What CRS reporting is
The Common Reporting Standard is the OECD's rulebook for sharing financial account data between tax authorities. Banks, custodians, brokers, investment funds and insurers that sell cash-value policies collect each customer's tax residence, report the accounts of residents of partner countries to their own tax authority, and that authority sends the data on to the country where the customer lives (OECD consolidated CRS text, 2025). Nobody has to ask for it: the exchange is automatic.
Exchanges run once a year, a year behind: data on the 2024 calendar year was exchanged in 2025, as the OECD's table of exchanges as of May 20, 2026 sets out year by year.
CRS follows tax residency as each country's law defines it, not citizenship and not the place where the account sits. A Portuguese citizen who lives in Georgia and keeps an account in Spain is reported to Georgia, because Georgia is where she is resident and Spain has an activated exchange with Georgia.
What a CRS report contains
Section I of the standard lists the fields (OECD consolidated CRS text). For each reportable account the bank sends:
- Your name, address, every jurisdiction where you are tax resident, your tax identification number (TIN) in each, and your date and place of birth
- Whether you gave a valid self-certification, and whether the account is joint
- The account number and type, and the bank's name and number
- The balance at the end of the year, or at closing if you closed the account
- Gross interest on a deposit account; gross interest, dividends, other income and sale proceeds on a brokerage account
- For a company or trust account, the same details for each controlling person and their role
The self-certification flag, joint-account details, account type and controlling persons' roles came with the OECD's 2022 amendments (OECD consolidated CRS text) and apply from the 2026 reporting year in most CRS jurisdictions, so reports sent in 2026 on 2025 data lack them.
An account with a zero or negative balance stays reportable and goes in as zero, so moving money out before December 31 does not take the account out of the report (OECD consolidated CRS text). Place of birth is sent only where local law already makes the bank collect it, and the TIN can be left out where your country issues none.
| Account holder's residence | Portugal |
|---|---|
| Bank's jurisdiction | Spain |
| Balance on December 31, 2025 | €48,200 (about $54,800) |
| Gross interest paid in 2025 | €1,130 (about $1,290) |
| Sent to Portugal | In 2026 |
Invented figures. The report itself charges no tax: Portugal compares it with what the holder declared.
Which accounts are reported, and the thresholds
The standard covers deposit accounts (current, savings and time deposits), custodial accounts at brokers and custodians, equity and debt interests in investment funds and similar entities, and cash-value life insurance and annuity contracts (CRS Section VIII). A loan or mortgage you owe the bank is not one of these account types, and regulated, tax-favored pension accounts that report to the tax authority, restrict early withdrawals and cap contributions at $50,000 a year or $1,000,000 for life are excluded (CRS Section VIII).
CRS thresholds. Source: OECD consolidated CRS text (2025), Sections III, V and VIII.
| Account | Threshold | What it means |
|---|---|---|
| New personal account | None | Reportable from the first dollar |
| Older personal account | $1,000,000 | Above it, a relationship manager check and, where electronic records are incomplete, a paper search |
| Older company account | $250,000 | Review may wait until the balance passes it |
| E-money balance (amended CRS) | $10,000 | Excluded while the 90-day average stays at or under it |
| Regulated pension account | $50,000 a year or $1,000,000 for life | Excluded when contributions are capped at these and withdrawals are restricted |
How the bank decides where you are tax resident
For a new account the answer is your self-certification: a signed form, usually part of the account opening pack, naming every country where you are tax resident and your TIN there. The general rule is that the bank collects it on the day the account opens, and the OECD names making account opening conditional on a valid form as an effective way to enforce it (OECD consolidated CRS text).
The bank then checks the form against what it collected for anti-money-laundering purposes, mainly your ID and address, and it cannot rely on a form that conflicts with its own records. A virtual mailbox address abroad counts as a mailing address like any other, and on older accounts an address in a country, or a phone number there with none in the bank's country, is treated as a sign of residence there until you document otherwise.
Every bank in a CRS jurisdiction asks the same question, whichever bank you pick as a digital nomad, because the duty comes from the law of the bank's country. When you move and become resident somewhere else, the bank cannot keep relying on the old form and must obtain a new one.
Before you sign a CRS self-certification
- List every country where you are tax resident this year under that country's own law, not the country on your passport.
- Find your TIN for each one. If a country issues none, say so on the form; the standard allows it.
- Give a residence address that matches your ID and proof of address. A mismatch makes the bank stop and ask.
- Recertify as soon as you move: once the bank knows, it has 90 days to get a new form, and without one it treats you as resident in both the old and the new country and reports you to both (CRS commentary on Section IV, paragraphs 14 and 15).
- Answer recertification letters by their deadline: an account the bank cannot document is one route to a frozen bank account abroad.
CRS for digital nomads: no residence, 2 residences or a residence by investment
If you claim no tax residence anywhere
The form lets you say you have no residence for tax purposes, but the bank must test that answer against its records. An address on file is itself a reason to doubt it, and without a reasonable explanation and documents the bank must get a new, valid self-certification (CRS commentary on Section IV, paragraph 25bis). A perpetual traveler whose parents' address is still on the account should expect that conversation.
Whether you truly have no residence is a question of each country's law, which the bank cannot settle for you, and the answer drives how digital nomads are taxed far more than any bank form does.
If you are resident in 2 countries
Under the original rules a dual tax resident may use a tax treaty's tie-breaker to name 1 country. Once the amended CRS applies, a dual resident who signs a new self-certification cannot rely on tie-breakers and must declare every jurisdiction of residence, and the full balance and income are reported to each (OECD consolidated CRS text).
If your residence comes from an investment program
The OECD flags residence and citizenship schemes that offer a personal income tax rate under 10% on offshore financial assets without at least 90 days of presence. Its current list names 3 Panamanian permits: the Reforestation Investor Permit, the Economic Solvency Permit and the Friendly Nations Permit, whose ID cards carry the codes PRP-FOR, PRP-SEP and PRP-PA.
A bank shown one of those cards should not rely on the self-certification until it has asked more: did you get residence through an investment scheme, do you hold residence anywhere else, did you spend more than 90 days in another country last year, and where did you file tax returns (same OECD page). Living in Panama for real passes these questions; a Panamanian ID card with a life elsewhere is what they are written to catch.
The same nomad, 2 self-certifications
Holds
Marta moved from Germany to Georgia in March 2025, rents an apartment in Tbilisi, spends most of the year there and holds a Georgian tax residence certificate. She certifies Georgia with her Georgian TIN and updates her address. Her Spanish brokerage account is reported to Georgia.
Fails
Marta keeps her Berlin address on file, ticks "no tax residence" and gives no TIN. The bank sees a German address, cannot rely on the form and asks for an explanation, and Germany is the country its own records point to.
Company and trust accounts: the look-through rule
A company account is reported under the company's own residence. If the company meets none of the active tests, the main one being less than 50% passive income and less than 50% passive assets, it is a passive entity, and the bank also reports the people who control it to their own countries of residence (CRS Section VIII).
Control usually means an ownership stake above a risk-based threshold, with 25% as the OECD's own example; failing that, control by other means, then the senior managing official (CRS commentary on Section VIII). For a trust, the settlor, trustees, protector and beneficiaries are all controlling persons.
That is why an offshore company holding investments does not take the money out of CRS: the bank looks through it to you. A professionally managed investment company based outside CRS is treated as passive whatever its income.
An active trading company, such as a consultancy that invoices clients, is reported under its own residence only. When you compare business accounts that accept non-resident owners, expect each bank in a CRS country to ask for the company's tax residence, its active or passive status and who controls it: that entity form is the CRS self-certification.
CRS countries: which jurisdictions exchange data
By November 20, 2025, 116 jurisdictions had started exchanging (Global Forum annual report 2025). The OECD's status of commitments, last updated September 30, 2026, puts 49 jurisdictions in the 2017 group, among them every EU member except Austria, the UK and its crown dependencies, the Cayman Islands, Mexico and India, and 51 in the 2018 group, among them Austria, Switzerland, Singapore, Hong Kong, the UAE, Panama, Canada, Australia and Japan. Commitments for 2019 to 2025 ran at 2 to 5 a year, Georgia among the 4 for 2024. Cabo Verde, Mongolia and Papua New Guinea are due to start by 2027 and 6 more, Paraguay among them, by 2028, and Morocco is expected by 2028 at the latest.
Taking part does not mean exchanging with everyone. Each pair of countries has to activate its exchange, and the OECD's table of activated relationships lists 10,413 sending-to-receiving links as of October 2026. Of the jurisdictions in it, 24 send data but receive none, among them the United Arab Emirates, the Cayman Islands, the Bahamas, Bermuda and Qatar.
Selected jurisdictions nomads bank in. Activated links: OECD table, October 2026. Sent in 2025: OECD exchanges table, May 20, 2026. First exchange: OECD status of commitments, September 30, 2026.
| Jurisdiction | First CRS exchange | Activated links: sends to | Activated links: receives from | Sent data to in 2025 |
|---|---|---|---|---|
| Portugal | 2017 | 94 | 119 | 90 |
| Spain | 2017 | 95 | 119 | 90 |
| Malta | 2017 | 95 | 120 | 85 |
| Cyprus | 2017 | 93 | 117 | 89 |
| Mexico | 2017 | 84 | 108 | 80 |
| Switzerland | 2018 | 93 | 116 | 83 |
| Singapore | 2018 | 93 | 117 | 86 |
| Hong Kong | 2018 | 89 | 108 | 84 |
| Panama | 2018 | 92 | 108 | 87 |
| United Arab Emirates | 2018 | 93 | 0 (sends only) | 81 |
| Thailand | 2023 | 74 | 84 | 67 |
| Georgia | 2024 | 75 | 83 | 44 |
| Armenia | 2025 | 66 | 74 | 21 |
The volume has grown fast: data on 171 million accounts worth nearly €13 trillion (about $14.8 trillion) moved in 2024, against 47 million accounts in 2018 (Global Forum annual report 2025).
The non CRS countries are the United States, late joiners such as Jordan and Montenegro that have not exchanged yet, and 42 developing countries that have not set a date (OECD status of commitments). An offshore bank account in Switzerland, Singapore, the Cayman Islands or Panama is reported like any other: in 2025 each of these sent data to between 83 and 87 partners (OECD exchanges table, May 20, 2026).
The US and CRS: FATCA instead
The United States has not signed the CRS multilateral agreement (OECD list of signatories) and has exchanged under its own law, FATCA, since 2015 (OECD status of commitments).
FATCA follows US status rather than residence: it requires banks outside the US to report on accounts held by their US account holders (IRS FATCA page). A US citizen living abroad can therefore be reported to the IRS under FATCA and to their country of residence under CRS, which is why banks ask whether you are a US person and look for signs of a US connection.
A US company is a common route for non-residents who want card payments through a US processor. Its account at a US bank sits outside CRS; its accounts at banks in CRS countries do not, and those banks document the company like any other entity.
CRS 2.0: what the amended rules add from 2026
In most CRS jurisdictions the amended CRS applies from the start of 2026, the reference year for exchanges in 2027, and adds digital money products, more detailed reporting and clarified due diligence. The Global Forum counts 84 jurisdictions planning to exchange under the amended rules in 2027, while 40 intend to use a transition of 1 to 3 years (Global Forum annual report 2025).
For nomads the change that matters is e-money. A balance held as e-money rather than as a bank deposit becomes a deposit account for CRS, excluded only while its rolling 90-day average stays at or under $10,000 on every day of the year (CRS Section VIII). Balances in popular multi-currency apps that are held as e-money fall in scope once the provider's country applies the amended rules.
Crypto gets its own system: by November 20, 2025, 73 jurisdictions had committed to the Crypto-Asset Reporting Framework, the first of them exchanging in 2027 (Global Forum annual report 2025).
Does CRS mean you owe more tax?
No. CRS moves information; it sets no rate and withholds nothing. Your tax depends on where you are resident and what that country taxes, so the legal ways to pay less tax all change your residence or how you hold your income, never what the bank reports. The report only lets the tax authority check your return against what your foreign bank says.
Tax authorities do use it: 93% of jurisdictions answering the Global Forum's survey use CRS data in audits, 83% in risk assessments and 54% to recover revenue, and 34% write to taxpayers about discrepancies (Global Forum annual report 2025).
David's note
I fill in a CRS form as if the tax authority will read it, because it will. If the country you would tick on the bank form is not the one you would defend on a tax return, the problem is your residence, not the bank, and that is the thing to fix first.
