CRS (Common Reporting Standard): what HNW migrants should know in 2026

The Common Reporting Standard, or CRS, is not a new regime — it has been operational since 2017 across more than 110 jurisdictions — but a series of 2025-2026 developments have materially altered the compliance landscape for high-net-worth individuals who hold cross-border assets. Three changes demand attention: the OECD’s tightening of the “prevention of abuse” provisions in the CRS Implementation Handbook (2025 revision), the expansion of the CRS to include digital asset reporting via the Crypto-Asset Reporting Framework (CARF), and the increasing willingness of tax authorities to exchange not just financial account data but also beneficial ownership information derived from corporate registries. For a principal with USD 10M+ in liquid wealth spread across four jurisdictions, the consequence is that a previously manageable reporting burden has become a structural risk that requires active, jurisdiction-specific planning. This essay treats the CRS as a technical compliance system — not a threat to be feared, but a set of rules whose precise application varies by residence, citizenship, asset location, and entity structure. The objective is to equip advisors and principals with the statutory references, worked examples, and planning steps that make the difference between a clean file and a multi-year audit. ## The mechanics of CRS reporting in 2026 CRS operates on a simple principle: financial institutions in participating jurisdictions must identify accounts held by tax residents of other participating jurisdictions and report those accounts to their local tax authority, which then automatically exchanges the data with the account holder’s jurisdiction of tax residence. The 2026 version of this process contains three structural changes that advisors cannot ignore. ### The expanded scope of reportable accounts Under the original CRS, reportable accounts were limited to depository accounts, custodial accounts, equity and debt interests in certain investment entities, and cash-value insurance contracts. The 2025-2026 OECD guidance, published as an addendum to the *Standard for Automatic Exchange of Financial Account Information in Tax Matters* (second edition, 2024), clarifies that certain hybrid instruments — including structured notes with embedded derivatives and certain types of variable annuity contracts — now fall within the definition of “custodial account” where the financial institution holds the underlying assets. The practical effect is that a principal who holds a USD 5M structured note through a Swiss private bank will see that account reported under CRS even if the note’s legal form is technically a derivative contract rather than a custodial holding. ### The integration of CARF with CRS The Crypto-Asset Reporting Framework, adopted by the OECD in 2023 and effective for reporting periods beginning on or after 1 January 2026, requires reporting of crypto-asset transactions by “reporting crypto-asset service providers” — a category that includes exchanges, wallet providers, and certain decentralised finance platforms that exercise control over user assets. What matters for HNW migrants is the overlap: a principal who is tax resident in Singapore but holds a USD 2M Bitcoin position through a UAE-based exchange that is a CRS-reporting entity (because the UAE has adopted CRS and CARF) will see that position reported to Singapore’s Inland Revenue Authority of Singapore (IRAS) under the CARF framework. The OECD has confirmed that CARF data will be exchanged through the same multilateral competent authority agreement (MCAA) infrastructure as CRS data, meaning a single data leak or mismatch can trigger enquiries across both regimes. ### The beneficial ownership overlay Since 2023, the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes has pushed for the integration of beneficial ownership information into CRS exchanges. The 2025 peer review reports for several jurisdictions — including the British Virgin Islands, Cayman Islands, and Panama — explicitly recommend that financial institutions cross-reference CRS self-certifications against corporate registry beneficial ownership data. For a principal who owns a Cayman Islands trust that holds a Swiss bank account, the consequence is that the Swiss bank must now verify that the CRS self-certification naming the trust’s tax residence matches the beneficial owner information filed with the Cayman Islands registry. A mismatch triggers a “reason to know” obligation under the CRS due diligence rules, requiring the bank to reclassify the account as reportable. ## Jurisdictional variation: where the rules diverge No two CRS-implementing jurisdictions apply the standard identically. The differences matter most for principals who hold assets in multiple countries or who change residence during a reporting period. ### The United States: not a CRS participant The United States does not participate in CRS; it operates its own Foreign Account Tax Compliance Act (FATCA) regime, which is bilateral rather than multilateral. This creates a structural asymmetry: a US citizen resident in London will have their UK bank account reported to the IRS under the US-UK FATCA intergovernmental agreement, but their US brokerage account will not be reported to HMRC under CRS. For a principal with dual US-UK residence, the planning implication is that US-based assets enjoy a degree of reporting opacity that UK-based assets do not — but only until the OECD’s proposed “FATCA-CRS convergence” framework, discussed in the 2025 OECD ministerial communiqué, is implemented. ### Switzerland: the end of banking secrecy Switzerland has been a CRS participant since 2017, but its implementation has evolved. The Swiss Federal Tax Administration’s 2025 circular on CRS due diligence (Kreisschreiben Nr. 45, 15 March 2025) clarifies that Swiss banks must now report accounts held by “passive non-financial entities” (PNFEs) where the controlling person is a reportable person — even if the entity itself is not a reportable person. For a principal who holds a Swiss account through a Liechtenstein foundation, the foundation is treated as a PNFE, and the principal’s identity and account balance are reported to their residence jurisdiction. ### Singapore and Hong Kong: the Asian divergence Singapore and Hong Kong both implement CRS, but their enforcement priorities differ. Singapore’s Inland Revenue Authority of Singapore (IRAS) issued a practice note in January 2026 (IRAS e-Tax Guide, CRS/G10/2026) requiring financial institutions to obtain a tax identification number (TIN) for every reportable account holder, with a penalty of SGD 5,000 per missing TIN for accounts exceeding SGD 1M. Hong Kong’s Inland Revenue Department, by contrast, permits financial institutions to accept a “reason for no TIN” declaration without penalty. For a principal who holds accounts in both jurisdictions, the practical effect is that Singapore imposes a higher compliance cost on the financial institution, which may pass that cost to the account holder through higher fees or increased documentation demands. ## Worked example: the composite case of Dr. A Dr. A is a 58-year-old physician and entrepreneur who became a tax resident of Portugal in 2024 under the Non-Habitual Resident (NHR) regime, having previously been a tax resident of Brazil. She holds the following assets: - A USD 4M investment portfolio at UBS Zurich (Switzerland) - A USD 2M real estate fund interest held through a Cayman Islands limited partnership - A USD 1.5M Bitcoin position held through Binance (registered in the Seychelles, but with a Singapore-based subsidiary) - A USD 500k savings account at Banco Santander Totta (Portugal) - A USD 2M life insurance policy issued by a Bermuda-based insurer, held through a Luxembourg-based insurance wrapper Under CRS as applied in 2026, the reporting obligations are as follows. ### Swiss account reporting UBS Zurich is a CRS-reporting financial institution in Switzerland. Dr. A’s Portuguese tax residence triggers a reporting obligation. UBS must report the account balance, interest, dividends, and gross proceeds from the sale of financial assets to the Swiss Federal Tax Administration, which exchanges the data with the Portuguese Autoridade Tributária e Aduaneira (AT). The 2025 Swiss circular on PNFEs does not apply because the account is held in Dr. A’s personal name. ### Cayman Islands partnership interest The Cayman Islands limited partnership is treated as an “investment entity” under CRS because its primary business is investing in real estate funds. The partnership is a CRS-reporting financial institution in the Cayman Islands. Dr. A is the controlling person. The partnership must report her interest — valued at USD 2M — to the Cayman Islands Tax Information Authority, which exchanges the data with Portugal. The 2025 OECD guidance on PNFEs does not apply because the partnership is itself a financial institution, not a passive entity. ### Crypto-asset position Binance’s Singapore subsidiary is a reporting crypto-asset service provider under CARF. Dr. A’s Bitcoin position of USD 1.5M is reportable to Singapore’s IRAS, which exchanges the data with Portugal. The critical detail: CARF requires reporting of the “aggregate value of crypto-assets” at the end of the reporting period, plus the total value of transactions exceeding USD 50,000. Dr. A’s position triggers both thresholds. ### Portuguese savings account Banco Santander Totta is a CRS-reporting financial institution in Portugal. Because Dr. A is a Portuguese tax resident, the account is not reportable under CRS — it is a domestic account. However, the bank must still maintain the self-certification on file and report the account to the AT as part of Portugal’s domestic reporting regime. ### Bermuda insurance policy The Bermuda-based insurer is not a CRS-reporting financial institution because Bermuda has not adopted CRS. However, the Luxembourg-based insurance wrapper is a CRS-reporting entity. Under the 2024 OECD guidance on insurance wrappers, the wrapper is treated as a custodial account, and the underlying policy’s cash surrender value of USD 2M is reportable to Luxembourg’s Administration des Contributions Directes, which exchanges the data with Portugal. The composite result: Dr. A’s total reportable assets across four jurisdictions amount to USD 9.5M, all of which are exchanged with Portugal. Any discrepancy between Dr. A’s Portuguese tax return and the CRS data — for example, if she reports only USD 7M in foreign assets — triggers an automatic data-matching flag. The Portuguese AT, which has invested heavily in its CRS data analysis unit since 2023, has the capacity to issue a notice of enquiry within 90 days of receiving the data. ## Planning strategies for HNW principals in 2026 The CRS is not avoidable for a principal who holds assets in participating jurisdictions. But the reporting burden can be managed through structural choices that reduce the number of reportable accounts, align asset locations with residence jurisdiction, and ensure that data integrity is maintained. ### Residence planning as a CRS strategy The most effective CRS planning tool is residence itself. A principal who becomes a tax resident of a jurisdiction with no CRS participation — such as the United Arab Emirates (which has adopted CRS but does not impose personal income tax) or the United States (which does not participate in CRS) — eliminates the reporting obligation for accounts held in that jurisdiction. However, the principal’s accounts in other CRS jurisdictions remain reportable to their new residence jurisdiction. The strategy is not to hide assets but to concentrate them in a jurisdiction where the reported data has no tax consequence. ### Entity restructuring Holding assets through a corporate entity that is itself a CRS-reporting financial institution — such as a family office structured as an investment entity in a CRS jurisdiction — creates a reporting obligation for the entity. A better structure for a principal who wishes to minimise CRS reporting is a “non-reporting entity” under the CRS rules, such as a holding company that does not meet the definition of a financial institution. The 2025 OECD guidance on “active non-financial entities” (ANFEs) provides a safe harbour: an entity that derives less than 50% of its income from passive sources and has less than 50% of its assets held for passive purposes is not a reportable entity. A principal who holds operating businesses through a holding company can structure the entity to meet the ANFE test, thereby avoiding CRS reporting at the entity level. ### The timing of residence changes A principal who changes residence mid-year faces a reporting complication: both the former and new residence jurisdictions may claim the right to receive CRS data for the full year. The OECD’s 2024 guidance on “multiple residence” cases recommends that financial institutions rely on the principal’s self-certification of residence, but a change during the year creates a “reason to know” that the self-certification may be outdated. The practical solution is to close accounts in the former residence jurisdiction before the change takes effect, or to convert those accounts into non-reportable forms (such as real estate holdings) that fall outside CRS scope. ## Five actionable takeaways for 2026 1. Obtain a valid tax identification number (TIN) in your residence jurisdiction before opening any new account in a CRS-participating country, because financial institutions in Singapore, Switzerland, and the UAE now impose penalties for missing TINs on accounts exceeding USD 1M. 2. Review all existing self-certifications for accuracy, particularly for accounts held through trusts, foundations, or partnerships, because the 2025 beneficial ownership overlay means that a mismatch between the self-certification and corporate registry data triggers a “reason to know” obligation for the financial institution. 3. If you hold crypto-assets through an exchange or wallet provider, confirm whether that provider is a CARF-reporting entity, because the CARF framework effective 1 January 2026 requires reporting of positions and transactions to your residence jurisdiction even if the provider is based in a non-CRS jurisdiction. 4. Consider restructuring passive holding entities into active non-financial entities (ANFEs) if the entity’s income is primarily from operating businesses, because ANFEs are exempt from CRS reporting and reduce the number of reportable accounts in your portfolio. 5. Before changing tax residence, close or restructure accounts in the former residence jurisdiction to avoid dual reporting for the transition year, because the OECD’s multiple-residence guidance leaves financial institutions with discretion to report to both jurisdictions. ## Sources - OECD, *Standard for Automatic Exchange of Financial Account Information in Tax Matters*, Second Edition (2024), https://www.oecd.org/tax/automatic-exchange/common-reporting-standard/ - OECD, *Crypto-Asset Reporting Framework* (2023), effective 1 January 2026, https://www.oecd.org/tax/automatic-exchange/crypto-asset-reporting-framework/ - Swiss Federal Tax Administration, Kreisschreiben Nr. 45 zur CRS-Sorgfaltspflicht (15 March 2025), https://www.estv.admin.ch/estv/en/home/automatic-exchange.html - Inland Revenue Authority of Singapore, IRAS e-Tax Guide CRS/G10/2026 (January 2026), https://www.iras.gov.sg/taxes/international-tax/common-reporting-standard - OECD Global Forum on Transparency and Exchange of Information for Tax Purposes, *Peer Review Reports 2025*, https://www.oecd.org/tax/transparency/