Common Reporting Standard (CRS / DAC2 / AEOI): Overview, Scope & Reporting Requirements

Overview

The Common Reporting Standard (CRS) is a global framework for the automatic exchange of financial account information between tax authorities. It was developed by the OECD to combat tax evasion and improve tax transparency worldwide.

Within the European Union, CRS is implemented through Directive on Administrative Cooperation (DAC2), making CRS reporting mandatory for EU financial institutions. Internationally, CRS operates under the Automatic Exchange of Information (AEOI) framework between participating jurisdictions.

CRS requires financial institutions to identify reportable account holders, collect prescribed data, and submit structured reports to local tax authorities for onward exchange with other jurisdictions.

Legal Context

CRS is developed and maintained by the Organisation for Economic Co-operation and Development (OECD).

In the European Union:

• CRS is implemented via DAC2

• Supervised by national tax authorities

• Supported by EU-wide coordination mechanisms

Outside the EU, CRS operates under bilateral and multilateral AEOI agreements between participating jurisdictions.

CRS is distinct from, but closely aligned with, other international tax transparency regimes such as FATCA.

Applicability

CRS applies to Reporting Financial Institutions, including:

• Banks and credit institutions

• Custodial institutions

• Investment entities

• Certain insurance companies

• Trusts and similar arrangements (where applicable)

Institutions must:

• Perform due diligence on account holders

• Identify tax residency

• Classify accounts as reportable or non-reportable

Applicability depends on:

• Entity type

• Jurisdiction

• Account characteristics

Obligations

CRS introduces obligations across four main areas:

• Due diligence on new and pre-existing accounts

• Account classification and tax residency determination

• Data collection and validation

• Annual reporting to tax authorities

These obligations are supported by detailed OECD guidance and local implementing rules issued by national tax authorities.

Reporting

CRS reporting requires financial institutions to submit annual reports containing:

• Account holder identification details

• Tax residence and Tax Identification Numbers (TINs)

• Account balances or values

• Income and proceeds information

Reports must be submitted in OECD-defined XML formats, following strict schemas and validation rules.

Reporting timelines and submission channels vary by jurisdiction, but data structures are globally standardised.

Challenges

Common CRS operational challenges include:

• Complex entity and account classification rules

• Incomplete or inconsistent client data

• Manual data consolidation from multiple systems

• XML schema validation errors

• Managing multi-jurisdictional submissions and deadlines

These challenges increase operational cost and regulatory risk, particularly for cross-border institutions.

REGREP Solution

REGREP supports CRS as a regulatory reporting infrastructure, enabling institutions to operationalise CRS and DAC2 reporting requirements at scale.

REGREP provides:

• Structured ingestion of CRS-relevant account and client data

• Data validation aligned with OECD XML schemas

• Automated generation of CRS-compliant XML reports

• Jurisdiction-aware reporting outputs

• Audit-ready data traceability

• API-first integration with core banking and client systems

REGREP supports the technical preparation and submission of CRS reports and does not replace due diligence processes, tax determination, or regulatory responsibility.

• Organisation for Economic Co-operation and Development (OECD)

Links are provided for reference purposes only. REGREP is not affiliated with or endorsed by any regulatory authority.

• FATCA Reporting

• CARF / DAC8

• Regulatory reporting infrastructure