What Banks Actually Report About Nomads
If you open or hold accounts while traveling, CRS (Common Reporting Standard) is the quiet background process that ships your account data from your bank to your tax residence(s)—automatically, every year. This isn’t rumor or “big brother” lore; it’s a codified, audited system run via the OECD’s Automatic Exchange of Information (AEOI). Below you’ll find a plain-English explainer of who is reportable, what gets reported, when it moves, how due diligence works (self-certs, controlling persons), why multiple residencies can mean multi-country reporting, and how tax authorities actually use the data.
Introduction: The global financial surveillance you need to know about
CRS is not a bank policy; it’s an international standard adopted by 100+ jurisdictions and implemented through domestic law. Financial institutions (FIs) collect your tax residence details when you open or maintain in-scope accounts, report your identity + balance + income to their local tax authority, and those authorities exchange that data—generally by September following the calendar year. For nomads, the upshot is simple: if your self-cert says you’re tax-resident in Country A (and B), your bank in Country X will transmit your data to A (and B) via AEOI. The United States does not participate in CRS (it runs FATCA), but most of the rest of the world does.
CRS isn’t about catching you out for moving around; it’s about standardized transparency. The data fields are narrow and defined (who you are, which account, how much was in it at year-end, and what income hit it), the exchange is machine-readable (XML schema), and the receivers are required to meet strict confidentiality and data-safeguard standards. That’s why the system works at scale across dozens of bilateral exchange relationships.
What is CRS (Common Reporting Standard)?
OECD automatic exchange of information
CRS is the OECD’s technical standard that enables Automatic Exchange of Financial Account Information (AEOI). FIs in participating jurisdictions collect and report standardized fields to their tax authority; that authority then forwards the data to each relevant partner under the Multilateral Competent Authority Agreement (MCAA). The nuts and bolts—definitions, account types, due-diligence rules—live in the Standard and the Implementation Handbook.
100+ participating jurisdictions
More than a hundred jurisdictions have implemented CRS, with new joiners each year. The Global Forum’s commitments list and “CRS by jurisdiction” dashboard track who is live and when first exchanges occur (recent additions include countries that began exchanges in 2024–2025). Always rely on the OECD source for the current roster; do not trust outdated blog lists.
How it differs from FATCA
CRS is global/multilateral; FATCA is the US-centric regime targeting US persons. CRS uses self-certification of tax residence across participating countries; FATCA focuses on identifying US indicia. Also, the US is not a CRS participant—it exchanges via FATCA/IGAs. For a bank, both regimes can run side-by-side, but they’re legally distinct.
Who is a “reportable person” under CRS?
Tax residence indicators
Banks do not “decide” your tax residence; they collect your self-certification and check for indicia (address, phone numbers, standing instructions, POA, etc.). If you declare residence in Country A, your account becomes reportable to A (subject to threshold and account type rules). If you change residence, that’s a change in circumstances—you must update your bank. Wikipedia
Self-certification requirements
The CRS self-cert is the key form. Individuals provide name, address, date of birth, jurisdiction(s) of tax residence, and TIN(s); entities provide entity details + FATCA/CRS classification and identify controlling persons, who then self-cert individually. OECD publishes model self-certs FIs use or adapt. Refusing to self-cert typically leads to account restrictions or reporting based on indicia.
When nomads trigger reporting
If your self-cert lists multiple tax residencies, the FI reports your account to each listed jurisdiction. If you migrate mid-year and update your details, different periods may be reported to different countries. If you try to claim “no tax residence,” most banks will reject the self-cert and treat the account as reportable based on indicia or simply refuse onboarding. The system is designed to avoid “residence nowhere.”
What data banks actually report
Account holder information (name, address, TIN)
Banks report identity fields: name, address, TIN(s) (or functional equivalent), date/place of birth (for individuals), plus account number and the reporting FI’s identifiers. These are standardized in the CRS schema and mapped by the FI’s reporting system.
Account balance (year-end snapshot)
Reporting includes the account balance/value at year-end (or at closure, if the account was closed). Some jurisdictions may also request average balances domestically, but the CRS minimum is the year-end/closure value. Negative balances are typically reported as zero (per local guidance that implements the CRS).
Income types: interest, dividends, other
FIs report the gross amount of certain income credited during the year—commonly interest, dividends, and some other financial income (e.g., certain annuities or similar payments) depending on account type. The CRS uses defined income categories so partner tax authorities can match your reported income to domestic filings.
Gross proceeds from sales (in some cases)
For custodial accounts, jurisdictions may include gross proceeds from the sale/redemption of financial assets; consult your FI’s guidance to see if they report proceeds in your jurisdiction. The Standard and Handbook address these fields explicitly.
At a glance — “What’s in the CRS file?”
- Account holder IDs: name, address, TIN(s), DoB
- Account info: account number, reporting FI
- Year-end balance (or value at closure)
- Gross amounts credited: interest, dividends, and other in-scope items
- For custodial accounts (in many cases): gross proceeds of sales/redemptions
The reporting timeline: when your data travels
Annual cycles (calendar year → September report)
CRS reporting runs on a calendar-year basis. FIs file to their domestic authority after year-end, and under the MCAA the exchange between authorities occurs by the end of September of the following year. That is the anchor most jurisdictions work toward; local FI filing deadlines are set to meet it.
Which tax authority receives your data
Your bank reports to its tax authority, which then forwards your data to the tax authorities of each jurisdiction of residence you declared (and with which it has an activated exchange relationship). The OECD maintains dashboards of activated relationships and jurisdiction status so institutions (and you) can verify who exchanges with whom.
CRS due diligence: what your bank asks and why
Self-certification forms (like W-8BEN but for CRS)
Think of CRS self-certs as the global cousin of W-8BEN/W-9. They capture tax residence info (jurisdiction + TIN), and for entities, the CRS classification and controlling persons. Banks must obtain these at onboarding and on change in circumstances. Without them, reporting (or account restrictions) follows.
Documentary evidence requirements
Banks validate your self-cert with documentary evidence: passports, government letters showing address/TIN, company registries for entities, etc. The Implementation Handbook explains how FIs are expected to document and retain evidence that supports classifications and residence claims.
Controlling persons (for entities)
For Passive NFEs (passive non-financial entities), FIs must identify controlling persons (beneficial owners) and collect self-certs for each—so the individuals’ details are reportable too if they are tax-resident elsewhere. This is one of CRS’s core anti-opacity features. OECD provides a model controlling-person self-cert form widely used in practice.
Multiple tax residences: being reported to 2+ countries
Per the form you sign, each jurisdiction where you are tax-resident becomes a reporting destination for that account. If you list two countries (e.g., split-year or dual residence), your FI will mark the account as reportable to both (assuming activated exchange relationships exist). If you update mid-year, the FI applies the change going forward; timing can result in different year portions landing with different authorities. This is expected behavior, not a glitch.
Nomad-specific issues
Address changes mid-year
Your mailing address is not the same as tax residence, but frequent address churn is a change in circumstances that often triggers a self-cert refresh. Keep your bank profile and tax residence declarations in sync. If your W-8BEN/W-8BEN-E (for US withholding) and your CRS self-cert point to different countries, expect compliance follow-ups.
“No tax residence” claims (usually rejected)
CRS is deliberately designed to avoid gaps. Banks expect at least one jurisdiction of residence (and a TIN), unless your situation qualifies for a recognized exception. “Perpetual traveler with no residence anywhere” is not a workable CRS position for most banks; they’ll fall back to indicia or decline onboarding. Wikipedia
Digital nomad visas and CRS treatment
A digital-nomad visa is an immigration status, not automatically a tax residence. Banks care about your tax law status (where you are resident under domestic rules). If your DNV country becomes your tax residence (with a TIN), expect your FI to report to that country going forward; if not, your original residence may still govern reporting. Align your self-cert with the jurisdiction that actually taxes you.
What happens with the reported data
How tax authorities use CRS information
Tax authorities compare CRS data against domestic returns and registries. They use it to locate undeclared foreign accounts, cross-check investment income, and populate compliance campaigns. The AEOI framework includes peer review of confidentiality and process, and authorities must meet information security standards (often benchmarked to ISO-27000) to receive data.
Compliance checks and audits
CRS isn’t a bill; it’s a signal. Mismatches (e.g., foreign account reported to Country A with income, but your return in A shows nothing) can trigger soft letters, questionnaires, or audits. For nomads with legitimate split-year or exemption claims, having TRCs (tax residence certificates) and a clean day log makes closing inquiries far easier.
Privacy considerations and data protection
CRS exchanges are government-to-government and subject to confidentiality/use restrictions. Jurisdictions must demonstrate legal and technical data safeguards—and undergo assessments—before they can receive AEOI data. The Global Forum provides confidentiality toolkits and assistance to raise safeguards to acceptable standards. If a jurisdiction cannot meet the bar, it won’t be activated as your exchange partner until it does.
Treaty-style flowchart: How your data moves
You open/maintain an account → Bank obtains CRS self-cert (tax residence + TIN)
↓
Bank identifies reportable accounts per CRS due diligence
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Bank reports (XML) to its domestic tax authority (after year-end)
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By end-September (target under MCAA), authority exchanges with each partner
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Your tax authority ingests data → pre-populates checks → contacts you if needed
(Timeline benchmark per OECD Implementation Handbook; local filing deadlines vary by country to hit the September exchange.) OECD
CRS participating countries (snapshot & source of truth)
The roster evolves (new joiners commit, first-exchange dates shift). As of 2025, the OECD’s commitments list shows additional first-time exchanges in 2024–2025 (e.g., Georgia, Kenya, Moldova, Ukraine in 2024, and further adopters scheduled into 2025+). For an up-to-date, authoritative list and each jurisdiction’s implementation status, consult:
- AEOI commitments (Global Forum PDF) — status and first-exchange year, updated periodically.
- CRS by jurisdiction dashboard — implementation details and activated relationships.
Why this matters for you: If your tax residence is in a newly activated jurisdiction, your bank may redeem/update your self-cert and start reporting that year’s data to the new country according to the announced timeline.
Quick answers Nomads ask (and what the rules say)
- Do banks report every account? They report in-scope financial accounts (depository, custodial, certain investment/insurance accounts) held by reportable persons. Some domestic regimes add de minimis or local specifics; the CRS minimum is set in the Standard.
- Do they report transactions? CRS focuses on year-end balance and gross amounts credited (interest/dividends; often gross proceeds for custodial accounts). It’s not a full transaction ledger.
- When does my data move? Banks report after year-end; authorities exchange by end-September following the year (per MCAA). Local filing deadlines are set to make that possible.
- How safe is it? Exchange partners must meet confidentiality & ISM criteria (legal + technical, peer-reviewed).
- Is the US in CRS? No. The US operates FATCA; many banks handle CRS + FATCA concurrently.
Conclusion: Transparency is the new normal
As a traveling investor or contractor, plan on routine, automatic data exchange under CRS. Your job isn’t to game it—it’s to keep your self-cert honest, your TINs current, your addresses aligned with reality, and your documentation tidy (TRC, day logs, W-8s where applicable). If you adopt multiple tax residencies in a year, expect multi-country reporting; that’s by design. The good news is that CRS fields are simple and predictable. Treat the system as a compliance baseline and focus your energy on correct filings and legitimate planning—not surprises.
