Financial institutions (FIs) should review updated CRA guidance for due diligence and information reporting obligations under the Common Reporting Standard (CRS). In this update, which was released on December 19, 2025, the CRA clarifies the obligations of fund managers and dealers, expands its guidance on the due diligence and reporting obligations of fund structures, clarifies the guidance for undocumented accounts, and expands the circumstances under which a partnership may be considered a Canadian resident for CRS purposes, among other changes. Note that, despite this new update, the CRA has not currently updated its Foreign Account Tax Compliance Act (FATCA) guidance. As a result, new CRS guidance may differ from existing FATCA requirements.
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