Cayman Islands Updates Common Reporting Standard Regulations

The Cayman Islands has published amended regulations on the Common Reporting Standard (CRS). The updated rules affect registration and return obligations, as well as due diligence requirements, and also include additional guidance on penalties and digital assets. 

The amended regulations generally enter into force on January 1, 2026, with some provisions entering into force January 1, 2027. 

Registration Obligations for Cayman Financial Institutions

Under the amended regulations, unless exempted, an entity that becomes a “Cayman Financial Institution” within a calendar year must provide by the January 31 following such year notification via a registration form, which must include certain specified information about the institution. A transition rule provides that an entity that became a Cayman Financial Institution in 2025 shall have until April 30, 2026, to submit the registration form.

In addition, if any of the required information changes, the entity must file a notice with details of the change within 30 days after the change occurs. 

Cayman Financial Institutions must also name a principal point of contact in the Cayman Islands for compliance with these rules. By January 31, 2027, Cayman Financial Institution must submit a change form providing notice of the person in the Cayman Islands that the entity has authorized to act as its principal point of contact.

Return and Compliance Form Obligations

Beginning with 2026 reporting due in 2027, Cayman Financial Institutions must make a return for each reportable account that the institution maintained during the year in accordance with the CRS by June 30 of the year following the calendar year to which the return relates. This advances the due date for returns from the current July 31 due date. 

If an institution did not maintain any reportable account in a reportable jurisdiction during the year, the institution should make a nil return for that reportable jurisdiction. 

Beginning with 2026 reporting due in 2027, Cayman financial institutions must also submit by June 30 of each year a compliance form for the previous calendar year. This moves up the due date from the current September 15 due date for compliance forms. 

Required Due Diligence

The amended regulations provide that Cayman Financial Institutions must establish and implement written policies and procedures in compliance with Sections II to VII of the OECD CRS. They further specify that these policies and procedures must: 

1. Identify each jurisdiction in which an account holder or a controlling person is resident for tax purposes;
2. Apply the due diligence procedures set out in Sections II to VII of the CRS;
3. Ensure that valid self-certifications are collected; and 
4. Ensure that any information obtained in accordance with these requirements, or a record of the steps taken to comply with them, with respect of a financial account is kept for at least six years from the end of the year to which the information relates or during which the steps were taken.
   
   

For new accounts, each Cayman Financial Institution must collect a valid self-certification for new accounts on or before the date a financial account is opened. The regulations prescribe specific current information that the self-certifications must include to be valid.