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CRS 2.0 is an extension of the existing Common Reporting Standard (CRS). It expands the existing CRS scope to certain electronic money products, central bank digital currencies, regulated stablecoins, and indirect crypto exposure. CRS continues to be an annual exchange of account-level data and corresponding balances.
With the introduction of CARF and the widespread adoption of digital assets, companies must now determine whether they are subject to CARF, CRS 2.0, or both. This blog focuses on the additional data fields and reporting requirements associated with the CRS 2.0 extension.
CRS 2.0 Data Readiness: Essential New Fields for Compliance
The CRS 2.0 extension adds data points that require coordination across onboarding, KYC, product, account, and reporting systems.
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Controlling Person role
Capturing this data point on the Self-Certification is now critical as the ultimate XML now requires this data field for records with Controlling Persons.
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Joint Account Indicator
The Joint Account Indicator flags accounts held by multiple persons. Joint-account status should be captured and stored at the account level, not only as a contact relationship. It is also important to note that two Self-Certification forms are needed for Joint Accounts.
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Account Type
Proper account type classification is critical as it now impacts the ultimate fields utilized on the reporting file.
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New versus Pre-existing Status
This field distinguishes accounts opened after the applicable CRS effective date from prior accounts. The status should be maintained as a reporting classification linked to the account’s opening date.
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SEMP and CBDC Holdings
SEMP and CBDC holdings should remain connected to the relevant account, balance, income, and reporting treatment.
CRS 2.0 Operational Shift: Translating New Fields into Workflow Changes
Companies must transform their internal operations from a once-a-year data collection exercise into a broader annual function that includes collection, analysis, and monitoring. Operational workflows need to actively link customer onboarding to ongoing account maintenance by validating that self-certification forms capture the newly mandated CRS 2.0 parameters upfront.
Because these additional fields depend on dynamic circumstances involving the account holder, assets, activity, and classifications, companies must establish robust data-monitoring processes. This ensures that any operational change in ownership or account structure automatically triggers a re-evaluation of the client’s classification, guaranteeing that final XML reporting outputs remain accurate, lineage-tracked, and audit-ready.
CRS 2.0 FAQ
When did CRS 2.0 go live, and when is reporting due?
Because CRS 2.0 is implemented through domestic legislation across participating OECD jurisdictions, exact timelines depend on whether a country belongs to the First Wave or Second Wave adoption cohort. For First Wave jurisdictions, companies should be aware of the Self-Certification dates that generally were already in place, or commenced on January 1, 2026. The first wave of CRS 2.0 reporting will commence in early 2027.
Is CRS 2.0 a separate regime from CRS?
No. CRS 2.0 is an extension of the existing CRS. It expands the scope of CRS to cover certain digital assets and financial products, while CRS reports account balances and income.
Does CRS 2.0 apply to direct crypto-asset holdings?
Not automatically. CRS 2.0 covers certain indirect crypto exposure, including derivatives and funds deriving investment income from digital assets. Direct digital asset activity may fall under CARF, depending on the asset, service, and jurisdiction.
Are regulated stablecoins reported under CRS 2.0?
A regulated stablecoin is reported under CRS 2.0, while an unregulated stablecoin falls under CARF. What counts as a regulated stablecoin is decided country by country.
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