BVI: CRS XML Schema 3.0 Mandatory from 1 January 2027

What is changing?

From 1 January 2027, the BVIFARS Portal will stop accepting Common Reporting Standard (“CRS“) reports submitted in earlier XML Schema versions. All CRS reports filed through the Portal from that date must be prepared using CRS XML Schema 3.0. This move is part of the implementation of the Amended CRS.

The ITA encourages RFIs to speak to their software vendors, service providers and internal IT teams. The aim is to make sure reporting systems are upgraded and can produce reports that comply with CRS XML Schema 3.0 before the 2027 reporting cycle begins. RFIs, service providers and software vendors are also encouraged to read the relevant implementation guidance and technical specifications on the OECD Tax Transparency Resource Centre.

Reminder: additional information required under the Amended CRS

The Amended CRS, in force in the BVI since 1 January 2026, means RFIs may need to collect, keep and report:

• each Controlling Person’s role in relation to an Entity Account Holder (e.g. beneficial owner, settlor, trustee or protector or other equivalent role where applicable);
• certain Electronic Money Product and Central Bank Digital Currency Product information;
• the additional CRS XML Schema 3.0 data elements; and
• information needed for the revised due diligence requirements under the Amended CRS. RFIs should review their onboarding documents, due diligence processes, policies and reporting systems to make sure they can capture this information.

Key deadline for corrections to existing CRS filings: 30 November 2026

To support an orderly move to the new schema, the ITA encourages RFIs to review their past CRS filings. They should identify any corrections needed and any Reportable Accounts that were previously left out. Any corrections to existing CRS filings, including reports of previously omitted Reportable Accounts, should be submitted through the BVIFARS Portal no later than 30 November 2026.  RFIs that miss this window should expect any later corrections to be accepted only in CRS XML Schema 3.0 format.

Next steps for RFIs

BVI RFIs should take the following steps now:

1. Confirm with vendors and service providers that their reporting solutions will support CRS XML Schema 3.0 before 1 January 2027.
2. Review past CRS filings and submit any corrections or omitted Reportable Accounts by 30 November 2026.
3. Update onboarding documents, due diligence procedures, reporting systems and internal policies to reflect the Amended CRS data requirements.

The full notice is available on the BVI ITA website. We will continue to further updates from the ITA on the Amended CRS and the move to Schema 3.0, and will provide further guidance as updated.  If you would like to discuss how these changes affect you at this stage, please contact your usual Maples Group contact.