Jonathan McLean
...
The Department for International Tax Cooperation (DITC) has issued an industry advisory confirming that the Tax Information Authority (TIA) has extended the registration deadline under the Tax Information Authority (International Tax Compliance) (Crypto-Asset Reporting Framework) Regulations, 2025 (the CARF Regulations). The revised deadline of 31 January 2027 applies to certain Cayman Reporting Crypto-Asset Service Providers (RCASPs) and takes effect immediately.
Overview of the extension
Under the CARF Regulations, entities and individuals that qualify as RCASPs prior to the commencement of the regime, other than exempted bodies, were required to register on the DITC Portal by 30 April 2026.
The TIA has now extended this deadline to 31 January 2027. The extension is intended to allow sufficient time for compliance once the relevant portal functionality becomes available.
Scope and application
The revised deadline applies to all RCASPs required to register and maintain prescribed information with the DITC via its electronic portal.
Registration requirements
RCASPs must submit and maintain up to date information through the DITC Portal using the prescribed registration or change forms once functionality becomes available. The required information includes:
- the name of the RCASP and any identifying number issued by the General Registry, the Cayman Islands Monetary Authority or another regulatory or supervisory body
- details of authorised contacts, including:
- the principal point of contact (PPoC) located in the Cayman Islands
- any additional person authorised to submit change notices in respect of the PPoC
- the date on which the entity or individual became a RCASP
Principal point of contact
The advisory clarifies that the PPoC must be locally reachable in the Cayman Islands:
- a natural person must have a physical address in the Cayman Islands
- a legal person must be incorporated, registered or established in the Cayman Islands and maintain a physical address in the Islands, not solely a mailing or correspondence address
A PPoC may be either a natural person or a legal person.
The DITC Portal will require sufficient contact details to enable the TIA to communicate directly with the PPoC and to expect timely receipt of, and response to, official communications. Submissions that do not include sufficient contact details may be rejected or subject to follow up by the DITC.
Practical implications
The extension provides additional time for in-scope entities to:
- assess whether they qualify as RCASPs under the CARF Regulations
- identify and appoint an appropriate PPoC in the Cayman Islands
- prepare the required registration information and supporting internal processes
- monitor the release of the DITC Portal functionality and associated guidance
Corporate groups and service providers should ensure that internal governance and reporting frameworks align with the CARF registration requirements, including maintaining accurate and current contact information.
Next steps
RCASPs should monitor further communications from the DITC regarding the availability of the portal and be prepared to complete registration within the revised timeframe.
For further information or assistance in understanding how these developments may affect your organisation, please contact our Regulatory team at jon.mclean@stuartslaw.com.
