Cayman AEOI: 2025 Updates and Deadlines

Automatic Exchange of Information (“AEOI”) is one front on the global fight against tax evasion. This reporting framework promotes sharing of key data between jurisdictions about client financial accounts and transactions. AEOI encompasses the US Foreign Account Tax Compliance Act (“FATCA”) and the OECD’s Common Reporting Standard (“CRS”) frameworks and requires due diligence efforts as well as regulatory reporting.

The end results of AEOI compliance are multi-fold. Efforts to stamp out tax evasion in turn curb illicit activities and international crime, helping to make for a safer world. While these regulations lead to indispensable benefits, for financial institutions, compliance with AEOI can mean burdensome administrative paperwork that can distract efforts away from other strategic objectives.

Investment managers have several points to consider regarding AEOI regulatory reporting going into the next reporting season and beyond. The Maples Group has collective decades of experience in providing the latest legal advice and financial services solutions that support compliance with AEOI regulatory requirements.

For Financial Institutions domiciled in the Cayman Islands, what are the FATCA and CRS deadlines to be aware of?

For FATCA purposes, all Cayman Islands entities classified as Financial Institutions (“FIs”) need to register for a Global Intermediary Identification Number (“GIIN”) within 30 days of becoming a designated FI. The annual deadline for registration with the Tax Information Authority (“TIA”) for FATCA and / or CRS, which is under the auspices of the Cayman Islands Government Department of International Tax Cooperation (“DITC”), is 30 April. Reporting information on reportable account holders for FATCA and / or CRS is due 31 July, and the CRS Compliance Form, which is a set of additional compliance questions, including some in relation to non-reportable account holders, is due every 15 September.

What regulatory changes are anticipated with regards to FATCA or CRS?

One notable change for the 2025 AEOI reporting cycle is the inclusion of the place of birth for CRS reportable account holders. This is in addition to existing requirements to report name, address, tax information numbers and the birthdate of reportable account holders.

The main factor likely to change from year to year, however, is the list of reportable jurisdictions. Saint Kitts and Nevis have been added to the list of Reportable Jurisdictions for reports that are due in 2025 going forward and Cameroon and Mongolia have been added to the list of Reportable Jurisdictions for reports that are due in 2026 going forward.
Once jurisdictions become signatories of the CRS, they commit to passing legislation to implement CRS in their jurisdiction, as well as entering multi-lateral agreements with other jurisdictions to allow for cross-border reporting. Once this is in place with the Cayman Islands, they are added to the list of reportable jurisdictions with sharing of information to commence from the next reporting period.

On occasion, this part of the process is not completed in the time frame first anticipated, which results in changes to the first reporting period for some jurisdictions. For example, some jurisdictions that were previously included in the list for reports due in certain years were updated to be included in later reports. One such jurisdiction, Tunisia, is now included under reports due in 2026 onwards instead of 2025 onwards.

What are some AEOI focus areas?

The TIA has identified several key areas that FIs should be aware of in relation to CRS compliance:

• If an FI has a GIIN or is a CIMA-registered entity then it is expected to be registered with the TIA on the AEOI portal, and filing annual CRS returns and the CRS Compliance Form.
• An individual’s date and place of birth is required to be obtained and reported for CRS individual reportable accounts.
• Self-certification forms should be obtained for all new account holders including those that indicate they are FIs themselves. Verification to the IRS GIIN list is not sufficient to confirm the classification as an FI. Due diligence procedures should be carried out fully, including reasonableness checks against all account opening documentation and publicly available information.

How can Financial Institutions prepare for AEOI regulatory compliance?

It is very important that FIs have clear, written policies and procedures in place to ensure that they comply with AEOI regulations. This is required even when delegating compliance to an external provider such as the Maples Group. Even though reliance may be placed on the external providers’ own policies and procedures, the ultimate responsibility for compliance lies with the FI. FIs should document evidence of oversight over any external providers, which may include resolutions, an annual review in the board meetings or periodic reporting throughout the year from the outsourcing agent to the FI or investment manager.

What AEOI services does the Maples Group provide?

The Maples Group provides a full-service solution throughout the reporting cycle. Specific support may include:

• Applying for a GIIN. For FATCA purposes, Maples Group can serve as the responsible officer.
• Registration with the TIA, including acting as the FI’s principal point of contact.
• Account holder onboarding and facilitating the collection and review of the account opening documentation to determine FATCA / CRS classification, as well as whether those accounts need to be reported—and if so, to which jurisdictions.
• Preparation and submission of annual reporting of reportable account holders, as well as the CRS Compliance Form in relation to other account holders to the TIA on behalf of FIs.

For more information on how the Maples Group can assist with regulatory compliance concerning global AEOI reporting initiatives, please visit our Regulatory and Compliance – AEOI – FATCA and CRS page.

For legal and regulatory disclosures, please visit maples.com/legal-notices.