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Regulatory Round-up

CRS and Economic Substance Updates for the Cayman Islands

The DITC has issued key updates affecting CRS and Economic Substance reporting. Financial Institutions must file 2025 CRS returns and filing declarations by 31 July 2026, ahead of the DITC Portal’s closure for its transition to XML Schema v3.0. ES courtesy reminders will no longer be sent by email— relevant entities must track deadlines independently. Updated self-certification forms are now available. Two-factor authentication is on the horizon.

Financial Institutions and Relevant Entities

On 17 June 2026, the Cayman Islands Department for International Tax Cooperation (“DITC“) issued an Industry Advisory outlining important updates to the Common Reporting Standard (“CRS“) and Economic Substance (“ES“) reporting requirements.

CRS Return Filing Deadline — 31 July 2026

Financial Institutions (“FIs“) are reminded that the deadline for submitting 2025 CRS XML files and Filing Declarations is 31 July 2026. Critically, the DITC Portal will close for CRS XML submissions in early August 2026 due to the transition to XML Schema version 3.0 and will not reopen until early 2027. This closure does not extend the filing deadline for CRS Reportable Accounts related to the 2025 Reporting Year, making timely compliance essential.

Transition to XML Schema v3.0

When the DITC Portal reopens in 2027, all new filings, corrections, and deletions must use the updated XML Schema v3.0. The DITC will no longer provide its XML generator tool, so FIs should make alternative arrangements.

Updated CRS Self-Certifications, Administration Form and Guidelines

Updated Individual and Entity Self-Certification Forms—aligned with the 2025 Amendment Regulations that became effective 1 January 2026—are now available.

Additionally, updated administration forms and CRS industry guidance are anticipated in Q3 2026.

Portal Security Enhancement

Two-factor authentication will become mandatory for all access to the DITC Portal, with implementation expected in Q3 2026.

Economic Substance Communication Change

The DITC will no longer send courtesy reminder emails to Responsible Persons in advance of ES filing deadlines. From ESN Year 2025 onwards, reminders will only appear via the DITC Portal’s messaging banner. Relevant entities must ensure they independently track and meet all ES reporting obligations including the timely annual filing of ESNs by 31 January and of ES returns or Tax Resident Overseas Forms within 12 months of the entity’s financial year end (as applicable).

The Maples Group has extensive experience in advising on CRS and ES compliance obligations. Please reach out to your usual Maples’ contact if we can be of assistance.

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