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

Referenced PDF Sources

Struggling with DITC Portal Registrations or CRS Filings?

Every Cayman financial institution must appoint a physical, Cayman-resident Principal Point of Contact (PPoC) or face automatic USD $12,200 penalties. The transitional grace period ends January 31, 2027.

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