CRS 2.0 Explained: The Amended CRS, CARF and DAC8 for Crypto

CRS 2.0 is the informal name for the OECD's amended Common Reporting Standard, the global rulebook under which banks and other financial institutions report foreign account holders to tax authorities. The update brings e-money, central bank digital currencies, derivatives that reference crypto-assets and funds that invest in crypto-assets into scope, adds new data fields, and is designed to sit alongside the separate Crypto-Asset Reporting Framework (CARF), which covers crypto exchanges and brokers directly.

In the EU and the UK, CRS 2.0 has applied since 1 January 2026, so the first reports, covering calendar year 2026, are due in 2027. Other jurisdictions, such as the UAE, start a year later. This guide explains what changed, how CRS 2.0 relates to CARF and the EU's DAC8, the dates that matter, and what it means for platforms and for you.

What is CRS 2.0?

The Common Reporting Standard was adopted in 2014 as a global framework for reporting financial account information and exchanging it automatically between tax authorities every year, as PwC's summary of the amendments puts it. A bank in one country collects the tax residence of its customers, reports accounts held by foreign residents to its own tax authority, and that authority passes the data to the customer's home country.

By the early 2020s the standard had a gap. Money was moving into e-money wallets, crypto-assets and crypto-linked products that the original CRS did not clearly capture. The OECD's answer was a two-part package. The first part is CARF, a new standard for crypto-asset service providers, which we cover in our CARF guide. The second part is a set of amendments to the CRS itself, which practitioners call CRS 2.0.

Both parts were approved by the OECD on 26 August 2022, according to the recitals of the EU's Council Directive (EU) 2023/2226 (DAC8). The OECD published the CRS amendments on 10 October 2022 (PwC) and released the full package with commentary, titled "Crypto-Asset Reporting Framework and 2023 update to the Common Reporting Standard", on 8 June 2023 (DAC8 recitals).

What CRS 2.0 adds

The amendments do two things: widen what counts as a reportable account, and make each report more detailed. The main changes, drawn from PwC's breakdown and the EU's implementing text in DAC8, are below.

Two other changes matter to ordinary account holders. First, if you are tax resident in two countries, the revised commentary says you should self-certify every jurisdiction of residence and be treated as resident in all of them. Tie-breaker rules can no longer be used for self-certification once the changes take effect (PwC). Second, institutions may not rely on a self-certification they know, or have reason to know, is unreliable, and they should consider the OECD's list of potentially high-risk citizenship-by-investment and residence-by-investment schemes when making that judgement.

How CRS 2.0 fits with CARF and DAC8

The split depends on who holds the asset and what kind of asset it is.

• CARF makes crypto-asset service providers, such as exchanges, brokers and some custodial wallet providers, report their users' crypto transactions. Our CARF explainer covers who counts and what is reported.
• CRS 2.0 keeps covering traditional financial accounts and now adds e-money, CBDCs, crypto derivatives in custodial accounts and crypto-investing funds.
• DAC8 is the EU's legal vehicle for both. Directive (EU) 2023/2226 adds CARF-style crypto reporting in a new Annex VI and rewrites the existing EU version of the CRS to include the 2023 amendments. See our DAC8 guide for the crypto side.

The frameworks are built to avoid reporting the same thing twice. Under the EU text, a financial institution does not have to report the gross proceeds from selling or redeeming a financial asset under the CRS rules to the extent it already reports those proceeds under the crypto rules, unless it elects otherwise for a clearly identified group of accounts (DAC8, Annex I).

The boundary between e-money and crypto-assets also matters. In DAC8, a "Reportable Crypto-Asset" excludes CBDCs and electronic money, but the directive's recitals say the general understanding of crypto-assets includes stablecoins, "including e-money tokens" as defined under MiCA. A bank or e-money firm that also offers crypto services may therefore sit under both regimes for different products.

CRS 2.0 implementation dates by jurisdiction

The OECD sets the standard, but each jurisdiction must put it into domestic law and sign up to exchange the extra data. The legal basis for the exchange is an Addendum to the CRS Multilateral Competent Authority Agreement. The OECD's signatory list shows 83 jurisdictions had signed it as of 1 October 2026, including the UK, Switzerland, the UAE, Singapore, Japan, Canada and the Cayman Islands. The United States does not appear on the list; it runs its own reporting regimes instead.

• European Union: Member States had to transpose DAC8 by 31 December 2025 and apply it from 1 January 2026 (Article 2 of Directive 2023/2226). Accounts that fall under the CRS only because of the new rules count as new accounts if opened on or after 1 January 2026, so 2026 is the first reporting year and the first reports are exchanged in 2027. Crypto data under DAC8 must be exchanged within nine months of the end of the calendar year.
• United Kingdom: The International Tax Compliance (Amendment) Regulations 2025 apply CRS 2.0 from 1 January 2026 and bring e-money institutions into scope. The first CRS 2.0 reports, covering 2026, are due by 31 May 2027, the same deadline as the UK's first CARF reports (Grant Thornton UK, 1 July 2026).
• Switzerland: The Federal Council said the amended automatic exchange law and ordinance, covering both the CRS update and CARF, were due to take effect on 1 January 2026. Because parliament paused work on the list of CARF partner states, it decided the crypto-asset provisions would not apply in 2026, with CARF implementation "in 2027 at the earliest" (Federal Council, 26 November 2025).
• United Arab Emirates: The UAE Ministry of Finance announced that CRS 2.0 will be effective on 1 January 2027, with the first exchange in 2028, aligned with its CARF timeline (Aletihad / WAM, 8 November 2025).

So when you see "2027" next to CRS 2.0, it usually means one of two things: the year of the first exchange for early adopters such as the EU and UK, or the first reporting year for later adopters such as the UAE.

What changes for exchanges, e-money firms and brokers

For firms, CRS 2.0 is mostly an onboarding and data problem: customer data collected in 2026 feeds the 2027 reports.

• E-money and payment apps that hold e-money for customers can now be depository institutions. They need tax residence self-certifications from customers, and must monitor the USD 10,000 rolling-average threshold.
• Brokers offering crypto derivatives, such as contracts for difference on crypto-assets held in custodial accounts, must apply CRS due diligence to those accounts.
• Crypto funds and managers may now be investment entities and need to classify themselves and their investors.
• Firms under both regimes have to decide how to use the duplicate-reporting relief, and keep CRS and CARF self-certifications consistent.

Penalties are getting sharper. In the UK, failing to register can cost up to £1,000 plus £300 a day, failing to obtain a valid self-certification up to £300 per instance, and late or missing reports up to £5,000 plus £600 a day. HMRC has indicated it may not charge penalties in the first two reportable periods where firms took all reasonable steps (Grant Thornton UK).

AML onboarding runs in parallel; see our AML guide for VASPs.

What CRS 2.0 means for you as a user

For most users, CRS 2.0 shows up as more forms.

1. Expect self-certification requests. E-money apps, brokers and exchanges may ask for your tax residence and taxpayer identification number, sometimes for both CRS and CARF at once. Answer accurately: a firm cannot rely on a form it has reason to doubt.
2. Declare every country of residence. Under the revised commentary, dual residents should list all jurisdictions, and the account may be reported to each of them.
3. Larger e-money balances become visible. If an e-money account's rolling 90-day average stays above USD 10,000, it can be reported to your home tax authority like a bank account.
4. Crypto exposure through products is covered too. Crypto derivatives in custodial accounts and stakes in crypto-investing funds fall under CRS 2.0, while direct crypto trades on exchanges fall under CARF or DAC8.

What CRS 2.0 does not do is reach a self-custody wallet with no intermediary. Holding tokens in your own wallet, or using non-custodial DeFi such as liquid staking for JWLSUI, JWLEGLD or JWLXRD on JewelSwap, does not create a CRS account. Your tax obligations on gains and income are unchanged, and the exchanges you use to move in and out will report under CARF where it applies. US taxpayers have a separate system; see our guide to Form 1099-DA.

Frequently asked questions

What is CRS 2.0?

CRS 2.0 is the informal name for the OECD's amended Common Reporting Standard. It extends automatic tax reporting to e-money, central bank digital currencies, crypto-linked derivatives in custodial accounts and entities that invest in crypto-assets, and adds new data fields such as joint-account and self-certification status.

When does CRS 2.0 start?

It depends on the jurisdiction. The EU and the UK apply it from 1 January 2026, so first reports covering 2026 are filed and exchanged in 2027. The UAE has announced 1 January 2027, with first exchanges in 2028.

What is the difference between CRS 2.0 and CARF?

CARF makes crypto-asset service providers, such as exchanges and brokers, report their users' crypto transactions. CRS 2.0 covers financial institutions and accounts, including e-money, CBDCs, crypto derivatives and crypto-investing funds. Rules are built in to limit duplicate reporting between them.

How do CRS 2.0, CARF and DAC8 relate?

CARF and the CRS amendments are the two OECD standards approved in August 2022. DAC8, Council Directive (EU) 2023/2226, is how the EU implements both, adding crypto reporting and updating the EU version of the CRS from 1 January 2026.

Does CRS 2.0 apply to self-custody wallets or DeFi?

No. CRS 2.0 applies to accounts held with financial institutions. A self-custody wallet with no intermediary is not a CRS account, although your own tax obligations still apply and exchanges may report your transactions under CARF.

Is the United States part of CRS 2.0?

The United States does not appear on the OECD's list of signatories to the Addendum to the CRS Multilateral Competent Authority Agreement. It uses its own reporting rules, including Form 1099-DA for crypto brokers.

Keep reading

• CARF explained: the Crypto-Asset Reporting Framework
• DAC8 crypto reporting explained
• Form 1099-DA for crypto
• Crypto custody explained

Disclaimer: this article is educational and is not financial, tax or legal advice. Implementation dates and signatory counts are as of 17 October 2026 and can change; check your own tax authority's guidance. Sources are linked throughout.