The Cayman Islands Department for International Tax Cooperation (“DITC“) requires all Cayman Islands Financial Institutions (“FIs“) with CRS reporting obligations to file an annual CRS Compliance Form. This obligation extends to Trustee Documented Trusts. The form is separate from the CRS account report and the CRS Filing Declaration; it collects compliance-related information about an FI’s account population, due diligence processes, and service-provider arrangements.
For the 2025 calendar-year reporting cycle, the CRS Compliance Form must be filed by 15 September 2026. This follows the 31 July 2026 deadline for CRS and FATCA reporting. From the 2026 reporting period onwards, the annual deadline will move to 30 June, aligning it with the CRS reporting deadline. The form is submitted through the DITC Portal and can only be filed by the FI’s Principal Point of Contact (“PPoC“) or authorised Secondary Users. Bulk submissions via CSV upload are also available.
The Compliance Form requires information concerning the FI’s profile and Financial Accounts, its AML/KYC and accounting arrangements, its CRS processes and service providers, and confirmations regarding its CRS policies, procedures and due diligence. It concludes with a declaration that must be agreed before submission.
Failure to submit the form by the deadline places the FI in breach of Part 2 of the CRS Regulations, and an administrative penalty is automatically issued. Indicative penalties for non-submission are CI$10,000 for entities and CI$4,000 for individuals. Primary Penalties of up to CI$50,000 may also apply, with Continuing Penalties of CI$100 per day for unresolved breaches.
