With major regulations now in force, legacy tax compliance approaches fall short.
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