Topic | Amendment | 2026 | 2027 (and subsequent) |
CRS registration deadline | - For entities formed after 1 January 2026, the registration deadline is moved to 31 January of the preceding calendar year.
- All Cayman Islands financial institutions must designate a person located in the Cayman Islands as the Principal Point of Contact (PPoC) and identify this person on the registration form.
- Registered financial institutions that did not have a PPoC in the Cayman Islands have until 31 January 2027, to amend their registration via the change form discussed below.
- Non-reporting financial institutions are required to provide a statement to the DITC listing a person located in the Cayman Islands serving as PPoC.
| - The registration deadline for entities formed in 2025 is 30 April 2026.
| - The registration deadline for entities formed in 2026 and after is 31 January.
- The deadline for registered entities to modify their registration to designate a person in the Cayman Islands as PPoC is 31 January 2027.
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CRS registration and change of information | - Changes to registration information must be submitted to the DITC through the registration portal.
- Each entity registering as a financial institution must include on the registration form the date on which it became a financial institution.
- The detailed requirements on the change notification process have not yet been published in the DITC Portal Guidelines.
| - A change form is required within 30 days of the change.
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Reporting deadlines | - CRS reporting deadlines move to 30 June for CRS Financial Account Reporting and the compliance form.
- The Foreign Account Tax Compliance Act (FATCA) reporting deadline is not mentioned, so it is unclear whether it will remain 31 July.
- The reporting deadline change is effective in 2027; therefore, the 30 June deadline will apply in 2027 for the first time.
| - The deadline for the CRS return and nil return is 31 July.
- The deadline for the CRS Compliance form is 15 September.
| - The CRS return and nil return are due by 30 June.
- The CRS compliance form is due by 30 June.
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Penalties and compliance provisions | - Penalties are effectively capped at US$50k for combined primary and continuing penalties.
- No interest is imposed on penalties.
- For penalties related to the obligation to submit a return or nil return, the DITC can impose a penalty (by a penalty notice) without a prior breach notice.
- The deadline to respond to a breach notice is reduced from 60 days to 30 days.
- For confirming compliance, the DITC can request information, inspect records and mandate that entities bring information held abroad into the Cayman Islands, with a requirement to retain relevant records for at least six years.
| - These provisions are effective 1 January 2026.
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Amendments specific to implementing CRS 2.0 | - Financial institutions have new reporting requirements, including to report:
- Whether the account holder or controlling person has provided a valid self-certification
- Whether the account is a joint account and the number of joint account holders
- What roles are held by controlling persons, including for legal arrangements that are classified as CRS reporting financial institutions (see discussion below)
- Whether the account is new or preexisting
- Preexisting accounts are defined to include accounts treated as financial accounts solely by virtue of the CRS amendments as of 31 December 2025
- E-money products are included within the CRS scope.
- Definitions have been modified to align with CARF; for example:
- Depository Institution and Depository Account includes entities holding e-money products and central bank digital currencies.
- Investment Entity and Equity Interest in an Investment Entity includes crypto assets, so indirect investments in crypto assets will fall within the CRS reporting requirements going forward.
| - These provisions are effective 1 January 2026.
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Controlling persons | - The role of each controlling person must be reported along with whether a valid CRS self-certification has been provided.
- Anti-money laundering/know your customer (AML/KYC) standards can only be used to determine controlling persons for financial institutions not legally required to apply AML/KYC procedures that are consistent with Financial Action Task Force (FATF) recommendations.
| - The transition rule allows reporting financial institutions to not provide information on the roles of controlling persons if this information is unavailable until 2027 (for reporting due in 2028).
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Reasonable efforts to obtain taxpayer identification numbers (TINs) and date of birth | - Financial institutions are required to obtain TINs and dates of birth for preexisting accounts earlier than the second calendar year if the financial institution is required to update the information relating to these accounts under domestic AML/KYC.
| - This provision is effective 1 January 2026.
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Other CRS provisions | - Overall, the word "Reporting" has been removed in multiple places so the obligations (e.g., to archive documentation, maintain policies to verify the entity classification, provide compliance forms) are extended to all financial institutions (not just to reporting financial institutions).
- A new definition of "self-certification":
- Specifies all the information that a CRS self-certification must include for a valid self-certification form (these requirements align with the OECD version of the self-certification forms, including that a signature or attestation on the form is required).
- Clarifies that self-certification is not required (temporarily) in exceptional circumstances, allowing financial institutions to apply preexisting account-due-diligence procedures until the self-certification is obtained.
- The definition of "changes in circumstances" has been expanded to include not only a change in the information relevant to the status of an account holder or controlling person but also a change that otherwise conflicts with the status of an account holder or controlling person.
| - These changes are effective 1 January 2026.
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CARF requirements | - The following CARF requirements were included in the guidance release in addition to the standard due diligence and reporting provisions.
- Policies and procedures: Cayman Reporting Crypto-Asset Service Providers (CASPs) must establish written policies to comply with reporting and due diligence requirements. They are also required to collect self-certifications from preexisting individual and entity users within 12 months of the regulations coming into force (by 1 January 2027), and from new users before establishing a relationship.
- Registration deadline: Existing CASPs must register electronically by 30 April 2026, while new CASPs must register by 31 January of the following year. Any changes to required information must be reported within 30 days.
- Reporting deadline: CASPs are required to submit an annual return to the DITC for each reportable user or reportable controlling person and if there are no such entities, submit a nil return by 30 June of the year following the relevant calendar year.
- PPoC requirement: Each CASP must designate a PPoC located in the Cayman Islands during registration with the DITC and may also appoint another individual to submit change notices on behalf of the PPoC.
- Penalty structure and appeals process: Corporate bodies and individuals associated with unincorporated CASPs may face a primary penalty of up to US$50k, while other cases are subject to a maximum penalty of US$20k. A daily continuing penalty of US$100 can accrue for ongoing violations, ceasing once total penalties reach US$50k. If a penalty is not paid within 30 days, it becomes a debt that the CASPs owes to the DITC. The appeals process outlines representative liability, notification requirements and evidentiary standards for enforcement and legal proceedings.
| - These changes are effective 1 January 2026.
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