Changes to BVI CRS reporting requirements – June 2025

New requirements set out under the Common Reporting Standards will come into effect from June 2025. 

These new requirements are significant and include an updated Common Reporting Standards (CRS) form and the introduction of a risk rating system.

The requirements apply to all reporting and non-reporting financial institutions registered on the International Tax Authority's British Virgin Islands Financial Account Reporting System (BVIFARS) portal.

Key changes to BVI CRS reporting

Submission of new CRS Form

Beginning June 2025, all reporting and non-reporting financial institutions (FIs) must submit an annual CRS form via the International Tax Authority's (ITA) BVIFARS portal. 

Detailed information

The CRS form is extensive and requests additional information that was not previously required. This additional reporting requires in-depth knowledge of the FI's investor base as well as the CRS procedures for due diligence and reporting. 

Risk assessments

All FIs will be subject to a risk assessment based on responses received from the FIs via information available to the ITA within BVIFARS. On completion of the risk assessment, the FIs will be assigned a risk rating of either low, medium or high. 

Impact of the changes on financial institutions

Comprehensive reporting

FIs must ensure that their reporting includes all the information required by the updated regulations. This includes NIL filings if there are no reportable accounts and full information being filed for all reportable accounts.

Updated CRS policies and procedures

FIs must ensure that they have CRS policies and procedures in place and these must be updated to include the new additional reporting obligations. FIs that fail to establish and maintain CRS policies and procedures may be subject to administrative fines.

Risk ratings

The FI may be subject to reviews conducted by the ITA, based on the risk rating assigned to the FI. FIs that are assigned a medium or high risk rating may be subject to desk-based and onsite inspections.

How Ogier can help

These new requirements necessitate prompt action by all reporting and non-reporting FIs to ensure compliance.

Our BVI legal team can assist clients with updating their CRS policies accordingly. Our corporate and fiduciary experts at Ogier Global offer comprehensive AEOI compliance support.

Please reach out to your usual Ogier contact to find out more. 

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Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

Regulatory information can be found under Legal Notice