CRS 3.0: What’s Changing, When It Applies, and Why It Matters.

For trust and corporate service providers, family offices, fund administrators, and intermediaries, the changes introduce new reportable products, new data requirements, and new operational expectations, with key implications emerging in 2026 and 2027.

A Brief Timeline: From CRS to CRS 3.0

• 2014 – CRS is published by the OECD

• 2016 – First automatic exchanges of information take place between early adopter jurisdictions

• 2017–2018 – CRS becomes widely embedded across participating jurisdictions

• August 2023 – The OECD publishes a package of CRS amendments, alongside the Crypto-Asset Reporting Framework (CARF)

• 2024–2025 – Jurisdictions begin implementing CRS 3.0 into domestic legislation

• 2026 – First reporting period expected for CRS 3.0 in many jurisdictions

• 2027 – First automatic exchanges of CRS 3.0 data anticipated

While local adoption timelines will vary, 2026 and 2027 are the critical years for readiness.

Expanding the Scope of CRS Reporting

One of the defining features of CRS 3.0 is its expanded scope, addressing asset classes and arrangements that were either out of scope or ambiguously treated under earlier versions of CRS.

The updated rules bring greater clarity and coverage in relation to:

• Electronic money products, including certain prepaid, stored-value, and payment-based arrangements

• Central Bank Digital Currencies (CBDCs), as these move from concept to reality across multiple jurisdictions

• Indirect investments in crypto-assets, particularly where exposure is held via funds, trusts, companies, or other intermediated structures

These changes respond directly to the growth of digital finance since CRS was first introduced and aim to prevent circumvention through non-traditional or emerging asset types.

For administrators, this requires a reassessment of:

• Entity and account classifications

• CRS indicators and flags

• Asset and investment recording practices

Importantly, this work needs to be done before the 2026 reporting period, not after.

CRS 3.0 and the Updated OECD XML Schema

To support the revised reporting obligations, the OECD has introduced XML Schema version 3.0, published alongside the 2023 amendments.

The new schema:

• Reflects expanded data fields for digital and crypto-related exposures

• Aligns CRS more closely with other international transparency regimes

• Introduces stricter validation and consistency requirements

From a practical perspective, this means that legacy reporting formats and manual workarounds are unlikely to be sustainable beyond 2026. Firms will need systems capable of adapting quickly to schema changes while maintaining data integrity across reporting cycles.

Alignment with the Crypto-Asset Reporting Framework (CARF)

CRS 3.0 has been designed to operate in parallel with the Crypto-Asset Reporting Framework (CARF), which was also published by the OECD in 2023.

While CRS focuses on:

• Financial accounts

• Controlling persons

• Entity-level reporting

CARF targets:

• Crypto-asset transactions

• Crypto-asset service providers

• Cross-border exchange of crypto-related information

Together, CRS 3.0 and CARF form a coordinated transparency framework, ensuring crypto-assets are no longer a blind spot in international information exchange.

For firms administering structures with any form of crypto exposure, 2026 marks the point at which crypto can no longer be treated as exceptional or outside mainstream reporting processes.

What Is Operationally Relevant for 2026 and 2027?

Although first exchanges are expected in 2027, the 2026 calendar year is the effective starting point for many firms.

Key implications include:

2026

• First reporting year under CRS 3.0 in many jurisdictions

• Expanded asset scope applies

• New XML schema in use

• Increased data validation requirements

2027

• First automatic exchanges of CRS 3.0 information

• Heightened scrutiny from tax authorities as new data types are received

• Greater alignment between CRS, FATCA, and CARF datasets

Any gaps in data capture or classification during 2026 are likely to surface quickly once exchanges commence in 2027.

Supporting CRS 3.0 Readiness with Tax Data Exchange (TDE)

As CRS 3.0 comes into effect and reporting requirements expand in 2026 and 2027, many firms are reassessing how efficiently they can capture, validate, and exchange tax data across multiple regimes.

Tax Data Exchange (TDE) is designed to support this evolving landscape by helping organisations manage:

• CRS and FATCA data in line with updated OECD schemas

• Increased data volumes and validation requirements

• Alignment between CRS 3.0 and parallel frameworks such as CARF

By providing a structured and automated approach to tax data exchange, TDE can help reduce reliance on manual processes, improve data consistency, and support ongoing compliance as transparency standards continue to develop.

As international reporting frameworks become more interconnected, having the right infrastructure in place will be increasingly important in managing both regulatory risk and operational complexity.