CRS Expansion 2025: New Jurisdictions and Crypto

The Common Reporting Standard keeps expanding into new jurisdictions and crypto assets. Here is what automatic exchange means and why transparency wins.

When the Common Reporting Standard first went live, a familiar assumption quietly collapsed. The idea that an account in one country could remain invisible to the tax authority of another had, for a generation, underpinned a great deal of cross-border planning. CRS replaced that assumption with its opposite.

A decade on, the Common Reporting Standard is no longer a novelty but the default condition of international finance, and it is still growing. Each year brings new participating jurisdictions, and the framework is now being extended to capture asset classes that did not meaningfully exist when it was designed.

For internationally mobile individuals and the structures they use, the direction of travel is now beyond doubt. Understanding it is the starting point for any planning that is meant to last.

What automatic exchange actually means

CRS is an information-sharing framework developed under the OECD and adopted by over a hundred jurisdictions. Its mechanism is automatic exchange. Financial institutions, banks, custodians, certain investment entities, and some insurers, identify accounts held by tax residents of other participating jurisdictions, gather defined information about those accounts, and report it to their local tax authority.

That authority then passes the data, once a year and without any specific request, to the tax authority of the account holder's country of residence. The reported information includes the account holder's identity, the account balance, and income such as interest, dividends, and certain proceeds.

The word that matters is automatic. Under the older system of exchange on request, a tax authority had to know what it was looking for and ask for it specifically. Under CRS, the data simply arrives. There is no longer a gap to hide in between suspicion and discovery.

It is also worth appreciating how the reporting is keyed. CRS turns on tax residence, not nationality or where an account was opened. A financial institution is obliged to establish, through self-certification and documentary checks, where each account holder is resident for tax purposes, and to report accordingly. Someone who has moved countries, holds residence in more than one place, or has an unclear or contested residence position can therefore find their information flowing to a jurisdiction they did not expect. Getting one's residence position clear and consistent is, for that reason, a foundational part of any cross-border plan.

A framework that keeps widening

CRS was never a fixed list. New jurisdictions continue to join, including financial centres that were once seen as outside the net, and the practical reality is that the number of places offering genuine reporting opacity has dwindled to a handful that carry their own severe drawbacks.

Just as significantly, the standard reaches through structures, not just around them. Where an account is held by a passive entity, a personal investment company, certain trusts, an underlying holding vehicle, the financial institution is generally required to look through to the controlling persons and report on them. Settlors, beneficiaries, and ultimate beneficial owners are within scope, not merely the entity on the account-opening form.

The result is that interposing a company or a trust between an individual and an account does not, of itself, defeat reporting. The structure may serve perfectly good purposes, succession, governance, asset protection, but invisibility is no longer among them.

There is a further consequence that catches people out: the classification of an entity under CRS drives everything that follows. Whether a structure is treated as a financial institution or as a passive non-financial entity determines who reports, what is reported, and on whom. Misclassification is a common and costly error, because a structure that the owner assumed was outside the reporting net frequently is not, and the discovery arrives indirectly, through a bank's account review or a trustee's annual return, rather than through any choice of the owner's own.

The crypto frontier

The clearest recent development is the extension of automatic exchange to crypto-assets. The OECD has developed the Crypto-Asset Reporting Framework, commonly called CARF, to bring exchanges, certain wallet providers, and other crypto intermediaries within a reporting regime broadly parallel to CRS.

The logic is straightforward. As wealth migrated into digital assets, a reporting gap opened, and tax authorities have moved to close it. Under CARF, crypto service providers will be expected to collect information on their users and report relevant transactions and balances, with that information then exchanged between jurisdictions.

Timing and scope vary as jurisdictions write the framework into domestic law, so anyone holding meaningful digital assets should treat the specifics as a moving target and seek current advice. But the strategic point is settled: the assumption that crypto sits permanently outside the reporting perimeter is not a foundation on which to plan.

The same applies to the platforms themselves. Major exchanges have already moved to fuller identity verification and transaction monitoring, both to meet anti-money-laundering rules and in anticipation of CARF reporting. An individual who acquired digital assets years ago through a now-compliant platform may find that historic activity becomes visible as that platform aligns with the new obligations. Planning that assumed permanence in the old, lightly documented world of crypto needs to be revisited in light of where the platforms are heading.

What this means for individuals and structures

The combined effect of CRS and CARF is that the financial picture of an internationally connected individual is increasingly visible to the tax authorities that matter, assembled automatically from many sources. For most people this is simply the new background condition, not a threat, provided their affairs are in order.

Where it becomes a problem is in legacy arrangements built on an expectation of opacity that no longer holds. An old account, a dormant structure, an unreported holding that once seemed safely out of view, these are precisely the things that automatic exchange tends to surface, often at an inconvenient moment and sometimes with penalty exposure attached.

The honest position is that reporting is now a feature of the system to be planned around, not a risk to be managed by concealment. The relevant questions are whether income is being correctly declared, whether structures are reported as required in every relevant jurisdiction, and whether historic gaps need to be regularised before they are discovered.

Why transparency-first planning is the only durable approach

Good international planning has not become impossible; it has become honest. There remain entirely legitimate reasons to hold assets across borders, residency and lifestyle, business operations, succession across multiple countries, currency and political diversification, and to use trusts and companies to achieve those ends.

What has changed is that every such structure must be built to withstand disclosure. A plan that only works so long as no one finds out about it is not a plan; it is a deferred liability. The structures that endure are those whose tax treatment, reporting, and economic rationale all stand up cleanly when, not if, the information reaches the relevant authorities.

This is liberating once embraced. Transparency-first planning is more robust, sleeps more soundly, and ages far better than its alternative. It also tends to be simpler, because the energy once spent maintaining opacity is redirected into getting the substance right.

We help clients understand exactly how CRS and CARF apply to their accounts and structures, identify and regularise any historic gaps, and design cross-border arrangements that achieve their genuine objectives while standing comfortably in the full light of automatic exchange. If you would like to know where you stand, we are ready to help.