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CRS v2 to v3 change explorer

The amended CRS is not a namespace bump. Seventeen changes sit between XML Schema 2.0 and 3.0, and only a handful of them reach any one institution. Pick your type and see which ones do — the fields they add, what they cost you in the data model, and what to do about each.

CRS XML Schema 3.0 · User Guide 4.0 · 17 changes · 8 institution types · field delta export · nothing stored

See the changes that reach you

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Answer for one legal entity. Where an entity does more than one thing — a bank that also custodies, a manager that also administers a trust — run it twice and take the union. Nothing here is stored or transmitted.

What this means: a change summary against the published OECD amended CRS package — the consolidated CRS text, the Schema 3.0 User Guide and the related commentary. It tells you which changes touch your institution type and what each one asks of the data. It does not tell you whether you are a Reporting Financial Institution, decide any account’s classification, or state your filing date. Domestic implementations add local fields, deadlines and validation rules of their own, and effective dates are set nationally. This is not tax advice.

Knowing the delta is not the same as producing a valid v3 file. The CRS module maps your data to Schema 3.0, applies the code lists and validates before submission — with a free tier to start.

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Shape of it

Four changes reach everyone. The rest depend on what you are

The universal changes are the reported fields. The expensive ones are the scope changes, and those land unevenly.

4 fields

Every reporter carries them

Account type, new versus preexisting, self-certification status, and controlling-person roles are now reported for everyone. Three of the four are already collected somewhere in most firms — as an operational flag, not as a reportable field.

E-money

A new population entirely

Qualifying specified electronic money products come into Depository Account scope. That makes CRS a first-time obligation for issuers who have never filed, rather than a migration.

Crypto

Indirect exposure stays in CRS

Derivatives referencing relevant crypto-assets, and Investment Entities that invest in them, sit inside CRS. Direct exchange and transfer activity goes to CARF. The two frameworks divide the same customer, not the same transaction.

Self-cert

The change with the longest tail

Reporting whether a valid self-certification was obtained turns a documentation gap into a visible field. Firms that have been carrying undocumented preexisting accounts find out at file level, not at audit.

Reviewed 25 August 2026 · source: OECD consolidated CRS text, Amended CRS XML Schema 3.0 and User Guide 4.0 (October 2024), and the related commentary · first exchanges under the amended CRS are expected to commence in 2027

Readiness

Nine things your extract has to be able to produce

Work down the list against the file you send today, not against the system you intend to build. Tick what your current extract already carries.

Have itData itemFeedsUsual failure

The checklist is scored in your browser and is not recorded. Items nine and two are the ones most often missing entirely rather than partially — a single residence field and a single date field cannot be patched, they have to be re-modelled.

Scope

What this explorer does

It sets the published amended CRS package against the legacy one and filters the result. It does not classify your entity or your accounts.

It doesFilter the delta by institution type

  • Lists the changes between CRS XML Schema 2.0 and 3.0 that reach the type you select.
  • Separates scope changes from new reported fields, due diligence and excluded accounts.
  • Names the schema element or data item each change lands on.
  • Marks which changes are determinate and which depend on the implementing jurisdiction.
  • Exports the filtered delta as CSV for a migration backlog.
  • Flags where a change makes CRS a first-time obligation rather than a migration.

It does notDecide your status or your dates

  • Determine whether the entity is a Reporting Financial Institution — use the entity classification tool.
  • Classify individual accounts, products or e-money instruments.
  • State when the amended CRS takes effect for you; effective dates are set domestically.
  • Cover local filing fields, portals or validation rules added by a Member State or jurisdiction.
  • Validate, convert or generate a CRS file.
  • Constitute tax advice.

Not sure the entity is a Reporting FI at all?

The classification tests come first, and the amended definitions widened two of them. Settle status before you scope the migration.

Open the classification tool

Nothing you select here leaves your browser

The filter, the checklist and the CSV are all built in your own browser. No selection is sent to REGREP, written to a log, saved to a database, or passed to any analytics tool.

Reload the page and everything is gone. Mapping, validation and file generation happen inside your account, under our data processing agreement.

Questions

About the move to amended CRS

Is “CRS v3” the same thing as the amended CRS?

Not quite, and the distinction matters when you read guidance. The amended CRS is the substantive standard approved in 2023. Version 3.0 is the XML schema that carries it, published in October 2024 alongside User Guide 4.0. People say “v3” because the schema version is the visible artefact, but the obligations come from the amended standard, not from the file format.

When does this actually start?

First exchanges under the amended CRS are expected to commence in 2027. The date that governs you, though, is domestic: each implementing jurisdiction sets when the amended rules apply to reporting institutions and from which reporting period. Confirm it with your competent authority rather than working from the exchange date.

We are an EMI and have never filed CRS. Does this reach us?

Possibly, and it is the single largest change in the amended standard. Qualifying specified electronic money products are brought within the Depository Institution and Depository Account concepts, which can make an issuer a Reporting Financial Institution for the first time. The product has to meet the definition — the label on it does not decide the question — and there is a new excluded-account category for low-value e-money that may take some balances back out again.

Does the amended CRS make us report crypto transactions?

No. CRS reports financial accounts and covered financial interests. What the amendments add is indirect exposure: derivatives referencing relevant crypto-assets, and Investment Entities that invest in them. Direct exchange and transfer activity for customers is CARF territory, under a separate framework and a separate schema.

What is the joint account field for?

The amended CRS reports whether an account is jointly held and how many holders it has. It is a small element with an outsized migration cost, because legacy extracts commonly hold one row per holder with no joint indicator and no count — so the information has to be reconstructed rather than mapped.

If we report gross proceeds under CARF, do we report them again under CRS?

Potentially not. The frameworks include an interaction rule allowing CRS gross-proceeds reporting to be switched off where the same gross proceeds are reported under CARF. It is optional and depends on the implementing jurisdiction, and it only works if the two engines can see each other — which is why an anti-duplication check belongs in the shared layer rather than in either module.

Do you store what I select?

No. The filter, the checklist and the export are all built in your browser and discarded when you close or reload the page.

The delta is a list. The migration is a data model.

Create a free account and map an extract to Schema 3.0 against real validation, instead of against a checklist.

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