UAE: Additional CRS guidance on “Undocumented Accounts”

The UAE Ministry of Finance (MOF) in April 2025, updated the circular on the reporting of “Undocumented Accounts,” providing clarifications and additional guidance for reporting financial institutions.

The key updates to the circular are as follows:

Impact of the common reporting standard (CRS)

• Updated to clarify that, in addition to high-value pre-existing individual accounts, low-value pre-existing individual accounts must also be reported as undocumented if self-certification forms or other relevant documentary evidence cannot be obtained, until they cease to fall into this category.
• Updated to note that, along with electronic and/or paper record searches, reporting financial institutions must conduct annual inquiries with the relevant relationship manager (as applicable) to determine whether the account holder is a tax resident of a reportable jurisdiction.

In addition, the following new sections were added:

Data review

• Reporting financial institutions are reminded that any Undocumented Accounts they submit will undergo a data review to identify accounts lacking sufficient documentation.

Remediation plan

• Reporting financial institutions are required to have a remediation plan in place for Undocumented Accounts to provide compliance with CRS regulations.
• Reporting financial institutions submitting Undocumented Accounts are subject to audit(s) as part of the compliance program.

Furthermore, reporting financial institutions must document all actions, such as communication attempts, follow-ups, and due diligence measures, to maintain an audit trail. This structured approach helps reporting financial institutions mitigate non-compliance risks and avoid regulatory penalties.

Read an April 2025 report prepared by the KPMG member firm in the UAE