What Has Changed?
The updated form aligns with the expanded data collection and reporting requirements under the 2025 Amendment Regulations. Many of these changes codify existing practice or formalise requirements previously addressed through guidance. The updated form also reflects the expanded mandatory data fields that must be collected which include full Controlling Person details, all jurisdictions of tax residence (removing reliance on tiebreaker rules), and standardised TIN non-availability reasons in accordance with the 2025 Amendment Regulations.
Action Required
Financial institutions and fund administrators should review their onboarding and self-certification processes to ensure all mandatory data fields are being collected going forward. A form that does not do so will not produce a “valid self-certification”, a requirement under the updated framework.
For further guidance on the updated requirements, please contact a member of the Maples Group’s Regulatory team.
