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FATCA & CRS Reporting Update - September 2021

A summary of updates from the Department for International Tax Cooperation on FATCA and CRS reporting in the Cayman Islands.

FATCA and CRS Reporting Open

The DITC Portal is now open for 2020 FATCA XML uploads. Filing deadlines are as follows:

Reporting ObligationDeadline
2019 & 2020 CRS Compliance Form15 September 2021


CRS Compliance Form – Bulk Upload CSV

The DITC has published the bulk upload CSV template for the CRS Compliance Form. This is an alternative to the smartform version currently available on the Portal and is designed for Users with access to a large number of FIs on the Portal. Users with a small number of FIs may find it easier to use the smartform version. The template can be downloaded from the DITC website. It can be prepared in Excel – however it must be submitted to the Portal as a CSV file. Users are strongly advised to read the Explanatory Note accompanying the template and Section 5.F. of the CRS Guidelines to assist with the completion of the CSV file.

Questions generally regarding CRS or FATCA can be sent to the DITC Portal Team on

The reporting deadline for the 2019 CRS Compliance Form was 15 September 2021.

The CRS Compliance Form requires express confirmation that financial institutions have established and maintained written policies and procedures which comply with the financial institution's obligations under the Cayman Islands CRS Regulations.

Clients should check with their CRS/AEOI service provider that the CRS Compliance Form has been submitted by the 15 September deadline.

Please contact your usual Stuarts attorney for advice.

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.