Navigating CRS 2.0 and CARF: the next phase of global tax transparency
With global automatic exchange of information frameworks continuing to evolve, early preparation is critical. Firms that adapt now will find the transition straightforward. Our focus is on ensuring our clients are well ahead of regulatory expectations.
Global tax transparency is entering a new phase, and from 2026 onwards, businesses with structures in the British Virgin Islands and Cayman Islands will face expanded reporting obligations. With the introduction of the enhanced Common Reporting Standard (CRS 2.0) and the new Crypto-Asset Reporting Framework (CARF), regulators are signalling a clear shift toward broader data collection, tighter deadlines, and increased scrutiny.
We understand that regulatory change can feel overwhelming. Our role is to turn that complexity into clarity, and to ensure you feel supported, informed, and prepared well ahead of time.
What’s changing and why it matters
Both Cayman and the BVI are adopting updated OECD standards designed to strengthen transparency and address emerging risks, particularly in the digital asset space.
From 1 January 2026, financial institutions will be required to collect and report more detailed information under CRS 2.0. This includes certain electronic money products, central bank digital currencies, and specified crypto-asset holdings held by investment entities. In terms of reporting timelines, Cayman is moving its CRS filing deadline to 30 June. The BVI will maintain its established April and May notification and reporting cycle.
At the same time, the introduction of CARF marks a significant development for crypto and fintech businesses. Transactions involving cryptocurrencies, stablecoins, certain NFTs, and other digital tokens will become reportable for the first time. Cayman’s CARF regulations are already in place and will apply to 2026 data, with reporting due in 2027. The BVI will follow shortly thereafter.
Alongside these changes, regulators are reinforcing compliance expectations. Cayman now requires each financial institution to appoint a locally resident Principal Point of Contact (PPoC), and enforcement regimes in both jurisdictions are becoming more robust, with greater focus on data accuracy, validation of self-certifications, and completeness of filings.
| Date | CRS milestone | CRS obligations for FIs |
|---|---|---|
| 1 January 2026 | Amended CRS comes into force | FIs are required to comply with the amended CRS legislation |
| 1 January 2026 | Appointment of Cayman based PPoC (for entities which become FIs from 01/01/2026) | Need help? Reach out to our team |
| 30 April 2026* | Registration deadline (for entities which became FIs in 2025) | FIs must register the required information with the DITC (including a Cayman-based PPoC) |
| 31 July 2026 | Reporting deadline (for 2025 calendar year) | Submit CRS returns using the OECD XML scheme v2.0, or submit Nil Returns and a Filing Declaration |
| 15 September 2026 | Reporting deadline (for 2025 calendar year) | Submit Compliance Form |
| 31 January of the following year* | Registration deadline (new FIs from 2026 onwards) | New FIs must register the required information with the DITC |
| 31 January 2027 | Deadline to register Cayman-based PPoC | Where, prior to 1 January 2026, a Cayman FI was registered with the Authority and has not notified the Authority of a person in the islands authorised to act as a PPoC, the Cayman FI must notify the Authority of the authorised person on or before 31 January 2027 |
| 30 June 2027 | Reporting under Amended CRS (for 2026 calendar year) | Submit CRS Returns using updated OECD XML Schema v3.0 or Nil Returns, Declaration and Compliance form |
| 30 June 2028 | Reporting under Amended CRS (for 2027 calendar year) transitional period ends | Full reporting of controlling person or equity interest holder roles, and all additional data fields, becomes mandatory for reportable accounts maintained as at 31 December 2025, where such information is available in the electronically searchable data held by the Reporting FI |
| *within 30 calendar days | File Change Notice | Notification to the DITC of any change in circumstances |
How we can help you prepare
We’ve been closely tracking these developments and have taken practical steps to help our clients prepare with confidence.
Our dedicated BVI and Cayman Regulatory Reporting team has analysed the new rules and translated them into clear, actionable guidance. We’ve developed updated checklists and practical frameworks tailored to trusts, funds, investment entities, fintech businesses, and crypto-asset service providers.
We’re also offering a CRS 2.0 and CARF Readiness Assessment. This service reviews your current compliance processes, identifies gaps against the new requirements, and delivers a clear action plan, giving you ample time to address any issues well before the first reporting deadlines.
As a licensed service provider in both Cayman and the BVI, we can act as your local point of contact where required, manage portal registrations, and submit filings on your behalf using technology aligned with the latest OECD reporting standards. For clients operating in the digital asset space, our teams combine regulatory reporting expertise with a strong understanding of blockchain and fintech business models, allowing us to support compliance without disrupting day-to-day operations.
Looking ahead
The direction of travel is clear: regulatory requirements are expanding, and early preparation is key. By starting now, we can help ensure that data collection in 2026 and reporting in 2027 feel routine, not reactive.
We’re committed to staying ahead of regulatory change, reach out to our team to discuss how CRS 2.0 or CARF may affect your structures.
