UAE Ministry of Finance announces amendments to the Common Reporting Standard ("CRS 2.0") implementation by 2027

2 minute read
November 24, 2025

In brief

The United Arab Emirates Ministry of Finance (“UAE MoF”) has signed the Addendum to the Multilateral Competent Authority Agreement (“Addendum to the MCAA”) on the Automatic Exchange of Financial Account Information (“AEOI”), reinforcing the country’s commitment to international tax transparency and alignment with Organisation for Economic Co-operation and Development (“OECD”) standards.

The UAE MoF has officially announced the amendments to the Common Reporting Standard ("CRS") adoption by 2027. The CRS 2.0 initiative underscores the UAE’s ongoing commitment to international best practices in automatic exchange of financial account information and the prevention of offshore tax evasion.

In detail

According to the OECD’s list of signatories to the addendum to the MCAA on the AEOI, last updated on 4 November 2025, the UAE MoF signed the addendum to the MCAA—commonly referred to as “CRS 2.0”—on 11 August 2025, thereby committing to commence automatic exchanges of information under the CRS 2.0 by 2028 (in respect of the 2027 calendar year).

The CRS 2.0 is expected to introduce, amongst other aspects, expanded reporting obligations, enhanced due diligence procedures, and alignment with new financial instruments — including crypto-assets and digital financial products.

CRS 2.0 updates include, but are not limited to:

E-money, Central Bank Digital Currencies and crypto-assets inclusion:

As part of the "Depository Account" definition:

Specified Electronic Money Product ("SEMP"): Digital representations of a single fiat currency that are issued on receipt of funds for the purpose of making payment transactions, that are represented by a claim on the issuer denominated in the same fiat currency, that are accepted by a natural or legal person other than the issuer; and that, by virtue of regulatory requirements to which the issuer is subject, are redeemable at par for the same fiat currency upon request of the holder of the product, and Central Bank Digital Currency ("CBDC"): Any official currency of a jurisdiction, issued in digital form by a Central Bank.

As part of the "Investment Entity", "Custodial Institution" and "Financial Asset" definitions:

Relevant Crypto-Asset: a digital representation of value that relies on a cryptographically secured distributed ledger or a similar technology to validate and secure transactions different than a CBDC, SEMP, or any crypto-asset that cannot be used for payment or investment purposes.
Reporting requirements expansion: Additional data elements from the Reporting Financial Institutions ("RFIs") are expected on annual basis.
Due diligence requirements strengthening: More robust requirements for verifying account holder tax residency and controlling persons, temporary alternatives to determine account holders' tax residency are provided, reliance on government verification services, etc.
Expansion of definitions and interpretative guidance incorporation: Amongst others, the following definitions are expanded by the CRS 2.0: "Depository Institution", "Depository Account", "Investment Entity", and "Financial Asset"; the CRS 2.0 includes interpretation to the "Investment Entity" definition by clarifying the terms "business" and "customer"; and, incorporates references to commentary in respect of the frequently asked questions ("FAQs") as a source of interpretation, where required.

Why is it relevant?

The CRS 2.0 represents a significant evolution in global tax transparency, reflecting the OECD’s efforts to enhance compliance effectiveness and address the transformation of the financial system over the past decade (e.g., e-money platforms, digital payment providers, and central bank digital currencies CBDCs, etc.), which has created gaps in the existing CRS framework. The CRS 2.0 updates will:

Bring in-scope UAE businesses previously not impacted by the Common Reporting Standard ("CRS").
Increase reporting complexity and potentially broaden the reportable population of account holders;
Require IT and compliance upgrades to accommodate new data fields and digital asset classifications;
Increase regulatory scrutiny from UAE regulatory authorities to assess compliance levels.

Aligning with the CRS 2.0 framework will be critical for RFIs and newly impacted UAE businesses to implement the necessary modifications throughout 2026, in preparation for the go-live date in 2027.

Suggested next steps

Existing RFIs under the existing CRS should consider the following:

Conduct a comprehensive gap assessment to identify areas of opportunity that require attention ahead of the go-live date in 2027,
Identify synergies with ongoing compliance initiatives (such as Foreign Account Tax Compliance Act ("FATCA") or CRS) to achieve an unified implementation project during 2026, and
As one of the main amendments of the CRS 2.0 relates to the expansion of the reporting data elements, assess current technology platforms to identify potential system gaps in due diligence, data management, and reporting.

UAE businesses that are not currently in scope of the CRS should consider the following

Conduct an impact assessment to determine whether your business falls within the CRS 2.0 scope, and
For impacted UAE businesses, a comprehensive implementation plan for 2026 should be prepared including, but not limited to, developing a governance framework, updating onboarding documentation and monitoring controls, and technology to manage and report data.

Download Alert