Non CRS Countries: Who Does Not Exchange Bank Account Data

Which countries are not in CRS

Under the Common Reporting Standard, banks report accounts held by foreign tax residents to their own tax authority, which passes the data to the account holder's country of residence once a year. A non-CRS country is one whose banks do not report under it, or whose tax authority does not exchange the data yet.

The OECD keeps the list. Its status of commitments, updated September 30, 2026 names 131 jurisdictions with a committed year for their first exchange and 42 developing countries that were not asked to commit and have not set a date. Jurisdictions on none of the OECD's lists are outside CRS too: the status of commitments does not include US territories such as Puerto Rico, Guam, the US Virgin Islands and American Samoa, or countries such as Iran, Cuba, Venezuela, Bolivia, Bangladesh and Kosovo, none of which has a CRS commitment on the OECD's record. The groups below cover every jurisdiction that does not exchange yet.

Nauru and Niue are a special case: both committed, but the OECD's table of exchanges records that no reporting financial institutions are located there, so they have nothing to send. Russia is another: it committed for 2018 and sent data to 69 partners in 2021, but the same table shows no data for it for exchange years 2022 to 2025.

The United States: FATCA instead of CRS

The United States is the largest economy outside CRS: it is not among the 126 signatories of the CRS multilateral agreement listed on March 13, 2025 (OECD list of signatories), and it has exchanged under FATCA and its intergovernmental agreements since 2015 instead (OECD status of commitments).

Outside CRS is not the same as unreported. US banks report to the IRS the deposit interest they pay to nonresident aliens who live in countries on the IRS's list of tax information exchange partners, countries the US has agreed to provide information to as well as receive it from (26 CFR 1.6049-8). Where a reciprocal Model 1A FATCA agreement is in force, the US also sends that partner data on deposit accounts held by individuals resident there that earn more than $10 of interest in a year (US Treasury, reciprocal Model 1A agreement).

A US citizen gains nothing from the US being outside CRS either: FATCA makes banks outside the US report their US account holders, and US persons report their own foreign assets, depending on their value, on FATCA Form 8938 (IRS FATCA page).

Countries committed to CRS but not exchanging yet: Montenegro, Jordan, Paraguay

Jordan and Montenegro both committed to start exchanging in 2023, and the OECD's table of exchanges still lists their domestic and international legal frameworks as not fully in place (OECD table of exchanges, May 20, 2026). Trinidad and Tobago committed for 2018 and had still not started by September 30, 2026 (OECD status of commitments); in May 2026 the OECD's table of exchanges recorded its plan to start in 2026. For anyone weighing Montenegro as a tax residence, that means its tax authority receives no CRS data yet on their accounts abroad.

Morocco committed to start in 2025 but has not exchanged, and the OECD now expects it to start by 2028 at the latest; Senegal, also due in 2025, has not started either (OECD status of commitments). Cabo Verde, Mongolia and Papua New Guinea are due in 2027, and 6 more in 2028, including Paraguay, a territorial-tax residence.

Developing countries with no CRS start date

Developing countries that do not host a financial center were not asked to commit to a specific date for their first exchange, and some have set one voluntarily (OECD status of commitments, note 3). The 42 that have not set one include Egypt, Guatemala, North Macedonia, Serbia, Sri Lanka, Uzbekistan and Vietnam.

Of the countries on the Nomad Tax Index, the Philippines, Serbia and the Dominican Republic sit in this group. Their banks do not report foreign residents' accounts under CRS, and their tax authorities receive no CRS data on their own residents' accounts abroad.

Developing countries in the same position have volunteered dates before: Georgia, Kenya, Moldova and Ukraine did so and joined the 2024 group (OECD status of commitments). The list shortens each time one does.

Send-only jurisdictions: the UAE, Cayman and other non-reciprocal cases

A non-reciprocal jurisdiction sends data but receives none, and the OECD shows its links only in the sending column (OECD exchange relationships). The OECD's table of activated relationships has 24 of them: Anguilla, Antigua and Barbuda, Bahamas, Bahrain, Bermuda, British Virgin Islands, Brunei Darussalam, Cayman Islands, Dominica, Kuwait, Lebanon, Macau, Marshall Islands, Nauru, New Caledonia, Niue, Oman, Qatar, Saint Vincent and the Grenadines, Samoa, Sint Maarten, Turks and Caicos Islands, the United Arab Emirates and Vanuatu. Of these, Nauru and Niue have nothing to send, the OECD marked Lebanon's exchanges as delayed in every year from 2022 to 2025, and Saint Vincent and the Grenadines was delayed in 2025 (OECD table of exchanges).

Where they do send, these places are in CRS for anyone who banks there from abroad. In 2025 the UAE sent CRS data to 81 partners and the Cayman Islands to 84 (OECD table of exchanges), so an account in either is reported to the holder's country of residence whenever that country is one of its partners. What they do not do is receive data on their own residents' accounts elsewhere.

For someone with genuine UAE residence and tax status, that means an account in a CRS country is not reported under CRS, because no CRS country sends data to the UAE. The bank still tests the self-certification against what it knows, and a UAE form from someone whose life is elsewhere is reportable to the country they really live in.

Is it legal to bank in a non-CRS country?

Yes. Holding an account in the United States, Serbia or any other non-CRS country is legal, and CRS has no rule against it. What CRS changes is who receives data, never your tax: your country of residence taxes you under its own law, and declaring foreign accounts and their income is your duty wherever the bank is.

That makes CRS status a poor reason to choose a bank as a digital nomad. Fees, currencies, how the bank treats non-residents and whether it will keep you as a customer when you move matter far more.

E-money is moving into CRS as well. Under the amended CRS, e-money balances count as deposit accounts once their rolling 90-day average passes $10,000 (OECD consolidated CRS text), so balances at e-money providers that are not banks become reportable wherever the provider's country applies the change. Among the multi-currency apps nomads compare, those that hold a banking license already report deposits like any other bank.

How to check a country's CRS status

Beyond the OECD's tables, each country publishes its own lists. In CRS terms, a participating jurisdiction is one that will provide information, and a reportable jurisdiction is one the bank's country must send information to; both must appear on a published list (OECD consolidated CRS text). That is why the lists differ from country to country and year to year.

A country missing from the bank country's participating list is a non-participating jurisdiction, and the label reaches companies. An investment entity resident there that earns mainly investment income and is managed by a financial institution counts as a passive entity, so a bank in a CRS country looks through it and reports the people who control it (OECD consolidated CRS text, Section VIII(D)(8)).

David's note

I would not choose a bank for its CRS start date. Paraguay is due to exchange by 2028, and a country that starts must have its banks review the accounts they already hold, so an account opened today because the country is outside CRS ends up reported like any other.