- in North America
- in North America
The Cayman Islands has now implemented the OECD's "CRS 2.0" updates through the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025, which will apply from 1 January 2026, with key reporting changes taking effect from 2027.
The amendments materially tighten data quality expectations, accelerate notification and reporting timelines and modernise the regime to address electronic money products, central bank digital currencies and crypto-assets. Cayman Financial Institutions should begin implementation planning in order to be compliant for the 2026 reporting year.
Key points for Cayman Financial Institutions
- Governance and due diligence: Cayman Financial Institutions must maintain written policies and procedures that fully implement Sections II–VII of the Common Reporting Standard, including collecting a valid self-certification for new accounts on or before opening, subject only to a narrow "temporary lack of self-certification" carve-out. Records must be retained for at least six years.
- Registration and local Principal Point of Contact: From 1 January 2026, Financial Institutions must register on or before 31 January following the year in which they become a Financial Institution (with a one-off deadline of 30 April 2026 for entities that became Financial Institutions in 2025). The required information now includes the details of a Principal Point of Contact located in the Cayman Islands, with transitional relief until 31 January 2027 for existing registered institutions to appoint a local Principal Point of Contact and file a change form. Change forms for any updates must be submitted within 30 days.
- Reporting cycle and declarations: For the 2026 reporting year onwards, returns and CRS compliance forms must be filed by 30 June of the following year, together with declarations that the information provided is adequate, accurate and current. All filings must be made via the Department for International Tax Cooperation's electronic portal.
- Digital assets and electronic money: Amendments to the Schedule expand the CRS framework to cover specified electronic money products, central bank digital currencies and relevant crypto-assets, including by updating the definitions of Depository Institution, Financial Assets and Depository Accounts, and by introducing specific value thresholds for low-risk electronic money accounts.
- Penalties and supervision: The Tax Information Authority's monitoring powers are reinforced and the penalty regime revised, including a cap that prevents the combined primary and continuing penalties from exceeding CI$50,000 and the removal of statutory interest on penalties. In certain cases of failure to file returns, the Authority may proceed directly to a penalty notice.
The Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 has been published.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
