The answer “this country does or does not participate in the CRS” almost never solves the client’s problem. You need to check tax residency, account type and structure, specific pair of jurisdictions, FATCA, exchange on request and internal declaration obligations.
- The CRS is an annual exchange between tax authorities and is not a public register of accounts.
- In 2024, CRS transmitted information about more than 171 million financial accounts.
- Participation in the system does not yet prove an exchange with a specific country: the activated bilateral relationship is verified.
- The absence of CRS does not cancel FATCA, AML/KYC, exchange on request and self-declaration.
01
What is CRS
The Common Reporting Standard is a standard developed by the OECD for the automatic exchange of information on financial accounts. The financial institution determines the tax residence of the client, collects the data required by the standard and transmits it to its tax authority. The competent authorities then exchange information on current international relations.
The CRS does not impose tax or determine residency. These issues are determined by the country's domestic laws and applicable tax treaty. Bank self-certification is an important document, but not a universal conclusion about the client’s status.
02
System scale in 2026
According to the Global Forum, by November 20, 2025, 116 jurisdictions had already begun exchanges, with another 12 committed to begin them by 2027. In 2024, information on more than 171 million financial accounts was automatically transmitted. In May 2026, the OECD reported that 130 of the 173 Global Forum members had committed to begin exchanging by a certain date, and nearly 120 were actually exchanging jurisdictions.
The numbers refer to different cut-off dates and show the development of the system.
03
What information is transmitted
For an individual, name, address, tax residence jurisdictions, tax numbers, date and place of birth are usually important. The account's ID, financial institution, closing balance or value, and standard income and receipts amounts are reported for the account.
For a company, fund or trust, the bank first classifies the structure. If it is a passive non-financial entity, the reporting may cover controlling persons. The nominee company therefore does not automatically separate the beneficiary from the CRS analysis.
The discrepancy between the bank application form, residence certificate, address, place of actual management and tax return is often more important than the country of registration of the company.
04
How to read an exchange card
You cannot limit yourself to a general list of “CRS countries”. For each case, the obligation to initiate an exchange, the internal legislation, the activated relationship between the sender and the recipient and the date of its application are checked.
This jurisdiction is usually the originating jurisdiction.
Residence is determined by applicable law, and not solely by citizenship or residence permit.
The OECD Exchange Relationships database shows the direction and legal basis of the exchange.
For a passive organization, controlling persons are analyzed.
05
What does a country outside the CRS mean?
Only that the CRS does not apply to the jurisdiction or the exchange has not yet begun to the appropriate extent. This is not a promise of banking secrecy. Information may be obtained under a tax treaty or exchange procedure upon request. The bank continues to perform AML/KYC, establish the beneficiary, source of funds and tax status.
The responsibility to declare a foreign account, structure, income or CFC often falls directly on the taxpayer. The absence of automatic transmission does not cancel it.
We abandoned the old ranking of “seven confidential countries”: such a list quickly becomes outdated and creates a false impression of guaranteed secrecy.
06
USA and FATCA
The US does not use CRS as its primary system, but does use FATCA. Foreign financial institutions identify and report information about U.S. accounts or work through an intergovernmental agreement. In Model 1, information is transferred to the local authority and then exchanged with the IRS; under Model 2, the institution reports directly to the IRS under the prescribed regime.
Therefore, the phrase “The United States does not participate in the CRS” does not mean that the United States is outside the international exchange of information.
07
Checking the structure before opening an account
- 01
Tax residence of the owner, beneficiaries and controlling persons.
- 02
Classification of a company, fund or trust according to CRS and FATCA.
- 03
Activated exchange relationships between the bank and relevant countries.
- 04
Responsibilities for notification of accounts, CFCs, structures and income.
- 05
Compliance of self-certification with facts and documents.
- 06
Source of capital, economic sense and readiness of the KYC package.
08
Practical conclusion
A working international structure is not built around account concealment, but around provable residency, correct classification, transparent source of funds and consistent reporting. Selecting a country solely on the basis of non-CRS participation usually impairs banking accessibility and does not eliminate legal obligations.
Before opening an account, a personal card is drawn up: who is a tax resident and where, who is considered the owner or controlling person, what information the bank will collect, where it can be transferred and what declarations are submitted independently.