Dec 2025
Effective 1 January 2026, the Cayman Islands will implement extensive revisions to the Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations (the “CRS Regulations”), with certain operational requirements commencing in 2027. The reforms elevate data quality expectations, accelerate key filing dates, mandate the appointment of a Cayman Islands‑based Principal Point of Contact (the “PPoC”), and broaden the range of reportable information, with particular emphasis on digital assets.
The Common Reporting Standard (“CRS”) is the Organisation for Economic Co-operation and Development’s (“OECD”) global framework for the automatic exchange of financial account information designed to deter offshore tax evasion. The Cayman Islands, alongside more than 100 jurisdictions, participates in CRS by sharing account information annually under multilateral and bilateral exchange arrangements.
The Cayman Islands has been a CRS participant since 1 January 2016. Cayman Islands entities must assess their status as either Financial Institutions (“FIs”) or Non-Financial Entities (“NFEs”). Cayman Islands FIs are required to register and report via the Department for International Tax Cooperation (“DITC”) Portal and to maintain written policies and procedures that align with the updated due diligence and reporting rules.
The Cayman Islands will implement the 2026 “CRS 2.0” package through the Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025.
Key Updates
The amendments are designed to enhance data integrity—requiring information to be “adequate, accurate and current”—better align due diligence with contemporary anti‑money laundering standards, bring forward registration and reporting timelines, and modernise key concepts to expressly include crypto‑assets, e‑money and central bank digital currencies within the CRS scope.
Due Diligence
Cayman Islands FIs must put in place, implement and adhere to written policies and procedures that satisfy the revised CRS due diligence and reporting standards. These must include explicit controls to obtain a “valid” self‑certification for new accounts at or prior to account opening, subject to the limited “temporary lack of self‑certification” exception. Where a self‑certification cannot be obtained at onboarding in exceptional circumstances, the FI must apply pre‑existing account procedures until a valid self‑certification is received and validated.
Registration (Notification)
Cayman Islands FIs are required to file a registration form by 31 January following the calendar year in which they became an FI, with a one‑time deadline of 30 April 2026 for entities that first became FIs during 2025. This advances the current registration date from 30 April.
The information to be provided by a Cayman Islands FI has been clarified. It includes the FI’s name; any identifier issued by the General Registry, CIMA or other regulator; its CRS classification; the date on which it became an FI; and full details of the PPoC or another designated person for change submissions.
Any changes to a Cayman Islands FI’s registered information must be notified by submitting a change form on the DITC Portal within 30 days of the change.
Reporting
From 2027, Cayman Islands FIs must file both the CRS Return and the CRS Compliance Form by 30 June of the year following the reporting period (i.e., for the 2026 reporting year). These revised deadlines are earlier than the previous cut‑offs of 31 July for CRS Returns and 15 September for CRS Compliance Forms.
Each of the CRS Return and the CRS Compliance Form must now be accompanied by a declaration confirming that the information submitted is “adequate, accurate and current.”
Principal Point of Contact
The PPoC must be physically based in the Cayman Islands. This is a narrowing of the previous position, which permitted the PPoC to be located outside the jurisdiction. Transitional relief allows currently registered Cayman Islands FIs without a local PPoC to file a change form by 31 January 2027 appointing a Cayman Islands‑based PPoC.
Penalties and Enforcement
The revised penalty regime introduces certain fee caps, removes the accrual of interest, and updates the enforcement notice process.
By way of example, continuing penalties will be capped so that aggregate penalties are effectively limited to CI$50,000. No continuing penalty will accrue where a CI$50,000 primary penalty has been imposed, and once the combined total of primary and continuing penalties reaches CI$50,000, no further continuing penalties may be levied.
Digital Money and Crypto‑Assets
The amended Schedule updates and introduces CRS definitions to reflect developments in the digital asset ecosystem.
In particular, the term “Financial Assets” is expanded to encompass crypto‑assets.
Separately, the OECD’s Crypto‑Asset Reporting Framework (“CARF”) is being adopted in multiple jurisdictions, including the Cayman Islands. CARF is a separate automatic exchange of information regime focused on crypto‑asset intermediaries and transactions and should not be conflated with the CRS amendments addressed in this note. Depending on the nature of your activities, you may fall within the scope of both regimes.
Practical Takeaways and Timing
- Effective Date. CRS amendments take effect on 1 January 2026, with certain reporting and procedural elements applying from 2027.
- Registration. Registration is due by 31 January following the year an entity becomes an FI; a one‑off 30 April 2026 deadline applies for entities that became FIs in 2025. Change forms must be filed within 30 days of any change.
- Reporting Cycle. From the 2027 filing year, the CRS Return and CRS Compliance Form are both due by 30 June, each with a declaration.
- PPoC Location. The PPoC must be resident in the Cayman Islands. Where a non‑local PPoC is currently registered, a change form appointing a local PPoC must be filed by 31 January 2027.
- Penalties. No interest applies; continuing penalties are capped; an immediate Penalty Notice may issue for failure to file returns; and a 30‑day window is provided for representations.
- Digital Scope. Definitions are expanded to include electronic money, central bank digital currencies (CBDCs) and crypto‑assets, with additional reportable data points.
How We Can Assist
Conyers provides advisory support on CRS compliance and offers a suite of reporting services that can be tailored to your operating model. Please contact your usual Conyers representative for further guidance.