The Common Reporting Standard (“CRS”), introduced by the Organisation for Economic Co-operation and Development (“OECD”) in 2014 and adopted by the Cayman Islands in 2017, was designed to create a global framework for the automatic exchange of financial account information and to enhance tax compliance.
Over time, the financial landscape has evolved, driven by new financial products, new risk exposures and heightened global transparency expectations. In response, the OECD has adopted CRS 2.0, a major upgrade that refreshes the framework, broadens reporting obligations, tightens due diligence rules, and aligns CRS more closely with the new Crypto-Asset Reporting Framework (“CARF”). CRS 2.0 represents the most significant enhancement to the CRS regime since its 2014 launch, and it will materially impact how Cayman Financial Institutions (“FI”) collect, manage, and report client data.
What does this mean for the Cayman Islands FIs?
For a Cayman Islands entity that is a FI for the purposes of CRS, CRS 2.0 introduces stricter reporting standards, expanded data requirements, and a greater regulatory focus on accuracy and timeliness.
This article highlights the key developments and outlines how we can support you in achieving seamless CRS 2.0 compliance.
Key changes in Cayman under CRS 2.0
- Requirement for a Cayman-based Principal Point of Contact (“PPOC”)
From January 1, 2026, each Cayman FI must appoint a Principal Point of Contact resident in the Cayman Islands.
Note: Existing FIs i.e FIs registered before 1 January 2026 have until 31 January 2027 to notify DITC of their Cayman-based PPoC. - Scope expansion - digital and innovative products
Cayman is adopting the OECD’s expanded definitions so that the CRS now explicitly captures certain electronic money products and relevant crypto assets held through financial products or investment vehicles.
The Investment Entity definition is also widened to cover entities investing in or managing Relevant Crypto-Assets, not just traditional financial assets.
The implication of these changes is that funds, managers, EMIs, payment platforms and any structures with digital-asset exposure must revisit their CRS classification and determine whether they are now FIs. - New data points to report
Cayman FIs must report several new data points for each reportable account under the amended CRS. These include:
• Account type
• Whether a valid self-certification has been provided
• Number of joint account holders
• All controlling persons’ roles
From 2027 reporting onwards (for 2026 data), full reporting of these roles and additional data fields will become mandatory, with a transitional phase for 2025–2027. - Stronger due diligence and self-certification rules
CRS 2.0 pushes Cayman FIs to:
• Obtain a valid self-certification at or before account opening for new accounts, with only a narrow “temporary lack” exception (where pre-existing account procedures must apply until a valid self-cert is obtained).
• Ensure information reported is “adequate, accurate, and current” – this is now a formal standard, and filings must be accompanied by a declaration to that effect. - Registration and change-notification rules
• Registration deadline moved forward:
- Entities that became FIs in 2025: must register with DITC by April 30, 2026.
- FIs from 2026 onwards: must register by January 31 of the year following the year they became an FI.
• 30-day change-notification rule
- Any change to registration details (e.g. PPoC, classification, contact info) must be notified to DITC via a change form within 30 calendar days. - Reporting deadlines and schemas
The table below shows the changes that CRS 2.0 will bring to the existing historical reporting deadlines:
Requirement Historical deadline date New deadline date (for 2025 data reported in 2026) New deadline date (from 2026 onward, reported in 2027 and beyond) CRS Return July 31 July 31, 2026 June 30 of the following year CRS Compliance Form September 15 September 15, 2026 June 30 of the following year - Penalties and enforcement
Effective January 1, 2026, the Tax information Authority (“TIA”) will have the ability to issue an administrative penalty for breach without first providing a breach notice.
This is consistent with the global trend and the DITC has already signaled increased focus on enforcement as part of AEOI effectiveness reviews.
How we can help you
Our team of dedicated professionals can help you ensure full compliance as you transition into the new framework by providing you with the following services:
- Full DITC management and Cayman-based PPoC:
- We will handle all aspects of DITC registrations, updates, and ongoing notifications
- We will act as your Cayman-based PPoC, ensuring that you meet the new requirements with zero operational burden
- CRS calendar management – we will manage your entire CRS calendar, ensuring that you never miss any deadline - Other bespoke solutions, such as updating of policies and procedures and training of teams and boards to ensure that they are aware of the new requirements.
You focus on performance. We handle the compliance.
Please contact us if you have any questions.
Anne Storie, Global Head of Strategic Alliances & Country Head, Cayman
Geoffrey Mutua, Director of Operations
Tel: +1(345) 747-2739
Email: info@apexfunds.ky
Frequently Ased Questions – CRS 2.0 Compliance (Cayman Islands)
- What is CRS?
The CRS is an international standard for the automatic exchange of account information between tax authorities. The CRS imposes obligations on FI, to review and collect information to identify an account holder’s country of tax residence and then provide certain account information to the TIA in the Cayman Islands. - How is CRS different from the Foreign Account Tax Compliance Act?
The Foreign Account Tax Compliance Act (“FATCA”) relates only to customers who are citizens of the United States or are resident for tax purposes in the United States. On the other hand, CRS reports on a wider range of tax residency jurisdictions. - What is CRS 2.0?
CRS 2.0 is the OECD’s major update to the Common Reporting Standard, designed to update the framework, strengthen due diligence, and reflect new financial products, particularly digital assets. - When does CRS 2.0 take effect in the Cayman Islands?
CRS 2.0 becomes effective in Cayman from January 1, 2026, with the first filings under the new rules due June 30, 2027, for 2026 calendar-year data. - What are the biggest changes under CRS 2.0?
Key changes include expanded entity definitions, appointment of a Cayman-based PPOC, additional data fields, stricter self-certification requirements, earlier reporting deadlines, and enhanced enforcement powers. Digital-asset exposures may also trigger new classifications or due-diligence obligations. - Who is a PPoC?
The PPoC is the individual or legal entity appointed by the Reporting FI to act as the main liaison with the TIA and the Department for International Tax Cooperation (“DITC”) for all CRS-related matters. - What is a Cayman FI?
A “Cayman Financial Institution” means a custodial institution, a depository institution, an investment entity or a specified insurance company –
(a) resident in the Islands other than any of the institution’s branches outside the Islands; and
(b) a branch in the Islands of a FI not resident in the Islands. - Who must appoint a Cayman-based PPoC?
Every Reporting Cayman FI must appoint a Cayman-resident PPoC under CRS 2.0. Existing FIs must update their PPoC by January 31, 2027; new FIs must appoint one by the standard registration deadline. - Can Apex Cayman act as the PPoC for our entity?
Yes. We can serve as your Cayman-based PPoC, manage all correspondence with the TIA and DITC, and ensure your institution meets all CRS 2.0 obligations without operational burden on your team. - How will CRS 2.0 impact our onboarding process?
CRS 2.0 requires valid self-certifications at or before account opening, clearer identification of controlling persons, and structured collection of new mandatory data fields. Most onboarding forms and workflows will need to be updated. - What are the consequences of non-compliance?
The DITC now has enhanced enforcement powers. Penalties may be applied without prior warning for late filings, incorrect filings, missing data, or governance failures. Poor CRS compliance may also trigger regulatory scrutiny or reputational risk.
The Cayman CRS 2.0 timeline at a glance
From January 1, 2026
- CRS 2.0 comes into force.
- New entities becoming FIs from 2026 start tracking towards the January 31 registration deadline.
- Cayman-based PPoC requirement begins for new FIs formed in 2026.
2026 key dates
- April 30, 2026 – Registration deadline for entities that became FIs in 2025 (including appointment of a Cayman-based PPoC).
- July 31, 2026 – Reporting deadline for 2025 calendar-year CRS Returns (still using XML v2.0).
- September 15, 2026 – Deadline for the 2025 CRS Compliance Form.
By January 31, 2027
- New FIs formed in 2026 must register and provide full details, including Cayman-based PPoC.
- Existing FIs registered before January 1, 2026, must submit a change form to update their PPoC to a Cayman-based individual (if not already done).
June 30, 2027
- First full CRS 2.0 reporting deadline:
- CRS Returns and CRS Compliance Forms for 2026 data are due.
- New data fields and the updated OECD XML Schema v3.0 are mandatory.
June 30, 2028
- CRS Returns and Compliance Forms for 2027 data are due.
- Transitional provisions for some additional data fields and role-reporting end; 2.0 requirements fully embedded.
Ongoing
- Within 30 days of any relevant change (e.g. contact details, PPoC, classification): file a Change Notice via the DITC Portal.
