CRS 2026: What a Foreign Company Owner Should Check

The CRS (Common Reporting Standard) is the OECD standard for the automatic exchange of financial account information. A bank, broker or payment institution establishes the tax residency of the account holder and, for accounts of passive companies, of their controlling persons as well. The bank then reports the information to its own tax authority, which sends it once a year to the country of residence. In 2026, the standard was updated and Ukraine joined the extended exchange. Here is what this means for the owner of a foreign company.

The scale of CRS exchange in 2026

According to the OECD Global Forum (annual report, December 2025), 116 jurisdictions have started automatic exchange of account information, and another 13 have committed to start by 2028. For 2024, information was exchanged on 171 million accounts holding assets of almost €13 trillion. A separate standard for crypto assets, CARF, is ready to be implemented by 75 jurisdictions, with the first exchanges under it expected in 2027.

Ukraine and the CRS: timeline

• August 2022. Ukraine joined the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS MCAA).
• Since 2024, Ukraine has taken part in exchange under the CRS standard.
• On 15 June 2026, Order No. 316 of the Ministry of Finance aligned the national rules with the updated version of the CRS; the changes also partly implement EU Directive 2023/2226 (DAC8).
• September 2026. Ukraine joined the CRS MCAA Addendum: the Ministry of Finance announced this on 11 September, and the State Tax Service signed the declaration of accession. The Addendum adds the new data elements of the updated standard to the exchange.
• From 2027, according to the State Tax Service, the exchange of extended data will begin.

Accession by itself introduces no new taxes and does not make account information public: the data is received only by tax authorities.

What the updated standard (CRS 2.0) changes

The OECD amendments take effect in different countries on their own schedules. In the British Virgin Islands, they have applied since 1 January 2026: financial institutions collect the new data during 2026 and report it to the tax authority by May 2027. The main changes listed by the BVI government:

• the definition of a financial account now includes certain electronic money products and central bank digital currencies;
• crypto assets held in custody, derivatives and indirect investments in crypto assets are treated as financial assets;
• the information on account holders, controlling persons and the accounts themselves has been expanded;
• institutions must verify the reasonableness of the self-certification of both the account holder and the controlling person.

For an owner, this means that EMI accounts and brokerage positions in crypto instruments are increasingly included in reporting, and the bank will spot and correct errors in the self-certification form.

What the tax authority learns about your company

A bank divides corporate clients into active and passive ones. An active company carries on real trade or provides services, and the bank reports on the company itself. A passive company mainly receives dividends, interest or royalties, or holds assets. For its accounts, the bank discloses the controlling persons, that is, the beneficial owners, and the information goes to their country of residence. Banks classify most holding companies in the BVI and other offshore jurisdictions as passive companies. Who counts as a beneficial owner is explained in the article UBO and beneficial ownership disclosure.

CRS 2026: what an owner should check

• Tax residency. In the self-certification, state the country where you are actually tax resident. A mismatch with the bank’s data triggers a request.
• The company’s status. Check how the bank has classified the company (active or passive) and, if needed, submit a corrected form.
• CFC reporting. In Ukraine, the CFC rules are set out in Article 39-2 of the Tax Code, and controlling persons file a CFC report. Check thresholds and deadlines against the current version of the code and the State Tax Service’s guidance; more in the article CFC rules and the offshore company.
• The company’s place of management. If decisions are made in the owner’s country, the company risks becoming tax resident there; see company tax residency.
• EMI accounts and crypto instruments. The updated standard brings certain electronic money products and indirect investments in crypto assets into the exchange, so treat them in your CFC reporting the same way as bank accounts.
• Consistent data. The beneficial ownership register, the bank application and the CFC report must describe the same structure.

Common mistakes

Stating the country of citizenship instead of the country of tax residency in the self-certification. Forgetting to update the form after moving. Assuming that an EMI account is outside the exchange. Filing a CFC report with data that differs from the bank’s information. Each of these mistakes surfaces when the tax authority matches the CRS data.

If you are planning a structure with the CRS and CFC rules in mind or want to check your current one, start with a consultation on offshore company formation and maintenance.

Frequently asked questions