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CRS Filings - Financial Institutions to Maintain DoB Information

The Department for International Tax Cooperation ("DITC") has issued a reminder bulletin that the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations (2021 Revision) require the reporting of the date of birth (“DoB”) for all individuals classified as Reportable Persons, including both Account Holders and Controlling Persons.

On 22 March 2024, the Department for International Tax Cooperation ("DITC") issued a reminder bulletin that the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations (2021 Revision) require the reporting of the date of birth (“DoB”) for all individuals classified as Reportable Persons, including both Account Holders and Controlling Persons. Following an examination of data submitted for the 2022 Reporting Period, it appears 10% of Financial Institutions neglected to do so.

Further, it is expected that Financial Institutions maintain DoB information in their records, regardless of whether the account is categorised as a Pre-existing Account under the CRS, as per Anti-Money Laundering (“AML”) obligations (e.g. the requirement to collect a valid passport that contains a DoB).

As such, the DITC will review submitted returns as part of its annual compliance and enforcement endeavours, with a particular emphasis on FIs that fail to report a D.o.B.

Action Required

  • FIs must ensure the accurate provision of DoB for all individual Account Holders and Controlling Persons in CRS XML Returns for the 2023 Reporting Period (deadline: 31 July 2024).
  • Failure to include the DoB in a CRS XML Return may lead to compliance and enforcement actions against the FI.

If you require further information or need assistance with updating your records, contact a member of the Stuarts team or reach out to one of our key contacts below.

Contact our experts for further advice

View profile for Chris HumphriesChris Humphries
Managing Director and Head of Funds
, View profile for Jonathan McLeanJonathan McLean
Partner and Head of Banking & Regulatory

This publication is for general guidance and is not intended to be a substitute for specific legal advice. Specialist advice should be sought about specific circumstances.