CRS (Amendment) Regulations, 2025

FAQs

The Cayman Islands’ tax authority, the Department for International Tax Cooperation (“DITC”) has introduced significant updates to its Common Reporting Standard (“CRS”) framework through the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025. These changes modernise the jurisdiction’s automatic exchange of information regime, strengthen due diligence and reporting standards, and incorporate key elements of the OECD’s Updated CRS. As these amendments come into effect, Cayman Financial Institutions face enhanced governance obligations, expanded data requirements and increased regulatory scrutiny. The FAQs below summarise the key developments and their practical implications. 

Q1. What is driving these CRS amendments? 

The amendments implement the OECD’s Updated CRS, which reflect changes agreed internationally to address digital assets, enhance data quality and improve the effectiveness of automatic exchange of information. 

Q2. What are the main implications for Cayman Financial Institutions? 

Cayman Financial Institutions will face higher expectations for the quality and completeness of self-certifications and account information, additional annual reporting in the form of the Compliance Form, an expanded set of reportable data fields and a more robust penalty and monitoring framework. 

Q3. What happens if we cannot obtain a self-certification for a new account? 

In exceptional circumstances where a self-certification cannot be obtained in time for reporting, the institution must apply the pre-existing account due diligence procedures (using indicia and AML/KYC records) until a valid self-certification is obtained and validated. This is intended as a temporary measure, not a substitute for collecting self-certifications. 

Q4. When is the Compliance Form due and who must file it? 

All Cayman Financial Institutions within scope of the Regulations must file a Compliance Form annually by 30 June, for the prior calendar year, in addition to any CRS return or nil return. The Form must include a declaration that the information provided is adequate, accurate and current. 

Q5. What are the penalties for failing to submit the CRS return or Compliance Form? 

Failure to comply with Regulation 9 (which includes the obligation to submit returns and the Compliance Form) may result in an immediate primary penalty of CI$50,000, imposed by penalty notice without a prior breach notice. Continuing penalties cannot increase the total penalty beyond CI$50,000 and interest on penalties is no longer applicable. 

Q6. How do the DITC’s enhanced monitoring powers affect our operating model? 

Institutions must ensure that CRS and AML/KYC records can be produced promptly on request, including where records are held by group entities or service providers outside the Cayman Islands. Where required, records must be brought physically into the Islands within the timeframe specified by the DITC.