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      The OECD’s 2023 update to the CRS (“CRS 2.0”) is expected to become effective in Ireland from 1 January 2026, with the first CRS 2.0 Returns due to be filed with Revenue ahead of the 30 June 2027 deadline, with respect to the 2026 reporting year.

      CRS 2.0 will bring E-Money and certain Crypto Assets within the scope of CRS. However, the OECD will also be making updates to due-diligence and expanding reporting requirements under CRS. The changes regarding certain Crypto Assets are in addition to the Crypto-Asset Reporting Framework (“CARF”) regime, coming into effect in Ireland from 1 January 2026.

      Therefore, from 1 January 2026, many Irish tax resident entities that are not currently in-scope of CRS, may be brought in-scope as Reporting Financial Institutions (“FIs”) with registration and reporting obligations. For example:

      • E-Money providers and entities that hold Central Bank Digital Currencies (“CBDCs”) on behalf of customers will be classified as Depository Institution FIs;
      • Entities that are merely licenced to engage in certain banking activities but are not yet engaged in such activities will be classified as Depository Institution FIs;
      • Funds that invest in CBDCs or Relevant Crypto Assets on behalf of their investors will be classified as Investment Entity FIs; and
      • Wealth managers that hold Relevant Crypto Assets on behalf of investors in a custodial or nominee capacity will be classified as Custodial Institution FIs.

      All Irish FIs that are already within scope of CRS will also be impacted by CRS 2.0 as they will need to ensure that (i) they are compliant with the updated due-diligence requirements under CRS 2.0 from 1 January 2026 and (ii) required updates are made to their internal systems in order to pull the additional reportable data fields into their CRS Returns for the 2026 reporting period onwards. We have outlined further commentary below in this respect.

      Kevin Cohen
      Kevin Cohen

      Partner

      KPMG in Ireland

      Updated due-diligence requirements

      At a high level, the key updates to due-diligence requirements under CRS 2.0 will include:

      • Dual tax resident Individual and Entity Account Holders can continue to rely on the tiebreaker rules to determine their jurisdiction of tax residence for CRS Self-Certification Form purposes up to 31 December 2025. However, from 1 January 2026 onwards, dual tax resident Individual and Entity Account Holders will no longer be able to rely on the tiebreaker rules to determine jurisdiction of tax residence and must disclose all of their jurisdictions of tax residence on CRS Self-Certification Forms. FIs must then report such Account Holders in respect of each jurisdiction of tax residence on their CRS Return.
      • There will be new special due-diligence procedures available in exceptional circumstances where an FI has not obtained a valid CRS Self-Certification Form for a New Account in time for the FI to meet its reporting obligations. This will allow FIs to temporarily apply due-diligence procedures for Pre-Existing Accounts to such New Accounts (i.e. determine the tax residence of such Individual and Entity Account Holders and their Controlling Persons (as relevant) based on information collected via AML/KYC procedures) to ensure that such accounts are appropriately reported on the FI’s CRS Return. However, this is not a standard procedure and is not an alternative to the requirement to obtain a valid CRS Self-Cert from New Accounts at account opening. FIs must report such impacted accounts as “New Accounts” on their CRS Return under the new CRS 2.0 XML schema discuss further below.
      • If an Account Holder does not provide a Tax Identification Number (“TIN”) on their CRS Self-Certification Form but the Account Holder is tax resident in a jurisdiction that issues TINs to its tax residents, the self-cert will be deemed unreliable or incorrect and the FI should request a TIN from such Account Holder for inclusion on its CRS Return.
      • FIs are not required to confirm the format or other specifications of a TIN provided by an Account Holder on a CRS Self-Certification Form. However, they may wish to do so to enhance the quality of information collected and reported and in order to minimise potential future queries being received from foreign Tax Authorities when such data is ultimately exchanged under CRS.
      • There is a new optional “Non-Reporting FI” classification available for “Qualified Non-Profit Entities” provided the prescribed conditions are met. Revenue have not yet confirmed whether Ireland will be adopting this optional provision under CRS 2.0.
      • Central Banks that hold CBDCs on behalf of Non-Financial Entities (“NFEs”) or Individuals will not qualify as Non-Reporting FIs.
      • Certain Foundations or Capital Contribution Accounts and Low-value Specified Electronic Money Products (“SEMPs”) will qualify as “Excluded Accounts” (i.e. accounts that are not required to be reviewed or reported) for CRS purposes, provided the prescribed conditions are met.
      • Some jurisdictions may offer Government Verification Services (“GVS”) to their FIs for the purpose of ascertaining the identity and tax residence of an Account Holder or Controlling Person. In this respect, a unique reference number, code or other confirmation received by an FI in respect of an Account Holder or Controlling Person via a GVS will be considered a functional equivalent to a TIN. 

      It is important that FIs make the required updates to their CRS Self-Certification Forms this year ahead of CRS 2.0 becoming effective in Ireland from 1 January 2026, including the following:

      • Ensuring that the “Controlling Person Type” field is mandatory to complete for Controlling Person(s) of Entity and Trust Account Holders (e.g. that are classified as Passive NFEs);
      • Ensuring that dual tax resident Individual and Entity Account Holders disclose all of their jurisdictions of tax residence (and TINs) on CRS Self-Certification Forms; and
      • Ensuring that the OECD’s four additional questions are asked of Individual Account Holders that are claiming to be tax resident in high-risk Citizenship by Investment/Residence by Investment (“CBI/RBI”) scheme jurisdictions.

      Additional reportable data fields

      On 2 October 2024, the OECD published the Amended CRS XML Schema User Guide Version 4.0 which outlines the new reporting requirements for FIs under the new CRS 2.0 XML schema. Accordingly, FIs will be required to report the following additional data fields on their CRS Returns for reporting periods 2026 onwards:

      • FIs will be required to report the "Joint Account" field on their CRS Return if such data is held in their electronically searchable records.
      • The following fields will be mandatory to report on CRS Returns for validation purposes: 
        • “Type of Financial Account” (e.g. Depository Account, Custodial Account, etc.);
        • “Controlling Person Type” field for reportable Controlling Person(s) of Entity and Trust Account Holders (e.g. that are classified as Passive NFEs). Additionally, in the case of trusts that are classified as Investment Entity FIs (e.g. certain discretionary trusts), the “Equity Interest Type” field for each reportable Equity Interest Holder*;
        • "Self-Cert received" field;
        • "Due-Diligence Procedure" field to state if the account is either New or Pre-Existing; and
        • "No. of Joint Account Holders" field.

      *Helpfully, there will be transitional measures available under CRS 2.0 for each Reportable Account maintained by an FI as of 31 December 2025 and for reporting periods ending by the second calendar year following such date (i.e. reporting years 2026 and 2027), the

      • “Controlling Person Type” for reportable Controlling Person(s) of Entity and Trust Account Holders (e.g. that are classified as Passive NFEs); and
      • “Equity Interest Type” for each reportable Equity Interest Holder of a Trust FI is only required to be reported if such information is available in the electronically searchable data maintained by the FI. However, this will mean that the FI will be required to complete a retrospective exercise and check if it has such information on file for its existing reportable (i) Controlling Persons and (ii) Equity Interest Holders and if so, such information should be reported on the FI’s 2026 and 2027 CRS Returns.

      Additionally, the OECD have clarified that for Controlling Persons of Entity Account Holders (Passive NFEs), the FI must report according to the hierarchy of roles (i.e. ownership interests, control through other means, senior managing official), provided the identification of the role is required by AML/KYC Procedures. Accordingly, where a Reportable Controlling Person is both a Controlling Person for the entity by virtue of its “ownership interest” and a “Senior Managing Official”, the FI is only required to report such individual as a Controlling Person by virtue of its “ownership interest” given this comes first in the hierarchy.

      In contrast, if a Controlling Person of a Trust Account Holder (Passive NFE) acts as multiple types of Controlling Person for the Trust, the FI must report all types of Controlling Person for such Reportable Controlling Person on its CRS Return (e.g. where the individual acts as both the settlor and beneficiary of the Trust).

      Updated Irish list of participating jurisdictions for CRS and DAC2 purposes

      On 21 May 2025, Revenue published the latest List of Participating Jurisdictions for CRS and DAC2 purposes, which now includes 117 jurisdictions as of 19 May 2025. For the avoidance of doubt, Irish Reporting FIs are required to report all non-Irish and non-US tax resident Account Holders (other than certain exceptions) on their annual CRS Return.

      Multilateral Competent Authority Agreement (“MCAA”) signatories

      On 13 March 2025, the OECD published a revised list of MCAA Signatories, bringing the total number of signatories to 126.

      Consolidated text of the CRS (2025)

      On 2 June 2025, the OECD published an unofficial Consolidated text of the CRS (2025) which incorporates the OECD’s 2023 update to the CRS, as discussed at section 1 above.

      Get in touch

      If you would like to discuss the impact of CRS 2.0 on your business, please contact Kevin Cohen of our FATCA team.

      We'd be delighted to hear from you.

      Kevin Cohen
      Kevin Cohen

      Partner

      KPMG in Ireland

      Transferring information between international tax authorities
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