Educational only. This explainer is a practical overview of the Common Reporting Standard (CRS) for cross-border investors. It is not legal or tax advice. Laws, guidance, and local implementations vary. Confirm details with your tax authority or a qualified professional.
A clean CRS posture has three parts: know the scope (who reports what), understand the data flow (FI → local tax authority → partner authorities), and keep your self-certifications and identifiers current so your records reconcile with what tax authorities receive.
What is CRS (and why it exists)
Use these actions:
- Understand CRS as the OECD’s automatic exchange framework for financial account information between participating jurisdictions.
- Identify whether your country, financial institution (FI), and accounts fall in scope.
- Keep your self-certifications (residency + TINs) accurate to avoid mismatches downstream.
- Remember: CRS is reporting, not a tax regime. Your home country’s rules determine tax owed.
- Treat this guide as educational, not individualized advice.
Purpose: combat tax evasion via automatic exchange of financial account info
CRS was designed by the OECD to curb offshore tax evasion by creating a standardized, automatic data exchange. Participating tax authorities receive annual account information about residents who hold accounts abroad, helping them pre-fill returns, run risk analytics, and open audits more efficiently.
Who’s in scope: participating jurisdictions, reporting FIs, account holders
- Participating jurisdictions opt into CRS and sign competent authority agreements to exchange data.
- Reporting Financial Institutions (banks, brokers, custodians, certain insurers, and some investment entities) must perform due diligence and report.
- Account holders and controlling persons: Individuals and entities tax resident outside the FI’s jurisdiction are typically reportable.
This guide is educational, not legal/tax advice
CRS implementation differs by country (thresholds, deadlines, nuances). Use this as a workflow companion; verify local specifics with official guidance or a qualified advisor.
Who reports what (actors and data fields)
Use these actions:
- Confirm whether your provider is a Reporting FI and what account types they classify as reportable.
- Provide accurate self-certs (residency + TINs) and keep them updated after moves/name changes.
- Mirror your broker/bank profile (name, address, TINs) across platforms to reduce mismatch risk.
- Save annual statements and, if offered, CRS summary letters for your files.
- Keep an account list with residency tags and close-date notes.
Reporting Financial Institutions (banks, brokers, custodians, some insurers)
Reporting FIs identify reportable accounts via onboarding and periodic reviews. They compile required fields and file them with their local tax authority in the prescribed XML schema.
Reportable persons (non-resident account holders, controlling persons of entities)
- Individuals: If you’re tax resident in country X and hold an account in country Y, Y’s FI may report you to Y’s tax authority, which forwards to X.
- Entities: If the entity is passive, the FI may have to identify and report controlling persons (beneficial owners) who are non-resident.
Core data: name, address, TIN(s), date of birth, account number, balance, gross amounts
Typical fields include name, address, date of birth, TIN(s), account number, year-end balance, and gross amounts like interest, dividends, and gross proceeds.
Table — Actors and Data (template)
| Actor | Obligation | Data elements | When reported | To whom |
|---|---|---|---|---|
| Reporting FI (bank/broker/custodian/insurer) | Perform due diligence; file CRS report | Account holder/controlling person name, address, DOB, TIN(s); account number; year-end balance; gross interest/dividends/proceeds | Annually (per local deadlines) | FI → Local tax authority |
| Local tax authority | Validate & exchange | Aggregate per partner; ensure schema/validation | Annually (CRS schedule) | Local authority → Partner authorities |
| Partner tax authority | Use data | Ingest; match to domestic records | On receipt | Home jurisdiction of account holder |
The data flow (end-to-end)
Use these actions:
- Map your accounts: for each FI, note jurisdiction, account type, and your tax residence(s).
- Expect annual reporting with prior-year balances/amounts (date cut-offs differ locally).
- Anticipate mismatches from name/TIN/address inconsistencies; fix upstream at the FI.
- Keep FX conversion notes for your own records (even if FIs report in a different currency).
- Understand timing: your home authority may receive data months after year-end.
FI collects → sends to local tax authority → exchanged with partner jurisdictions
- FI due diligence: Onboarding self-certs + periodic reviews identify reportable accounts.
- FI filing: FI compiles and files CRS data to its local authority.
- Exchange: Local authority transmits to partner authorities for matched tax residences.
Annual cadence and cut-off dates (high-level)
Reporting is annual. The reporting period (often calendar year) and submission deadlines vary. Many authorities receive and exchange data mid-to-late the following year.
How mismatches arise (names/TINs/addresses, currency conversions)
- Name formats (diacritics, multiple surnames), address moves, missing/incorrect TINs, and date formats cause matching errors.
- FIs may report in their local currency while you file in another; keep your FX source and timestamp for reconciliation.
Diagram — Flow (placeholder)
[Account Holder]
│ self-cert (residence + TINs)
▼
[Reporting FI] — collects balances & gross amounts
│ annual CRS file (XML)
▼
[Local Tax Authority] — validates & packages
│ automatic exchange (AEOI)
▼
[Partner Tax Authority] — ingests & matches to resident
Onboarding & due diligence (how FIs classify you)
Use these actions:
- Complete self-certification forms fully (individual vs entity).
- Provide TIN(s) for each tax residence; if unavailable, supply reason codes allowed locally.
- For entities, determine classification (FI vs NFE; active vs passive).
- Identify controlling persons (names, DOB, addresses, TINs) for passive entities.
- Update self-certs when residency or entity status changes.
Self-certification forms (individual vs entity)
- Individual self-cert: declares tax residence(s) and TIN(s); you attest accuracy.
- Entity self-cert: declares entity classification under CRS and lists controlling persons if the entity is a Passive NFE.
Residence/TIN capture and reason codes (where applicable)
If you cannot provide a TIN, many regimes allow a reason code (e.g., “no TIN issued”). This is not a tax strategy; it’s documentation of fact. If a TIN is issued later, update the FI.
Entity classification & controlling persons (look-through)
Entities are classified as Financial Institution (FI) or Non-Financial Entity (NFE); NFEs are Active or Passive. Passive NFEs require identifying controlling persons (e.g., >25% owners, per local rules).
CRS vs FATCA (and where they overlap)
Use these actions:
- Know that CRS ≠ FATCA. CRS is a multilateral OECD standard; FATCA is US law.
- The US is not a CRS jurisdiction; it exchanges under FATCA/IGA frameworks.
- Expect similar data fields (identity, balances, gross amounts) but different definitions/exemptions.
- For cross-border portfolios, you may be subject to both regimes.
- Keep consistent identifiers across forms to avoid mismatches.
Scope differences, US participation note
- CRS spans many jurisdictions exchanging with one another.
- FATCA targets US taxpayers and foreign financial institutions reporting to the US (or via IGAs). The US does not participate in CRS.
Data fields: similarities and key divergences
Both collect identity and financial data; however, entity classifications, exempt accounts, and due diligence criteria can differ.
Practical takeaway for cross-border investors
If you’re an EU resident investing globally, expect CRS reporting from your non-US accounts and FATCA-like processes if you have US indicia. Keep self-certs, W-8/W-9 (as applicable), and account identifiers aligned.
Practical implications for individuals
Use these actions:
- Track all accounts (bank, broker, custodian, insurer) with jurisdiction and status (open/closed).
- Update self-certs on address or residency changes.
- Keep TINs tidy—store copies and renewal reminders.
- Expect pre-filled government data or follow-up letters if mismatches occur.
- Use UTC and consistent FX sources in your own records.
Multiple residencies, address changes, and keeping records tidy
If you hold multiple tax residencies in a year, your FI may report you to multiple authorities. Maintain a timeline of addresses and residencies with supporting documentation.
How brokers may ask for updated self-certifications
Brokers periodically refresh self-certs, especially after KYC events, mail bounces, or returns from partner authorities. Respond promptly to avoid account restrictions.
What shows up at home: pre-filled data vs your return (high-level)
Some authorities pre-fill parts of your return (balances/amounts). You remain responsible for accurate filing—reconcile pre-filled data with your statements.
Practical implications for entities & controlling persons
Use these actions:
- Determine your entity classification (FI vs NFE; Active vs Passive).
- Identify controlling persons and gather their TINs.
- Keep ownership registers current and accessible.
- Refresh self-certs upon ownership or activity changes.
- Store board resolutions or policies supporting your classification.
Entity self-certification, NFE vs FI concepts (high-level)
Investment entities may themselves be Reporting FIs (depending on where they’re managed). Operating companies are usually Active NFEs; holding companies with mainly passive income may be Passive NFEs.
Identifying controlling persons and their TINs
Define controlling persons per local CRS rules (often >25% ownership or control via other means). Capture names, DOB, addresses, TINs, and keep them updated.
Record-keeping and evidence trail
Maintain a CRS file: self-certs, ownership charts, controlling person IDs, and correspondence with FIs.
Common issues and how to avoid them
Use these actions:
- Standardize name formats (diacritics, order of surnames) across all FIs.
- Keep TINs valid and legible; replace expired IDs.
- Update addresses everywhere after a move—before year-end cut-offs.
- Close dormant accounts formally; keep closure confirmations.
- Reconcile FX differences; note source and timestamp.
Missing/incorrect TINs, name variations, outdated addresses
These cause matching failures and letters from tax authorities. Fix at the FI level and document the change.
Dormant/closed accounts still showing balances (timing)
Year-end snapshots can show balances on accounts closed early next year. Keep closure letters to explain timing.
Currency/FX mismatches and reconciliation tips
FIs may report in local currency using internal rates. For your return, record FX source (e.g., central bank, broker rate) and timestamp.
Security & privacy basics for exchanged data
Use these actions:
- Upload self-certs only through secure FI portals; beware phishing.
- FIs never need crypto seed phrases, private keys, or wallet passphrases—decline any such request.
- Use hardware-key 2FA (where possible) for bank/broker portals.
- When traveling, prefer hotspot over public Wi-Fi.
- Store exported files in encrypted archives with offline backups.
What FIs can ask vs what they should never ask (e.g., no seed phrases/keys)
Legitimate requests: IDs, addresses, TINs, entity forms. Illegitimate: passwords, 2FA codes, seed phrases/private keys.
Secure channels for document upload; phishing red flags
Upload via logged-in portals only. Watch for look-alike domains, unsolicited “urgent compliance” emails, and attachments requesting macros.
Travel scenario: accessing portals safely (link to Security guide)
See Security for Nomads for a full hardening playbook: /security-for-nomads.
FAQs (short and practical)
Does CRS mean I owe tax where my account is?
No. CRS is a reporting framework. Your tax residency drives where you owe tax. The account jurisdiction sends data to your home authority.
Do non-custodial crypto wallets fall under CRS?
CRS focuses on financial institutions and financial accounts as defined locally. Self-custody wallets are generally outside FI reporting, but exchanges/custodians may report on-platform activity. See Crypto Reporting Basics: /crypto-reporting-basics.
What if my country isn’t a CRS participant?
Your FI’s jurisdiction may still require reporting if you are a resident of a participating country. If neither side participates, CRS exchange won’t occur—but other regimes (e.g., FATCA, local rules) may apply.
How long should I keep self-certs and statements?
Plan for 7–10 years (local rules vary). Keep raw PDFs, acknowledgments, and a timeline of changes.
CHECKLIST — CRS Clean-Up Pack (downloadable)
(Copy this block to your notes; print and tick boxes. Keep an offline, encrypted copy.)
<a id=»crs-clean-up-pack»></a>
Self-cert & IDs
- Latest individual/entity self-cert on file at each FI
- Valid TIN(s) for each tax residence
- ID + address proof (≤90 days) stored, legible, matching FI profile
- Controlling persons (for entities): IDs, TINs, ownership chart
Accounts & timeline
- Master account list (FI, country, account number, open/close dates)
- Address/residency timeline (date ranges + documents)
- Closure letters for dormant/closed accounts
Consistency & FX
- Name format standardized across FIs (accents, order)
- All timestamps normalized to UTC in your files
- FX source + method noted (per event or per statement)
Security & storage
- Files in encrypted archive (duplicate offline backup)
- Broker/bank portals secured with hardware-key 2FA
- Phishing playbook circulated to family/partners
Disclaimer
Key takeaways
- CRS is automatic exchange of financial account data: FI → local authority → partner authority.
- Your job is to keep self-certs, TINs, and addresses current and consistent across FIs.
- Expect annual reporting of balances and gross amounts (interest/dividends/proceeds).
- Reconcile mismatches by fixing upstream data; keep a CRS Clean-Up Pack.
- CRS is reporting, not tax law—your home country determines tax owed.
Educational only. This overview is not tax or legal advice. Verify your facts and obligations with official guidance and a qualified professional.
Interlinks:
- US Broker Requirements → Curated guide about US Broker Requirements.
- US–Spain Tax Treaty Basics → Insights about Tax Treaty between Spain and US.
- Crypto Reporting Basics → Quickstart guide about Crypto reporting.
- Security for Nomads → Hardening Your Brokerage and Crypto Access.
- Modelo 720 y activos en el extranjero → Guide for filling the Model 720.
- Declarar tus inversiones (acciones, ETFs) en España (ES) → Asset declaration in Spain.
