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Germany: Updated FATCA and CRS guidance

Guidance including the final exchange list for 2025, CRS system maintenance, and limitations of GIIN

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June 25, 2025

The German federal central tax office (BZSt) on June 17, 2025, issued common reporting standard (CRS) Newsletter 03/2025 that contains the following updates:

  • Final exchange list for 2025: Starting in 2025, Belize’s exchange status with Germany has changed to reciprocity—requiring reporting financial institutions in Germany to submit data for Belize to the BZSt—beginning with the 2024 reportable period. Additionally, Germany has newly established mutual exchange relationships for financial account information with Armenia, Moldova, Uganda, and Ukraine, effective from the 2024 reportable period. The BZSt also notes that changes have been made compared to the 2025 provisional exchange list. The CRS system is now configured to allow reports for all countries on the final exchange list. The final list of participating and reportable jurisdictions for the 2025 reporting can be found on the BZSt website.
  • CRS system maintenance: Planned system maintenance is scheduled from June 27, 2025, to no later than July 2, 2025. CRS report submissions will remain operational during this period; however, users may experience delays in processing of log transmissions.
  • Limitations of Global Intermediary Identification Number (GIIN) for classifying entities as financial institutions: In reminding German reporting financial institutions of their obligation to accurately identify reportable accounts, the BZSt specifies that accounts held by financial institutions are not subject to reporting requirements. Consequently, correctly classifying account-holding entities as financial institutions is crucial. It is important to note that a GIIN alone is not sufficient to classify an entity as a financial institution. The U.S. tax authority (IRS) issues a GIIN to any legal entity that requests it without validating their status as financial institutions under the FKAustG or FATCA-USA-UmsV, meaning a non-financial institution (NFI) can also possess a GIIN. Therefore, having a GIIN in place does not replace the need for proper due diligence procedures, as avoiding them may lead to failing to report accounts with a reportable status.

Read a June 2025 report prepared by the KPMG member firm in Germany

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