Bermuda: CRS reporting deadline is May 31, 2024
Reminder to all Bermuda reporting financial institutions to submit CRS reports by May 31, 2024
CRS reporting deadline is May 31, 2024
The Bermuda Ministry of Finance in May 2024 issued an announcement reminding all Bermuda reporting financial institutions to submit the common reporting standard (CRS) reports by May 31, 2024, and the Annual CRS Compliance Certification Form by September 30, 2024, for the 2023 reporting period.
Any reporting financial institutions failing to comply with the statutory deadlines may incur penalties.
In addition, the Ministry issued the following reminders:
- Primary users: An active and contactable primary user must always be appointed for each reporting financial institution. If the current primary user is not active, reporting entities must promptly submit a primary user change notice following the instructions provided in the portal user guide.
- Deactivation requests: Reporting financial institutions that no longer have reporting obligations must promptly request to be deactivated from the portal.
- Undocumented accounts: Reporting financial institutions must classify accounts as undocumented only if they meet the criteria provided in subparagraphs B(5) and C(5) of Section III of the CRS. For all other cases, the CRS due diligence rules must be followed.
- Taxpayer identification numbers (TINs): Although TIN is an optional field, reporting financial institutions must provide that TINs are included in line with the CRS due diligence requirements, providing reasonable efforts are taken to obtain TINs of preexisting accounts.
- Date of birth: The date of birth field for individual account holders and controlling persons is shown as optional on the form; however, reporting financial institutions must provide that dates of birth are included in the report in line with the due diligence requirements outlined in the CRS. If the date of birth is not included, the Ministry will follow up to require a correction.
- Addresses: Even though only the city and country fields are marked mandatory in the OECD’s CRS XML schema, reporting financial institutions must provide that full addresses are included for all account holders when available.
- Residence / citizenship by investment (CBI/RBI) schemes: The Ministry notes that all Bermuda reporting financial institutions need to take the outcome of the OECD's analysis of 25 potential high-risk CBI/RBI schemes into account when performing their CRS due diligence obligations, such as opening a financial account for a new account holder.
Read a May 2024 report prepared by the KPMG member firm in Bermuda
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