CRS controlling persons identifier
Once an entity is a Passive NFE, the question stops being about the entity and becomes about the people behind it. The answer is not the same for a company as for a trust — a company can have none, while a trust always has several, whether or not any of them controls anything. Work through the roles and see who has to be identified.
CRS Section VIII D(6) · FATF Recommendation 10 · company, partnership and trust routes · look-through · nothing stored
Identify controlling persons for one entity
Runs in your browser · nothing uploadedAnswer for a single account holder. Which questions apply depends entirely on the first answer, so start there — the company route runs a cascade and can end with nobody, while the trust route is a fixed list of roles.
Step 1 — What kind of entity or arrangement is it?
Section VIII D(6)The definition is deliberately different for each. Choose the legal form of the account holder itself, not of its owners.
Step 2 — The ownership and control cascade
FATF Rec. 10, interpretive noteThree tiers, applied in order. You only move down a tier when the tier above yields nobody — and the last tier always yields somebody.
Step 2 — Partners and executive control
Section VIII D(6)A partnership is not run through the ownership cascade in the same way. Guidance in a number of jurisdictions treats the partners themselves as the starting point.
Step 2 — Which roles exist?
Commentary on Section VIII, paras 132–137Under the CRS the settlor, the trustees, the protector and the beneficiaries are always controlling persons, whether or not any of them exercises control over the trust. This step is an inventory of roles, not a test of influence.
Identifying them is the easy half. The CRS and FATCA modules hold controlling person records against each account, carry residences and TINs through validation, and produce jurisdiction-ready XML — with a free tier to start.
Create free account →One term, two completely different mechanics
Section VIII D(6) defines controlling persons as the natural persons who exercise control over an entity, and states that the term is to be interpreted consistently with the FATF Recommendations. What that produces depends on the legal form.
A cascade that can end with nobody
Ownership first, then control by other means, then the senior managing official. Each tier is only reached when the one above yields no natural person — so a widely held company may have no controlling person by ownership at all, and still produce one at the last tier.
A fixed list, regardless of control
Settlor, trustees, protector if there is one, and the beneficiaries or classes of beneficiaries are always controlling persons. Whether any of them actually controls the trust is irrelevant to the question. Anyone else with ultimate effective control is added to that list, not substituted for it.
Equivalent positions
For a legal arrangement that is not a trust — a foundation, a fiducie, an Anstalt — the controlling persons are the people in equivalent or similar positions to those in a trust. The mapping is a matter of the arrangement's own constitution.
Look through, don't stop
A controlling person is always a natural person. Where a settlor, partner or qualifying owner is itself an entity, the chain is followed up through it. An entity name in a controlling person field is a defect, not an answer.
Rules reviewed 21 August 2026 · CRS Section VIII D(6) · Commentary on Section VIII, paras 132–137 · FATF Recommendation 10 and its interpretive note (as adopted February 2012)
What this tool does
It turns a legal form into a list of roles to document. It cannot tell you whether any of those people is reportable.
It doesEnumerate the roles
- Applies the three-tier cascade for companies, in order, and shows which tier produced the answer.
- Applies the fixed role list for trusts, including the roles that are controlling persons whether or not they exercise control.
- Flags every point at which an entity in the structure has to be looked through to reach a natural person.
- Notes where a lower domestic ownership threshold changes the population.
- Separates the question of who is a controlling person from the question of what gets reported for a discretionary beneficiary.
- Marks unresolved answers rather than guessing past them.
It does notDecide reportability
- Determine tax residence, which is what makes a controlling person reportable at all.
- Decide whether the entity is a Passive NFE. That question comes first, and is a different test.
- Apply your jurisdiction's AML/KYC procedures, which are the actual mechanism for identification.
- Handle FATCA, which shares the wording but not all of the interpretation.
- Tell you what to do where a role is vacant, contested or held by a person who will not self-certify.
- Produce anything you can file. It is a checklist, not a return.
This question only arises for a Passive NFE
Controlling persons are looked through to when the account holder is a Passive NFE, or an investment entity in a non-participating jurisdiction managed by another financial institution. If you have not settled the classification, settle that first — the answer may remove the question entirely.
Nothing you enter here leaves your browser
Every answer is evaluated on your own machine. Nothing is sent to REGREP, written to a log, saved to a database, or passed to any analytics tool.
That is deliberate. The structure of a client's trust is not something we want to hold.
About controlling persons
Can an entity have no controlling persons?
By ownership, yes — a widely held company may have no natural person at or above the threshold, and no one exercising control by other means. But the cascade does not stop there. The final tier identifies the natural person holding the position of senior managing official, so the practical answer for a company is almost always somebody. For a trust the question does not arise: the roles exist by definition.
Is a beneficiary a controlling person even if the trustee ignores them?
Yes. Under the CRS the settlor, trustees, protector and beneficiaries or classes of beneficiaries are always treated as controlling persons of a trust, regardless of whether any of them exercises control over its activities. That is a deliberate departure from the ordinary meaning of control, and it is the point most often missed on a self-certification.
Our jurisdiction uses a threshold below 25%. Which applies?
The lower one. The definition is applied through domestic AML/KYC procedures, so where a jurisdiction's implementation of the FATF Recommendations sets a threshold below 25% for identifying controlling ownership interests, the financial institution subject to those procedures identifies on that lower basis. The effect is a larger population of controlling persons, not a different test.
What if the settlor is a company?
Then its own controlling persons have to be identified and, where required, reported as controlling persons of the trust. The same follows for a corporate trustee or a corporate partner. A controlling person is by definition a natural person, so an entity name in that field means the chain has not been followed to the end.
When does a discretionary beneficiary get reported?
Generally in a reporting period in which a distribution is made to them. They are a controlling person of the trust throughout, but the reporting consequence attaches to the distribution. Some authorities read the circumstances in which a discretionary beneficiary is treated as having received a distribution broadly, so check your own jurisdiction's guidance rather than assuming the narrow reading.
Does identifying someone mean reporting them?
No. Identification and reporting are separate steps. A controlling person is reported where they are resident in a reportable jurisdiction; one resident in the same jurisdiction as the reporting financial institution is identified and documented but not exchanged. That is why residence and TIN collection matter as much as the role inventory.
A role inventory is the start of due diligence, not the end.
Create a free account and hold controlling person records, residences and TINs against each account, validated before anything is submitted.
No card required · free tier on core modules · nothing stored from this tool