Mandatory common reporting for corporate entities

The Common Reporting Standard (CRS) was introduced into UK law around 10 years ago to enable the automatic exchange of information between tax authorities and improve transparency in tax compliance.

Historically, financial institutions only needed to register with HMRC if they had reportable accounts. 

What’s changing?

Under the updated rules, known as CRS2.0, all financial institutions must register with HMRC for the Automatic Exchange of Information (AEOI) — even if they have no reportable accounts. This is a significant change from previous requirements. 

Key points to note:

• Registration is mandatory for any entity classified as a Reporting Financial Institution under CRS or FATCA, including (but not limited to):  
• Banks and custodians 
• Investment managers 
• Certain family trusts with investment income 
• Entities with discretionary fund managers 
• Trustee-Documented Trusts are also within scope. 
• Registration must be completed by 31 December 2025. 
• If there is nothing to report, you are not required to submit nil returns, although you may choose to do so. 

Additional considerations:

• CRS2.0 also expands reporting obligations to include crypto asset service providers under the Crypto Asset Reporting Framework (CARF). 
• Family Investment Companies (FICs) and Personal Investment Companies (PICs) may fall within scope if more than 50% of their income comes from financial assets and those assets are professionally managed. 

What to do

We would strongly recommend registration with the HMRC AEOI as soon as possible. There should be no disadvantage to register if there is any uncertainty about the requirement since it should protect your position. The link can be accessed here.

Information Required for Registration

• Organisation name and lead trustee details 
• Telephone number and email 
• GIIN (Global Intermediary Identification Number) (or 000000.00000.LE.000 if not applicable). You can find out if your trust has a GIIN here.
• UTR (e.g. 1234567890) or other tax identifier 
• Principal business address 

A note on penalties

HMRC can apply penalties if an organisation doesn’t register or report on time. However, as these changes were announced with very little notice, it’s likely HMRC will take a reasonable approach if registration occurs early in 2026. Even so, we recommend completing the registration at your earliest convenience. 

If you have any questions or would like to discuss next steps, please call or email your usual Kreston Reeves contact or get in touch with us directly here.