FATCA reporting requirements
The framework page: who is in scope, what is submitted and to whom.
Read the requirements →
Resource center · Tax Transparency
FATCA reporting for non-US financial institutions.
FATCA looks like CRS and behaves differently. This record covers the parts that catch out institutions filing both: registration identifiers, the two intergovernmental models, pooled reporting and the correction mechanics of the FATCA XML schema.
Who has to file
FATCA obliges foreign financial institutions to identify accounts held by specified US persons, and by certain non-US entities with substantial US owners, and to report them. The reporting obligation attaches to the institution, not to the account holder, and it runs whether or not any withholding ever occurs. Certain non-financial foreign entities also report where they have substantial US owners.
Registration comes first. An institution registers with the Internal Revenue Service and receives a global intermediary identification number, which then appears on the published foreign financial institution list and inside every report it files. Some filers — United States withholding agents, territory financial institutions, third-party preparers and software vendors — do not hold such a number and instead obtain a FATCA identification number in order to enrol in and transmit through the International Data Exchange Service.
Model 1 and Model 2
The intergovernmental agreement in force where the institution is resident decides the whole operating model, and it is worth stating explicitly because it changes who the counterparty is.
| Model 1 | Model 2 | |
|---|---|---|
| Files to | The local tax authority | The Internal Revenue Service directly |
| Onward exchange | Authority to authority, on an agreed cycle | None — the report has already arrived |
| Format control | National portal rules layered over the schema | The schema and transmission rules as published |
| Non-consenting accounts | Reported in the normal population | Aggregate pooled reporting, with group requests following |
An institution operating in several jurisdictions can therefore hold both models at once, with different portals, different validation layers and different dates against the same underlying data.
What the report contains
The reported dataset is the content of Form 8966: the reporting institution and any sponsor or intermediary, the account holder’s name, address and United States taxpayer identification number, the account number, the account balance or value, and payments made or credited during the year. Where an account holder is an entity, owner information is reported separately for each substantial US owner that is a specified US person.
Pooled reporting sits alongside the account-level population and carries aggregate figures for defined categories — recalcitrant account holders with and without US indicia, those who are US persons, and non-participating financial institutions. A pooled report containing no accounts should not be included at all; an empty pool causes the file to fail.
The XML schema and its identifiers
Reporting uses the FATCA XML schema. Version 2.0 replaced version 1.1 and is generally not backward compatible: files built to the earlier version will not validate. As with CRS, the mechanics turn on identifiers.
MessageRefIdidentifies the transmission and must be unique for the sender.DocRefIdidentifies each correctable record — an account report, a pooled report, or the reporting institution, sponsor or intermediary element — and must be unique across every filer and every period. The Internal Revenue Service publishes a required standardised format for it.CorrMessageRefIdandCorrDocRefIdcarry the references of the record being changed, so every update is traceable to the report it replaces.
Prohibited characters in text content will cause the packet to be rejected as not well-formed, so anything carried from a source system needs encoding before it reaches the file. Metadata accompanying the packet is prepared to its own schema and is never encrypted.
Where FATCA and CRS diverge
Institutions that run both frameworks from one data model save real effort, but four differences have to be modelled explicitly rather than assumed away.
| Dimension | FATCA | CRS / DAC2 |
|---|---|---|
| Test | United States citizenship or tax residence — citizenship counts wherever the person lives | Tax residence only |
| Counterparties | One — the United States | Every reportable jurisdiction the institution has exchange relationships with |
| Thresholds | Account thresholds and elections apply to parts of the population | No general de minimis for individual accounts |
| Non-consenting holders | Pooled reporting under Model 2; withholding consequences elsewhere | No pooling concept |
Corrections, amendments and voids
Version 2.0 of the schema accepts record-level updates rather than whole-file replacement. A record consists of the account or pooled report together with the reporting institution or reporting group element, including any sponsor or intermediary. Correctable data types carry a document specification block whose identifiers let a correction, an amendment or a void be tied to a specific earlier record. Files originally created under version 1.1 can still be corrected, amended or voided using version 2.0.
The distinction matters operationally: a correction repairs data the receiving system flagged, an amendment changes data the filer discovered was wrong, and a void withdraws a record that should never have been filed. Sending a fresh file with new identifiers achieves none of the three.
Official sources
Primary instruments only. Each is named in full so the reference remains traceable even if a link moves.
- Internal Revenue Service — FATCA XML schemas and business rules for Form 8966IRS · schema versions, validation guidance and sample packets
- Internal Revenue Service — FATCA XML reporting schema: correcting, amending and voiding recordsIRS · record-level update mechanics and document specification identifiers
- Internal Revenue Service — About Form 8966, FATCA ReportIRS · the reported dataset and its instructions
- Internal Revenue Code, Chapter 4, sections 1471 to 1474, and the applicable intergovernmental agreementUnited States statute · the obligation itself · consult the agreement for your jurisdiction
REGREP is an independent software provider. This record explains a reporting framework in plain language and is not legal, tax or regulatory advice. Confirm scope, thresholds and submission dates with your competent authority before you file.
Keep reading
More on this framework, and the module that produces the filing.
Reporting to the United States under FATCA
What changes when the counterparty is a single jurisdiction.
Read use case →CRS / DAC2 reporting walkthrough
The companion framework, end to end, for institutions running both.
Read the guide →One dataset, two frameworks.
Map your account data once and produce validated FATCA and CRS files from the same source. Start with a free test report.