08/10/2024

CRS #17 New XML Schema and Guidande for CRS reporting

The OECD recently published new CRS reporting requirements guidelines.

We are publishing these new guidelines but do not yet know when they will come into force in Monaco. However, based on the information we have, they will probably be effective in 2026 for 2025 reporting.

These new requirements will have a direct impact on financial institutions, which will have to adapt their reporting tools to comply with the changes. The aim of this post is to inform you in advance so that you can anticipate potential changes to your CRS reporting tools.

For you, we have highlighted the changes between the old guide and the new one:

Addition of a code to identify “Specified Electronic Money Product” account numbers. Possible values are as follows:

  • OECD601 = IBAN International Bank Account Number (follows a known structure)
  • OECD602 = OBAN Other Bank Account Number
  • OECD603 = ISIN International Securities Information Number (follows a known structure)
  • OECD604 = OSIN Other Securities Information Number
  • OECD605 = Other Any other type of account numbe

In the case of an investment entity being a legal construct such as a Trust, Foundation, etc., the account holder’s role in this entity must now be declared according to the following codes:

  • CRS401 = EIH of legal arrangement – trust – settlor
  • CRS402 = EIH of legal arrangement – trust – trustee
  • CRS403 = EIH of legal arrangement – trust – protector
  • CRS404 = EIH of legal arrangement – trust – beneficiary
  • CRS405 = EIH of legal arrangement – trust – other
  • CRS406 = EIH of legal arrangement – other – settlor-equivalent
  • CRS407 = EIH of legal arrangement – other – trustee-equivalent
  • CRS408 = EIH of legal arrangement – other – protector-equivalent
  • CRS409 = EIH of legal arrangement – other – beneficiary-equivalent
  • CRS410 = EIH of legal arrangement – other – other-equivalent

Moreover, a new validation code verifies whether the account holder has provided a valid CRS self-certification:

  • CRS901 = true
  • CRS902 = false
  • CRS900 = not reported (this value is available as a transitional measure, in order to facilitate interoperability with the previous version of the schema, particularly in respect of corrections)

First of all, the old specifications mentioned that the Controlling Person (CP) role was to be declared “when available” by the reporting entity. The new specifications seem to remove this notion and make the declaration of the CP role systematic.

Secondly, a new temporary code has been created to allow banks time to make corrections following the change in specifications (the same transitory code is planned for new information to be declared, notably for the verification code for valid CRS self-certifications):

  • CRS800 = not reported (this value is available as a transitional measure, in order to facilitate interoperability with the previous version of the schema, particularly in respect of corrections)

Finally, as for the account holder, there is now a new validation code to check whether CPs have provided a valid CRS self-certification:

  • CRS1001 = true
  • CRS 1000 = not reported (this value is available as a transitional measure, in order to facilitate interoperability with the previous version of the schema, including in respect of corrections)
  • CRS1002 = false

The account type held by the holder must now be declared as follows:

  • CRS1101 = Depository Account
  • CRS1102 = Custodial Account
  • CRS1103 = Cash Value Insurance Contract or Annuity Contract
  • CRS1104 = Debt or Equity Interest in Investment Entity
  • CRS1100 = not reported (this value is available as a transitional measure, in order to facilitate interoperability with the previous version of the schema, particularly in respect of corrections)

A new code set declares whether the account is a pre-existing account or a new account:

  • CRS1201 = New Account
  • CRS1202 = Preexisting Account
  • CRS1200 = not reported (this value is available as a transitional measure, in order to facilitate interoperability with the previous version of the schema, particularly in respect of corrections)

These two elements are used to declare whether the account declared is a joint account or not and, if so, to identify the account holders’ numbers.

  • The “JointAccount” data element identifies whether the account is a joint account or not,
  • The “Number” data element is used to identify the number of joint account holders.

To access the new guide, click here: New practical guide and XML schema for CRS reporting

For your information, we also invite you to note that separate specifications for crypto-asset reporting have also been published by the OECD: New practical guide and XML schema for crypto-asset reporting

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