How to use the December 2025 FAQ
This OECD document clarifies consistent CRS implementation. Questions marked “amended CRS” concern the 2023 amendments; applicability still depends on the jurisdiction’s implementing law. An example using 1 January 2026 is not a statement of Singapore’s commencement date. Several entries marked with an asterisk show only their topic because their answers were incorporated into the amended Commentary. The PDF does not reproduce those answers, so consult that Commentary rather than inventing an answer from the heading.
Balances, account aggregation and single names
Equity-interest value is the value calculated for the purpose requiring the FI’s most frequent valuation; if never otherwise recalculated, acquisition value may be appropriate depending on facts. Excluded Accounts are not Financial Accounts and therefore are not included in Financial Account aggregation. For a person with a legal single name, report NFN in the first-name field and the actual mononym in the surname field.
TINs, entity settlors and closed trust accounts
A person who has not been issued a TIN and is not required to obtain one need not be asked to obtain one merely because eligible. A controlling person of a passive investment entity who is not a Reportable Jurisdiction Person need not provide a TIN under the standard, subject to domestic law and the wider approach. Where a trust settlor is an entity, its controlling persons are identified and reported in the settlement year and subsequent years. Closure of either an FI trust account or an FI-held account for a passive-NFE trust requires reporting both closure and gross payments during the period.
Liquidation and valid-self-certification reporting
An account remains reportable until it ceases to qualify, including actual closure during FI liquidation. The liquidating FI continues annual reporting until closure; domestic insolvency law may govern procedure and third-party support may be permitted. Under amended CRS, determine whether the year’s reported information rests on a valid self-certification obtained in time for reporting. Account-holder status is measured at period end, or closure if earlier, rather than simply whether a form existed on an arbitrary review date.
Evidence retention and residence-address review
No paper copy is mandatory. The FI may retain original, certified copy, photocopy, or a record of the document type, review date and identification number. Residence-address testing does not require a paper search if such records or controls ensure the current address matches documentary evidence. Two valid residence addresses may be identified, for example where a person works and lives half-time in two countries; obtain a self-certification or report to all reportable jurisdictions supported by those addresses. A declaration under penalty of perjury includes domestic criminal penalties for a false declaration.
Controlling persons and the US$1 million threshold
For pre-existing entity accounts not exceeding US$1 million after aggregation, permitted reliance on existing regulatory/customer AML information may mean a named controlling person is not reportable where no residence indication is held or required. Test the threshold at reporting-period end: an account reviewed at US$900,000 but ending at US$1.1 million has exceeded it for that year. An intermediate FI in a passive NFE’s ownership chain does not remove the obligation to identify ultimate controlling persons. A domestic AML ownership threshold below 25% cannot be replaced with 25% for CRS convenience.
Reliability of self-certifications
For new accounts, the FI need not give tax advice or conduct a legal tax-residence analysis; it may rely on the customer’s certification unless opening information, including AML/KYC, gives knowledge or reason to know that it is incorrect or unreliable. Tax administrations should help taxpayers identify residence, and the OECD’s residence information may assist. An update-on-change clause is not itself mandatory under the standard, though domestic law may require it and it may ease monitoring. Even without it, known unreliability prevents reliance.
Verbal, yes/no and authorised certifications
Information may be obtained verbally if the certification contains every required item, is signed or positively affirmed, follows a process consistent with account opening, and the process as well as the certification is recorded for audit. Yes/no residence questions are allowed, but tax-residence information cannot be prepopulated. A legally authorised representative, including under a power of attorney, may certify for the account holder. During curing of pre-existing-account indicia, request a TIN where applicable; a certification without it may still be relied on if reasonable collection efforts continue.
New accounts for existing customers
A jurisdiction may permit a new account of an existing customer to be treated as pre-existing only if the stated conditions are met. The condition that opening requires no new, additional or amended customer information, except CRS information, covers legal, regulatory, contractual and operational requirements alike. If such new information is required, opening provides an opportunity to obtain a fresh self-certification; being an established customer alone does not satisfy the exception.
Relationship managers and service providers
Regular training and instructions, such as annually, may operationalise relationship-manager duties, with acknowledged responsibilities and clear channels to centrally report relevant knowledge. When new-account procedures are applied to pre-existing accounts, the specific manager inquiry is not required, but relevant manager knowledge can still make a certification unreliable. A jurisdiction may allow external providers with no standard-level domestic-location or approval requirement. The FI remains responsible, must obey domestic law and must ensure authorities can access the supporting records.
Public entity information and newly expanded scope
New-entity-account checks may begin by determining reportable-person status. If reliable held/public information establishes that the entity is not reportable regardless of residence, such as an FI or listed corporation, a residence self-certification is not required under that step. Mere appearance on the FATCA FFI list is insufficient by itself to establish CRS FI status. For entities or accounts newly brought into CRS by legislation, the pre-existing/new cut-off is that legislation’s entry-into-force date; the FAQ’s 2026 illustration separates accounts opened by 31 December 2025 from those opened from 1 January 2026.
Non-participating-jurisdiction pooled trusts
For a widely held regulated trust-type collective investment vehicle or pension fund that is a managed investment entity in a non-participating jurisdiction, new-account look-through need not go beyond domestic AML/KYC information meeting at least FATF Recommendations 10 and 25 as adopted in February 2012. This is the narrow case addressed by the FAQ, not an exemption from identifying every trust’s controlling persons.
Cash pools, treasury centres and holding companies
An entity pooling cash exclusively for related non-financial entities is not a banking-like depository merely because of that activity. Where it finances only such related entities and their group is principally non-financial, cash pooling counts as financing and can make it an active NFE. A financial group’s treasury or holding company instead follows its actual FI activities and investment-entity conditions, even if it serves only affiliates or shareholders. FX hedging or functioning as an investment/private-equity/venture-capital fund can satisfy FI status when other tests are met.
Investment-entity tests
The less detailed Model 1 FATCA IGA investment definition cannot be used alone for CRS; the CRS gross-income and activity tests remain necessary. Direct real-property investment is not financial-asset investment, regardless of management, but an interest in a property-owning entity is a financial asset and its income counts. “Managed by” includes discretionary management of all or part of assets, even without managing the entity itself. The three-year 50% gross-income test may use the final day of a non-calendar accounting period in the preceding year. Relevant trustee or custody remuneration counts even when paid to the appointing law/accounting firm rather than the trustee or custodian.
Crypto interests and restricted tokenised assets
Under amended CRS, interests in Relevant Crypto-Assets include derivatives referencing them, such as futures, forwards and options, but not ordinary custody interests in the underlying crypto asset. A tokenised financial asset legally transferable only through traditional depository/custodial accounts, or regulated investment-entity interests transferable only through the entity’s controlled register/ledger, cannot be disintermediated and is not a CARF/amended-CRS crypto asset. The optional CRS section I(G) provision therefore does not apply. Without those restrictions, tokenisation can qualify as crypto and that option may apply.
Specified e-money redemption conditions
All units in a given issuance must be covered by a regulatory right to redeem at any time at par in the same fiat currency. Substantive restrictions undermining that right disqualify the product. Reasonable redemption fees, AML/illegal-activity checks, business-hour limits and designated channels may be compatible if par redemption is not undermined. A reporting crypto provider may rely on regulatory product approvals or authorisations for this condition. It is not enough that only selected holders or units can redeem at par.
E-money changing status or holding several currencies
A crypto asset becoming specified e-money remains under CARF until, but excluding, the date all e-money requirements are met; earlier transactions are not retroactively reclassified. From that date it is outside CARF, exchanges are treated as fiat exchanges for CARF, and an entity holding it for customers is a CRS depository institution with year-end balance and any gross-interest reporting. A jurisdiction may permit a simplified whole/part-year status treatment. A multi-currency wallet can contain separate single-fiat e-money products; for one holder, report them as one notional depository account, applying normal aggregation/FX rules, including exclusion testing.
Government bodies and non-reporting institutions
First apply the functional FI test to a central bank, international organisation or governmental entity. A qualifying FI may be non-reporting if the detailed conditions are met; a body that is not an FI may instead be an active NFE. FATCA Annex 2 categories are not automatically CRS exemptions: treaty-qualified funds, local-client FIs/banks, low-value-only FIs and various sponsored vehicles were not all included. Domestic low-risk residual categories must independently meet CRS requirements. Central-bank accounts for current/former employees and their spouses/children are not commercial financial activity for this exception.
Qualified credit-card issuers and financial-asset accounts
A credit-card issuer meeting the detailed overpayment and policy conditions may qualify in a later reporting period if the required controls are in place from its start and throughout it. Debt interest is undefined in CRS and follows implementing local law. Qualifying term-life insurance ending before age 90 can be an excluded account when all additional conditions hold. OTC derivatives are financial assets just as exchange-traded ones are. Money alone is not a financial asset for a custody account: CFD client-money accounts are not custodial accounts on that basis, though may be depository accounts if maintained in a banking-like business.
Low-risk exclusions must be effective
The US$1,000 dormant-account example is indicative, but jurisdictions should not set a substantially higher low-risk limit. A domestic exclusion must present low tax-evasion risk, resemble a standard exclusion, be established by law and not frustrate CRS. If an early-withdrawal penalty replaces a contribution limit for an annuity, it must actually be enforceable against non-residents despite treaties. Reporting to regulatory/social-security bodies resembles tax-authority reporting only where domestic law ensures the tax authority can readily access that information.
CIV unit holders and investment advisers
A widely held public trust-type CIV may treat registered unit holders as equity-account holders where trustee/beneficiaries are unrelated, interests unitised, the register current and units freely transferable. A non-FI nominee holding for another is subject to the normal account-holder exception. Registered custodial institutions report units held for their own reportable customers. Debt/equity in an entity that is an FI solely as adviser or manager of client assets held in another FI is a financial account under the avoidance rule only where that interest class was established to avoid CRS reporting.
Reportable persons, listed stock and trust protectors
The minimum standard reports persons resident in designated reportable jurisdictions, not persons solely resident in the FI’s own jurisdiction, although domestic wider reporting may extend to them. “Stock regularly traded” refers to corporate shares: a non-corporate entity cannot itself qualify through this listed-stock active-NFE limb. A protector of an FI trust is an account holder regardless of effective control. Insurer income on business or regulatory reserve assets may be active because of its operating nature, but the miscellaneous answer excludes reserves abusively inflated for that result.
Payment codes and multiple residence indications
CRS504 may identify every payment type on cash-value insurance, annuity, equity or debt interests, including dividends, interest, gross proceeds and redemptions; separate CRS501–503 coding is not required for each type in those cases. For a pre-existing entity, review all residence indications: incorporation/organisation, registered/principal/effective-management address and trustee addresses. Do not stop at the first jurisdiction found. Treat the entity as resident in every jurisdiction indicated unless the specified curing procedure applies.
Topics incorporated into the amended Commentary
The PDF lists, without substantive answers, custodial sale proceeds, intermittent discretionary-beneficiary distributions, usufruct, AML/KYC due diligence, TIN validation, positive affirmation, entity CRS status, timing and validity of certifications, the general investment-entity definition, e-money providers, compartmentalised broad-participation retirement funds, low-value e-money exclusions, condominium/cooperative accounts, indirect trust distributions, cash-value-insurance holders, passive NFEs/income, regularly traded reportable-person definitions and indirect related ownership. These are pointers to the amended Commentary, not gaps to fill with conjecture.
Data safeguards and ISO standards
The ISO 27000 family is an information-security risk-management approach rather than a prescriptive requirement for certification. Jurisdictions are expected to use it, an equivalent protection standard, or a reasonable contextual justification for departure. The FAQ does not mandate a particular certificate for every FI. Protection is assessed in the tax administration’s overall information-security system.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
Read the official PDF ↗