CRS 2.0 introduces targeted updates to close coverage gaps and reflect market developments, most notably with respect to the increased adoption of digital assets.
Key updates to reporting requirements include the expansion of “financial accounts” to cover certain electronic money products and central bank digital currencies (“CBDCs“), as well as an expanded definition of “financial assets” to include crypto-assets held in custody, derivatives and other indirect crypto-asset investments.
The amendments also clarify reporting entity classifications by expressly bringing certain e‑money providers within the scope of “depository institutions” and broadening “depository accounts” to capture relevant e‑money and CBDC holdings.
The BVI has also committed to implementing the OECD’s Crypto‑Asset Reporting Framework (“CARF“), with information exchanges under CARF targeted for 2028.
BVI Financial Institutions should now map the CRS 2.0 changes against their customer onboarding, due diligence, classification and reporting processes, update policies and self‑certification documentation, and plan system enhancements to capture the new data elements in time for the 2027 reporting cycle.
BVI entities involved in crypto‑asset activities should also commence preliminary CARF impact assessments to align with the BVI’s 2028 exchanges timeline and in-scope businesses should begin assessing applicability, data readiness and system changes required to support future CARF reporting.
