Cayman CRS update: DITC extends deadline for Cayman PPoC appointment

The update in brief

Following the DITC Industry Advisory issued 21 January 2026, Cayman has introduced a limited extension linked to the Principal Point of Contact (PPoC) requirement under the Amended CRS.

The key point is simple: this is not a relaxation of the rule. Cayman Financial Institutions (FIs) are still expected to have a Cayman-based PPoC.

The PPoC requirement is intended to ensure that the Tax Information Authority has a locally reachable and accountable point of contact for CRS compliance and regulatory communications.

Which deadlines have been extended?

The deadline has been extended to 31 January 2027 for:

• appointing a Cayman-based PPoC; and
• recording the date on which the entity became an FI.

This extended deadline applies to all Cayman FIs.

What has not changed

All other CRS obligations remain on track. In particular:

• CRS registration and reporting deadlines for the 2025 reporting period (due in 2026) are unchanged;
• The underlying requirement to appoint a Cayman-based PPoC remains in force; and
• The broader regulatory direction remains toward stronger controls and enforcement, consistent with the wider CRS 2.0 trajectory.

Practical takeaway

Although the deadline has been extended, Cayman FIs should not treat this as a reason to defer action. We recommend that entities review their current PPoC position during 2026 to avoid last-minute remediation, operational bottlenecks, and potential compliance risk as the transition window closes.

Questions? Reach out to your usual Harneys Fiduciary representative or one of our authors.