CRS 2.0 and CARF: The Latest Updates

By Claire Terry, Global Head of Transparency

Following the OECD's first comprehensive review of the Common Reporting Standard (CRS), participating jurisdictions are now progressing towards the implementation of CRS 2.0 and the Crypto-Asset Reporting Framework (CARF).

These developments represent a significant shift in global tax transparency, expanding the scope of reportable financial accounts and digital assets. They also strengthen due diligence requirements and introduce updated reporting formats through XML Schema v3.0.

What is changing under CRS 2.0 and CARF?

CRS 2.0 builds on the existing framework and introduces several key changes:

Updated data collection and reporting standards
The introduction of XML Schema v3.0, requiring system and reporting updates
Enhanced due diligence requirements for identifying reportable persons
An expanded scope of reportable assets, including certain crypto-assets under CARF

CARF Global Commitments tracker: https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/commitments-carf.pdf

Together, these updates aim to close gaps in transparency. They will also improve consistency across jurisdictions as financial products evolve.

Jurisdictional Rollout

Implementation timelines vary across jurisdictions. Guidance is also being released at different stages.

Below is a summary of developments across Suntera's operating jurisdictions.

BAHAMAS

Legislative position	Remains a participating jurisdiction. However, there is no formal confirmation of full CRS 2.0 legislation yet, but have made some amendments.
Effective date	Expected in 2026
First reporting	Likely from 2027 onwards
Practical notes	Implementation is expected but progressing slightly slower
Relevant links	https://taxreporting.finance.gov.bs/legal/legislation/

CAYMAN ISLANDS

Legislative position	CRS 2.0 is fully enacted through Amendment Regulations 2025.
Effective date	1 January 2026
First reporting	2027
Practical notes	Aligned. Detailed operational changes have been provided, including deadlines, PPoC and crypto scope.
Relevant links	https://www.ditc.ky/wp-content/uploads/Amended_CRS_Quick_Guide.pdf

GUERNSEY

Legislative position	CRS 2.0 is fully enacted through Amendment Regulations 2025.
Effective date	1 January 2026
First reporting	2027
Practical notes	Aligned. Strong enforcement focus, with new penalties and expanded reporting fields.
Relevant links	https://www.gov.gg/CHttpHandler.ashx?id=196874&p=0

HONG KONG

Legislative position	Currently in consultation and policy development phase.
Effective date	Targeted for 2026 (not finalised)
First reporting	Likely between 2027 and 2028
Practical notes	Work in progress. As of July 2026, the Inland Revenue (Amendment) (Crypto-Asset Reporting Framework and Amended Common Reporting Standard) Bill 2026 has not yet been enacted. It is currently undergoing the legislative scrutiny process in Hong Kong. The key current details and next steps regarding the bill: Legislative Progress: The bill was gazetted on May 22, 2026, and officially introduced into the Legislative Council for its first reading on June 3, 2026. Proposed Implementation Timeline: Once passed by the Legislative Council, the amendments are scheduled to take effect on a phased timeline: Crypto-Asset Reporting Framework (CARF): Effective January 1, 2027. Amended Common Reporting Standard (CRS): Effective January 1, 2028. Bill Purpose: The bill aims to amend the Inland Revenue Ordinance to implement international tax transparency standards set by the OECD, requiring reporting crypto-asset service providers to collect and automatically exchange tax information.
Relevant links	https://www.ird.gov.hk/eng/tax/aeoi/crs_bill_2026.htm

ISLE OF MAN

Legislative position	CRS 2.0 is fully enacted. Regulations were approved in 2025 by Tynwald, and the CRS MCAA Addendum has been signed.
Effective date	1 January 2026
First reporting	2027 (for 2026 data)
Practical notes	Aligned. Comprehensive legislative updates are in place, including mandatory XML Schema v3.0.
Relevant links	Industry Advisory 2025 - Amended CRS Income Tax (Common Reporting Standard) Regulations 2025 https://www.gov.im/categories/tax-vat-and-your-money/income-tax-and-national-insurance/international-agreements/fatca-and-common-reporting-standard/crs-guidance/

JERSEY

Legislative position	CRS 2.0 has been implemented through both legislative updates and guidance. The CRS Addendum has been signed.
Effective date	1 January 2026
First reporting	2027
Practical notes	Aligned early adopter. Detailed guidance already incorporates CRS 2.0 requirements.
Relevant links	Automatic exchange of tax information: the Common Reporting Standard (CRS) https://www.gov.je/TaxesMoney/InternationalTaxAgreements/IGAs/pages/commonreportingstandard.aspx#anchor-0

SINGAPORE

Legislative position	Preparing for CRS 2.0. Focus is currently on adopting XML Schema v3.0.
Effective date	Deferred - 2027 likely
First reporting	2028
Practical notes	Delayed adopter. The schema update from January 2027 signals a later rollout.
Relevant links	CRS Overview and Latest Developments https://www.iras.gov.sg/taxes/international-tax/common-reporting-standard-(crs)/crs-overview-and-latest-developments

UNITED KINGDOM

Legislative position	Aligned both policy and enforcement with CRS 2.0. The CRS Addendum has been signed.
Effective date	1 January 2026
First reporting	2027
Practical notes	Strong focus on enforcement. Emphasis on audit activity, penalties and operational readiness rather than new standalone regulation.
Relevant links	https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/updates https://www.legislation.gov.uk/uksi/2025/744/made#f00003 https://www.legislation.gov.uk/uksi/2025/740/made

What This Means For Your Organisation

The transition to CRS 2.0 and CARF is more than a regulatory update. It represents a fundamental shift in how financial information is collected, verified and reported.

Key areas likely to be impacted include:

Onboarding and documentation - Enhanced due diligence requirements mean firms may need to collect more client information. This is particularly relevant where crypto-assets or complex structures are involved.
Ongoing due diligence - Existing client records may need to be reviewed.
Reporting systems and processes - The introduction of XML Schema v3.0 will require technical updates.
Cross-jurisdictional consistency - Implementation timelines are not aligned globally. Organisations operating in multiple jurisdictions will need to manage various compliance regimes at the same time.

How Suntera Can Support You

Suntera is actively monitoring developments across all jurisdictions. Our teams work closely with regulators and industry bodies, ensuring a proactive and coordinated approach. Our focus is to ensure:

Compliance frameworks remain aligned with evolving CRS 2.0 and CARF requirements
Reporting processes are updated in line with new technical standards
Clients receive clear and consistent guidance across all locations

Learn More

CRS 2.0 and CARF will continue to evolve as further guidance is released.

Suntera will continue to monitor developments and provide updates. Our aim is to ensure you remain compliant and well prepared.

If you would like to learn more about how these changes may impact your structures or reporting requirements, please get in touch with our Global Head of Transparency, Claire Terry.

About Claire

Claire has been with the organisation since 2014 and as Global Head of Transparency, she oversees the reporting and automatic information exchange compliance functions in all of our operating jurisdictions.

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