FATCA: IRS Public Key Expires 17 October 2025

The IRS announced the Public Key for FATCA filing will expire on October 17, 2025. For those financial institutions (FIs) who submit their FATCA reporting directly to the U.S. Internal Revenue Service (IRS), it is critical to determine if you have downloaded the IRS’ new public key and checked to see if your digital certificate is current.

What Is IDES?

Certain FIs transmit data directly to the IRS through the International Data Exchange Service (IDES). Depending on the amount of data to be submitted and an FI’s in-house staffing, the FI will either submit the data itself to the IRS or engage a third-party service provider who is specialized in electronic FATCA reporting.

Public Key

The IRS public key is a certificate that can be downloaded from the IDES enrollment site and must be included when you transmit FATCA data to the IRS through IDES. Both the IRS public key and your company’s digital certificate have expiration dates. The IRS will replace its public key for FATCA filing on October 17, 2025. You will not be able to submit data to the IRS until you download the new IRS Public Key from IDES.

Digital Certificate

Prior to submitting the IRS Form 8966 data in a standard XML schema format, it is necessary to obtain a Digital Certificate from one of the following IRS Approved Certificate Authorities:

• DigiCert

• Entrust

• GlobalSign

• GoDaddy

• IdenTrust

• Sectigo

Links to each of these companies can be found on the IRS site. The purpose of the certificate is for the certificate authority to confirm the identity of the person sending data to the IRS.

For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.