In July 2024, the U.S. Internal Revenue Service (IRS) announced that it updated the FATCA Registration System to enhance security. For those of you who have not yet created a new account or accessed an existing account, this post offers some user tips.
What Is the FATCA Registration System?
This is the online portal used by entities which are required by FATCA to register with the IRS to obtain a Global Intermediary Identification Number (GIIN). For some Financial Institutions (FIs), this FATCA portal is also where an FI will submit its Periodic Certifications and a one-time Certification of Preexisting Accounts (COPA). The FATCA Registration System is not the IDES portal which is used by FIs that are required to submit annual FATCA reporting directly to the IRS rather than a local tax authority.
How Was the FATCA Registration System Updated?
Previously, when a representative for the FI registered the FI in the IRS FATCA portal, she would create an Account Access Code that was between 8-20 characters containing an uppercase letter, a lower case letter, a number, and a special character. To log into the account after the initial registration, the user would need the Account Access Code and the FATCA ID (the first 6 characters of the GIIN). As of July 2024, the Account Access Code has been eliminated.
To access an existing account or create a new account, the user will still use the same IRS link. However, a completely different page appears. This page instructs the user to use Login.gov or ID.me. According to the IRS, “Login.gov is an account created, maintained, and secured by the U.S. government. ID.me is an account created, maintained, and secured by a technology provider.” The verification goal behind these systems is that the email address used to access the FATCA portal must match the Responsible Officer (RO) email address or one of the Points of Contact (POCs) email addresses in the FATCA GIIN registration.
A nice feature related to the update is that you can select among a limited number of other languages (Spanish, French, Mandarin) as the language in which you will receive emails.
Information Required for Login.gov
If you would like to use ID.me, you can explore the process on your own as this post focuses on Login.gov. Setting up a Login.gov account requires providing and then verifying an email address, creating a password, and setting up multi-factor authentication to secure the account. The following multi-factor authentication options are available:
A passphrase
Backup codes
One-time passcodes through SMS (text) or voice messaging, sent to a mobile device you control
One-time passcodes through authenticators apps such as Google Authenticator or Authy, downloaded to a mobile device of your own and registered with Login.gov
PIV and CAC cards, for federal and armed forces personnel only
WebauthN security devices and software, such as FIDO (“Fast IDentity Online”) tokens, Yubikeys, and Google’s Titan Security Keys, obtained by you and registered with Login.gov
Customer support and help desk services are available through https://login.gov/contact/.
Some Practical Tips
The account access codes are no longer relevant. The email you use to create the Logingov.com or ID.me account must be an email currently in your FATCA registrations. The system then allows that email access to all the FATCA accounts. When you log into the new system, you will have the choice to create a new FATCA account for a new company or to access existing accounts. To access the existing company accounts, you will need the "FATCA ID".
When you are registering a new company, the RO email will pre populate with the email address of the person who has logged on through Login.gov. If this person is not the RO, then make sure you enter the correct email address for the RO. The person registering the new company must enter the email address used to access the system as RO or as a POC. This is because the registration links back to the email address used to access the account as a validation mechanism.
When you are in a specific account, look at the bottom left and click on Switch Account. This allows you to enter another FATCA ID without having to redo the login process.
Once you log out of the specific entity’s FATCA account, you exit to the main IRS.gov page. You do not remain in the FATCA portal to continue to another FATCA account. This means if you choose Backup Codes as your form of authentication when you create your Login.gov account, you will use one backup code for each entity account you are accessing or creating.
The system may ask you "Do you want to sign out of Login.gov and return to IRS?" This will allow you to make changes to your login account but does not provide a path to continue to another FATCA account.
Multiple U.S. Agencies
The U.S. government views Login.gov as a step toward single user account access across participating government agencies. This means you have to determine which email you use: work or personal depending on the tasks you are handling.
You should not share your access with colleagues because the one login connects to other accounts you have included in your Login.gov dashboard. (E.g., You file a Beneficial Owner Information Report (BOIR) with FinCEN for an entity which is independent of your day job or you apply for a U.S. government job through USAJOBS.)
For those using ID.me, follow the instructions ID.me provides to keep your personal and business information separate.
For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.
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