UAE: Updated FATCA and CRS system FAQs

The UAE Ministry of Finance issued an updated version of the FATCA and common reporting standard (CRS) system “frequently asked questions” (FAQs) (v2.1).

The changes to the system FAQs are as follows:

Updated question:

• Can reporting financial institutions amend registration details submitted in the previous year?
• Reporting financial institutions can amend registration details submitted in CY 2022. Editing registration involves a maker, checker, and regulatory authority approval workflow. To edit their registration, reporting financial institutions need to select the CY 2022 registration row and use the “Edit Registration Details” feature. However, registrations made prior to CY 2021 cannot be amended. If a reporting financial institution was not registered for CY 2022 or was established in CY 2023, it must provide registration and reporting for its CY 2023 FATCA and CRS obligations.

New questions:

• Does a reporting financial institution need to do a fresh registration on the FATCA CRS system if they have previously registered on FATCA/CRS System for CY2022?
• Fresh registration is not required. However, reporting financial institutions must provide their existing registration details are up to date. If not, they need to promptly update using the “Edit Registration Details” feature.
• Registration requirement for financial institutions that dissolved in CY 2023?
• Financial institutions must register and report for CY 2023 until the date of dissolution.
• Registration requirement for financial institutions that dissolved in CY 2022?
• Financial institutions that dissolved in CY 2022 or earlier are not required to take any action, as registration in CY 2023 or later is not required or applicable. However, financial institutions must provide that no new reporting period is added to their existing registration, if any.
• Registration requirement for financial institutions that registered in CY 2022 and dissolved in CY 2023?
• Financial institutions are not required to register again. However, financial institutions are required to report till the date of dissolution.

Updated question:

• What actions are required by reporting financial institutions after submitting FATCA and CRS reports?
• The current system does not require the UAE regulatory authority approval for data and risk assessment submissions. After both the maker and checker users approve the submission, no additional action is needed from the reporting financial institutions.

Read a June 2024 report prepared by the KPMG member firm in the UAE