In July 2025, the Organization for Economic Cooperation and Development (OECD) released updated guidance to help financial institutions and crypto-asset service providers comply with evolving international tax transparency requirements. The updates include revisions to the frequently asked questions (FAQs) for both the Common Reporting Standard (CRS) and the Crypto-Asset Reporting Framework (CARF), as well as a new technical version of the CARF XML Schema User Guide.
What’s New for the Common Reporting Standard (CRS)?
The CRS sets a global standard for the automatic exchange of tax information between jurisdictions. The OECD’s updated FAQs provide two important clarifications for financial institutions relying on its guidance:
- Validity of Self-Certifications: Financial institutions must obtain valid self-certifications from account holders and any controlling persons identified as reportable before submitting their annual reports. The certification must accurately reflect the individual’s status either as of the reporting period or the time of account closure — whichever happens first.
- Crypto-assets as Financial Assets: The OECD confirms that derivative interests (e.g. options, futures, forward contracts) on applicable crypto-assets are considered financial assets for CRS purposes and must be reported. However, crypto-assets that are only held in custody are not considered financial assets for reporting purposes.
What’s New for the Crypto-Asset Reporting Framework (CARF)
As governments work to improve digital asset transparency, CARF sets requirements for reporting crypto-asset transactions. The new additions to the CARF FAQs include:
- Relying on Prior Due Diligence: In a business acquisition of another crypto-asset provider, the acquiring company can generally rely on existing due diligence already done by the seller. However, this only applies if there’s no reason to doubt the accuracy or if circumstances haven’t changed.
- Technical Schema Update: The OECD also released a new version of the CARF XML schema user guide. This new version includes technical updates to help financial institutions meet their electronic reporting requirements, building on the 2024 version of the schema.
Why This Matters
Such updates reflect the OECD’s continued efforts to improve tax transparency, especially in quickly evolving areas like digital assets and decentralized finance. Companies that handle financial accounts or crypto assets should review the changes to ensure compliance needs are met ahead of their next reporting cycle.
If you have questions about how these rules affect you, connect with a CBIZ tax professional to talk through your situation.
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