Switzerland: Amendments to AEOI legislation to incorporate CARF and CRS 2.0

During its Autumn session, the Federal Council of Switzerland on November 26, 2025, approved amendments to the Ordinance on the International Automatic Exchange of Information in Tax Matters (AEOI Ordinance).

These amendments include provisions for revising the Federal Act on the International Automatic Exchange of Information in Tax Matters (AEOIA) to implement the OECD’s cryptoasset reporting framework (CARF) and the updates introduced by the OECD in the common reporting standard (CRS 2.0) within Switzerland’s domestic framework.

If no referendum is called during the review period, both the amended AEOIA and AEOI Ordinance will become effective on January 1, 2026.

The amended AEOI Ordinance introduces new obligations for cryptoasset service providers (CASPs) under CARF, including requirements for reporting information, conducting due diligence, and registration. It also clarifies the nexus of CASPs with Switzerland.

Additionally, CRS 2.0 will now apply to associations, foundations, and their accounts, unless they meet certain exemption conditions outlined in the amended ordinance. Transitional provisions have been included to assist affected parties in implementing CRS 2.0 and CARF.

However, considering the Swiss National Council’s Economic Affairs and Taxation Committee (EATC) decision on November 3, 2025, to postpone the review of the draft legislation for activating the list of partner jurisdictions for CARF until next year, CARF will only be incorporated into Swiss legislation from January 1, 2026. Its implementation, however, will not commence on that date and is now expected to be deferred until 2027 at the earliest. Consequently, the Federal Council has confirmed that the cryptoasset provisions introduced under the amended AEOIA and AEOI Ordinance will not become effective in 2026.

Read a December 2025 report prepared by the KPMG member firm in Switzerland