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HMRC internal manual

International Exchange of Information Manual

Non-Reporting Financial Institutions: Introduction

Non-Reporting Financial Institutions (NRFI)

All the automatic exchange of information regimes exclude certain Financial Institutions from being Reporting Financial Institutions. Such Financial Institutions are not required to identify, collect or report information about Reportable Persons.

These institutions are identified in Annex II of the IGA with the USA for FATCA purposes and Annex II of the IGAs with the Crown Dependencies and Gibraltar for CDOT reporting.

For the CRS and the DAC the only Non-Reporting Financial Institutions are those specifically defined in Section VIII Paragraph B of the Standard and Annex I of the Directive respectively. The UK has not defined in domestic law any Financial Institutions excluded by reference to Sub-paragraph B (1)(c) of Section VIII of the CRS or the DAC (Low-risk Non-Reporting  Financial Institutions).

There are a number of differences between the regimes in this respect. The guidance that follows shows which Non-Reporting Financial Institutions are common to all regimes and which are specific to particular regimes.