CRS 2.0: Every Change to the Common Reporting Standard

CRS 2.0 is the biggest upgrade to the Common Reporting Standard since banks started swapping data, and it’s already running. Financial institutions began applying the amended rules on 1 January 2026, and the first data collected under them gets exchanged in 2027. It reaches e-money, central bank digital currencies and indirect crypto, and it tells banks far more about how you hold your money.

Most coverage fixes on crypto. The change that hits our readers hardest is quieter: people with more than one tax residence can no longer pick one. If you live between two countries, both now hear about your accounts. This guide goes through every change, what it means in practice, and what still works legally under the new rules.

What Is CRS 2.0?

CRS 2.0 is the nickname for the amended Common Reporting Standard, the OECD rulebook under which banks report foreign tax residents’ accounts. The OECD adopted the amendments in August 2022. They extend reporting to e-money, central bank digital currencies and indirect crypto investments. They also tighten due diligence and reporting, and carve out genuine non-profits.

The OECD’s consolidated text, published in 2025, folds the changes into a single version of the standard. Each participating country then writes them into its own law. If you’re new to the system itself, start with our main guide to the Common Reporting Standard, which explains how the original rules work.

Despite the name, the machinery stays the same. The banks, tax offices and annual exchanges don’t change. The net gets wider and every report gets more detailed.

When Does CRS 2.0 Start?

CRS 2.0 applies from 1 January 2026 in the EU, the UK and most other participating jurisdictions. Banks collect data under the new rules during 2026. The first exchanges of that data happen in 2027. Accounts opened on or after 1 January 2026 are treated as new accounts under the amended rules.

The OECD’s 2025 peer review found most jurisdictions planning their first amended-CRS exchanges in 2027. A few are slower, so check the country where your account sits.

CRS 2.0 Changes at a Glance

The main CRS 2.0 changes fall into three groups. Scope widens to e-money, central bank digital currencies and crypto held through derivatives or funds. Treaty tie-breakers end for people with several tax residences. And new fields cover account type, joint holders, new or pre-existing status, controlling persons’ roles and self-certification status.

HMRC’s International Exchange of Information Manual was updated in November 2025 to cover each of these for the UK. Its thresholds page confirms the USD 10,000 e-money exclusion.

CRS 2.0 and Dual Residence: The Tie-Breaker Is Gone

Account holders with tax residence in more than one country can no longer use treaty tie-breakers to name just one. They must declare every jurisdiction of tax residence on the self-certification, and the bank reports the account to all of them. Banks don’t analyse tie-breakers themselves.

This is the change that matters most to people living international lives. Under the old rules, a dual resident could often lean on the tax treaty and end up reported to one country. From 2026 both countries get the data, and each can decide for itself whether you owe it anything.

The UK guidance adds one mercy. Banks don’t have to redo due diligence completed before 1 January 2026 unless your circumstances change. A new account, a new address or a fresh form, though, and the new rule applies.

We’ve had clients split their year between Lisbon and London who assumed the treaty would keep one tax office in the dark. That assumption ended this year. The sensible response is to settle your tax residence cleanly in one place, ideally a country that doesn’t tax foreign income, and document it with a tax residency certificate.

CRS 2.0 E-Money and Digital Currencies

The amended standard treats e-money and central bank digital currencies as depository accounts. Firms holding specified electronic money products or CBDCs for customers count as depository institutions and report like banks. E-money accounts are excluded only if the rolling 90-day average balance stays at or below USD 10,000.

That closes the old gap around prepaid cards, e-wallets and payment apps holding meaningful balances. Small everyday wallets stay out. Anything you’d actually use to park money doesn’t.

CRS 2.0 and Crypto

CRS 2.0 covers crypto indirectly. Crypto derivatives now count as financial assets. Funds and other investment entities that invest in crypto are in scope. Custodians must also report income from crypto they hold for you. Direct crypto holdings at exchanges and brokers are reported under a separate system, the Crypto-Asset Reporting Framework (CARF).

The two were designed together and switched on at the same time. CARF makes crypto exchanges and brokers report their customers’ transactions. By the OECD’s 2025 review, 76 jurisdictions had committed to it, most exchanging from 2027. In the EU it runs through DAC8, which applies from 1 January 2026 and covers stablecoins, e-money tokens and some NFTs. Our guide to CARF crypto reporting covers that side in detail.

New CRS 2.0 Reporting Fields

CRS 2.0 adds six new fields to every report. They show whether the bank holds a valid self-certification, the role of each controlling person and of each person in a trust, and whether the account is joint. The account type and whether it’s new or pre-existing are reported too.

Two of those deserve attention. Reporting whether a valid self-certification exists tells your tax office when a bank couldn’t pin you down, which is itself a flag. And reporting the role of each person in a trust means a protector or settlor is now labelled as such. Our guide to CRS reporting for trusts explains how that plays out.

Banks also have to make reasonable efforts to collect missing tax numbers and dates of birth when they update older accounts under their anti-money-laundering checks. Expect fresh paperwork on accounts you’ve held for years.

What CRS 2.0 Doesn’t Change

CRS 2.0 doesn’t change the basic trigger, which is still tax residence. Citizenship still doesn’t matter, and the United States still isn’t a participant. Assets that aren’t financial accounts, such as directly owned property, still sit outside the reporting. The same legal planning principles apply, with less room for error.

Tax residence still decides everything. A second citizenship remains a powerful insurance policy, but it doesn’t change where your data goes unless your tax residence moves too. The OECD flagged 21 jurisdictions’ investment migration schemes as high risk for CRS back in 2018, and banks still ask more questions of anyone using them.

The United States is still outside. A non-American’s account at a US bank isn’t reported under the amended rules either. Our guides to the US bank account for non-residents and the full list of non-CRS countries cover the options. Americans still face FATCA.

Some gaps remain. A handful of structural gaps survived the amendments. Our breakdown of CRS loopholes covers which ones still hold up under the new rules.

How to Prepare for CRS 2.0

Preparing for CRS 2.0 starts with a clear tax residence. Answer self-certifications completely and truthfully, and review any structure built around the old rules. Anyone who relied on a treaty tie-breaker, a small e-money balance or an indirect crypto holding to stay unreported should assume that position has ended.

Start with residence. If you have more than one, both countries now see your accounts, so the clean answer is one well-chosen tax residency country. Then look at structures: trusts and investment companies will report more detail about who plays which role. Finally, review crypto held through funds or derivatives, which is now in scope, and direct holdings at exchanges, which CARF reports.

Common Mistakes With CRS 2.0

Thinking CRS 2.0 is about crypto only. The dual-residence change and the new data fields affect far more people.

Relying on a treaty tie-breaker. It no longer narrows reporting to one country.

Leaving self-certifications incomplete. Whether you gave a valid one is now reported.

Parking money in e-money accounts. Above a USD 10,000 average balance, they’re reported like bank accounts.

Assuming old accounts are untouched. Any change in circumstances brings them under the new rules, and banks are chasing missing tax numbers.

Treating a second passport as a shield. Reporting still follows tax residence.

Frequently Asked Questions About CRS 2.0

CRS 2.0 Raised the Stakes

The upgrade didn’t invent a new system. It took the existing one and closed the gaps people relied on: the second tax residence nobody heard about, the e-wallet balance, the crypto fund. What’s left is a cleaner question than ever. Where are you tax resident, and is that a country that leaves your foreign income alone?

Read the main Common Reporting Standard guide for the full picture, then the legal ways to avoid CRS that still work.