Amendments to the Cayman Islands Common Reporting Standard Regulations

From 1 January 2026, updates to the Common Reporting Standard regime in the Cayman Islands will take effect with certain provisions applying in 2027.

This is following the implementation of both:

• the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations (the CRS Amendment Regulations), which amend the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations (2021 Revision)
• the Tax Information Authority (International Tax Compliance) (Crypto-Asset Reporting Framework) Regulations, 2025 (the CARF Regulations)

The CRS Amendment Regulations and CARF Regulations:

• introduce a requirement for a Cayman Financial Institution to appoint a person in the Cayman Islands as its principal point of contact (PPoC)
• introduce new registration, reporting and compliance deadlines
• tighten penalty and enforcement mechanics
• extends the scope of Common Reporting Standard (CRS) to include certain categories of digital assets
• align Cayman’s regime with the OECD’s updated CRS and Crypto-Asset Reporting Framework (CARF) and impose additional obligations on entities dealing with crypto-assets

These amendments have been introduced to align the Cayman Islands CRS regime with amendments to the CRS adopted by the OECD in August 2022 (CRS 2.0).

Key actions for Cayman Islands financial institutions (FIs)

• Consider if the FI will be required to appoint a new PPoC in the Cayman Islands
• Review CRS policies and procedures to consider if any updates are required
• Review self-certifications documents for compliance with the new requirements

Further information on the key changes made by the CRS Amendment Regulations is set out below.  

Ogier can assist in reviewing and implementing any changes required in relation to the CRS Amendment Regulations and CARF Regulations. Reach out to your usual Ogier contact or the team below.

Location of the Principal Point of Contact

The amendments require that the Principal Point of Contact (PPoC) must be located in the Cayman Islands. FIs registered with the Tax Information Authority before the commencement of the CRS Amendment Regulations (that is, FIs registered by 31 December 2025) that do not yet have a PPoC in the Cayman Islands have a transition period until 1 January 2027 to both: 

• appoint a person in the Cayman Islands as PPoC  
• notify the DITC via a change notice within 30 days of making the appointment

Based on existing guidance, failure to provide details of the PPoC in the Cayman Islands may result in administrative penalties of US$12,200 (CI$10,000).    

Ogier Global's dedicated FATCA / CRS Compliance team can provide a Cayman resident PPoC if required, please reach out to your usual Ogier contact if you wish to discuss this service.

Earlier reporting deadlines

From the 2026 reporting year, the CRS Return filing deadline moves from 31 July 2027 to 30 June 2027.

The CRS Compliance Form filing deadline will also be aligned to 30 June 2027 (previously 15 September).

Therefore for the 2026 reporting period both the CRS Return and the CRS Compliance Form will be due by 30 June 2027.

Updated registration deadlines 

New FIs commencing activities from 1 January 2026 must complete their registration on the DITC portal by 31 January 2027.

Transitional rules for FIs that commenced activities during 2025

Transitional rules are in place for FIs that commenced activities during 2025 which can continue to register by 30 April 2026, submit their CRS Returns by 31 July 2026 and submit their CRS Compliance Forms by 15 September 2026 in line with existing arrangements. 

Ongoing obligation to keep registration details current

The amendments formalise a continuing obligation to keep the DITC portal information up to date. Where any information in a FI’s registration changes (for example, FI classification, contact details, PPoC, Authorising Person, service provider), the FI must file a change notice within 30 days of the change occurring. Failure to do so may result in administrative penalties of US$12,200 (CI$10,000). 

Due diligence – effect of the CRS Amendment Regulations

Under the existing regime, FIs were already required to classify accounts as "pre‑existing" or "new", obtain self‑certifications to establish tax residence, identify Controlling Persons for certain entities and retain evidence supporting their classifications, in line with Sections II–VII of the CRS Schedule. 

The CRS Amendment Regulations do not change those core due diligence mechanics. However, they do expand the information that must ultimately be reported and introduce a prescribed form of CRS self‑certification. In particular, reporting FIs will now be required to report additional information including:

• whether an account is a new account or pre‑existing account
• whether an account is a joint account
• the role by virtue of which each Controlling Person is a Controlling Person of the relevant entity 
  
  

Penalty and enforcement changes

The amendments significantly tighten enforcement measures. An FI  that fails to file a CRS return and / or CRS Compliance Form by the statutory deadlines may be subject to immediate penalties of up to US$12,000 (CI$10,000) per breach in accordance with existing guidance.  

Penalties may now be imposed immediately, without provision of a prior "breach notice".

Expansion of “Financial Assets” to cover crypto and e‑money

The CRS Amendment Regulations make updates to reflect the OECD’s 2023 work on digital assets.

New concepts of Crypto‑Asset, Relevant Crypto‑Asset, Specified Electronic Money Product, Central Bank Digital Currency and Fiat Currency have been introduced alongside Financial Assets in a number of terms, with the effect that Cayman Islands entities carrying out operations involving digital assets will need to consider if they have new or enhanced CRS obligations in relation to those activities.

Implementation timetable

Source: ditc.ky - The Amended Common Reporting Standard for Automatic Exchange of Financial Account Information in Tax Matters – Quick Guide

To support users through the transition phase, quick guides  are also available on the DITC website with further guidelines and resources to become available in 2026.

FATCA

No changes have been made to FATCA registration and reporting deadlines (although Cayman Reporting Financial Institutions may wish to align their 2027 reporting under FATCA and CRS). 

How Ogier can help

If you would like to discuss how the Cayman CRS amendments apply to your particular structure, please reach out to your usual Ogier contact or the team below.