Cayman Islands CRS Updates for 2026
- Elizabeth A. McMorrow
- 1 minute ago
- 3 min read
The Cayman Islands published updated regulations related to the Common Reporting Standard (CRS). Certain changes are effective as of January 1, 2026 while others will come into effect in subsequent years.
Primary Point of Contact (PPoC)
Currently, as part of the online Cayman Islands Notification process, it is necessary to appoint an Authorizing Person and Principal Point of Contact (PPoC) for each Financial Institution (FI). The PPoC can be an individual who is resident outside of the Cayman Islands. The PPoC may be a named employee/fiduciary of the FI or an employee/fiduciary of a third-party service provider.
Under the new regulations, FIs registering in the Cayman Islands portal January 1, 2026 and thereafter, must name a PPoC who is resident in the Cayman Islands. For FIs who are registered in the Cayman Islands portal as of December 31, 2025, the FI has until January 31, 2027 to update the PPoC if the PPoC does not meet the residency requirement.
Careful consideration should be given when identifying a person/entity who will serve as PPoC given the PPoC has the ability through the DITC portal permissions granted to a PPoC to:
Submit Authorizing Person Change Forms
Add and manage Secondary Users
Create, view, amend and delete a U.S. IGA or CRS report including FATCA/CRS return, CRS Compliance Form and CRS Filing Declarations
Submit FI Deactivations and FI Change Forms (to change the reporting obligations of the FI)
Registration Deadline
The Cayman Islands requires that reporting and non-reporting FIs submit a “Notification” by registering in the Cayman Islands DITC Portal by April 30 of the year following the year in which the entity becomes an FI. Registration is required under both the U.S.-Cayman Islands IGA and CRS. For entities formed in 2026 and thereafter, the new deadline will be January 31.
It is possible to register an FI in the DITC Portal throughout the year. Accordingly, internal communication is important to avoid missing the deadline. As new entities are formed or acquired, the FATCA/CRS team should be informed so they can determine whether FATCA/CRS applies and what registration requirements apply.
Reporting Deadline
Currently, the annual FATCA and CRS deadlines are the same: July 31 to report on data from the previous year ending December 31. Pursuant to the new regulations, the new CRS deadline will be June 30 starting with June 30, 2027.
Compliance Form Deadline
The Cayman Islands CRS Compliance Form must be submitted annually by all Cayman Islands Reporting FIs and can be completed using the DITC online smart form or in a bulk CSV upload. The Form is due annually by September 15. The form is akin to the IRS FATCA RO Certification covering five areas:
Section 1 - Financial Institution Profile Data
Section 2 - Financial Account Data
Section 3 - AML/KYC and Accounting
Section 4 - CRS Process
Section 5 - Declaration
Starting in 2027, the new annual deadline will be June 30.
Reporting Data
The new regulations require certain additional data be included in annual reporting. This means that onboarding documents / self-certifications must capture relevant information. These data points include:
Whether the account is a joint account, including the number of joint Account Holders.
What the account type is and whether the account is a Pre-existing Account or a New Account.
If an Equity Interest is held in an Investment Entity that is a legal arrangement, indication of the role(s) by which the Reportable Person is an Equity Interest holder.*
If a Reportable Person is a Controlling Person of an Entity, indication of the role(s) by which the Reportable Person is a Controlling Person.*
Whether a valid self-certification has been provided for each Reportable Person.
*Reporting of the Controlling Person role and the Equity Interest holder role will be transitioned in over time. For a Reportable Account that is maintained by a Reporting FI as of 31 December 31, 2025 and for reporting periods ending December 31, 2026 and December 31, 2027, the Controlling Person role and the Equity Interest holder role are only required to be reported if such information for that Reportable Account is available in the electronically searchable data maintained by the Reporting FI.
For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.