Concept: Reportable Account vs. Reportable Person
Under the CRS and FATCA, Financial Institutions do not simply report all accounts; they only report accounts that are classified as Reportable Accounts held by Reportable Persons (or certain passive entities controlled by Reportable Persons).
Understanding this distinction is key to defining the scope of annual compliance filings.
Reportable Person
A Reportable Person is an individual or entity that is tax resident in a Reportable Jurisdiction under the laws of that jurisdiction.
However, the regulations explicitly exclude the following entities from being treated as Reportable Persons (even if they are resident in a reportable jurisdiction): * A corporation the stock of which is regularly traded on one or more established securities markets. * Any corporation that is a Related Entity of a publicly traded corporation. * A Governmental Entity, an International Organization, or a Central Bank. * A Financial Institution (which has its own reporting obligations).
To establish whether an account holder is a Reportable Person, RFIs collect a Self-Certification.
Reportable Account
A Reportable Account is a financial account maintained by a Reporting Financial Institution (RFI) that is held by: 1. One or more Reportable Persons, or 2. A Passive Non-Financial Entity (Passive NFE) that has one or more Controlling Persons who are Reportable Persons.
Exclusions & Rules
- Active NFEs: If an account is held by an Active NFE, it is not a Reportable Account, regardless of the residency of its controlling persons.
- Nil Returns: If an RFI maintains no Reportable Accounts during a calendar year, it is still required to register on the DITC Portal and submit a CRS Filing Declaration (or Nil Return) by the 31 July deadline.
Related Concepts
- Reporting Financial Institution (RFI)
- Self-Certification
- Controlling Persons
- Reportable Jurisdiction
Referenced PDF Sources
- OECD Consolidated Text of the Common Reporting Standard (2025)
- Tax Information Authority CRS Regulations (2021 Revision)
- OECD CRS Implementation Handbook (Second Edition)
- OECD Crypto-Asset Reporting Framework (CARF) & 2023 CRS Update
- OECD Standard for Automatic Exchange of Financial Account Information (Second Edition)
- The Amended Common Reporting Standard for Automatic Exchange of Financial Account Information in Tax Matters
- CRS Enforcement Guidelines
- CRS Reporting Obligations: Date of Birth (DOB)
- CRS Reporting Obligations: Tax Identification Numbers (TINs)
- Entity Self-Certification Form
- Individual Self-Certification Form
- Cayman Islands MCAA (Certified Copy)
- DITC Portal User Guide
- Explanatory Note: CRS Deactivations
- Tax Information Authority ( International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025
- CRS-related Frequently Asked Questions
- OECD CRS XML Schema User Guide
- DITC CRS Guidelines
- DITC CRS News Updates