IEIM400970 - Non-Reporting Financial Institutions: Qualified Credit Card Issuers
NRFI: Qualified Credit Card Issuers
Qualified Credit Card Issuers (QCCI) are Non-Reporting Financial Institutions (NRFI) for both regimes.
A QCCI is an entity that:
• is a Financial Institution solely because it is an issuer of credit cards that accepts deposits only when the customer makes a payment in excess of the outstanding balance on the card due and does not immediately return the overpayment to the customer; and
• implements policies and procedures either to prevent a customer deposit in excess of $50,000 or to ensure that any customer deposit in excess of $50,000 is refunded to the customer within 60 days.
To qualify as a NRFI the policies and procedures need to be in place before the date from which the due diligence procedures under each regime come into effect. This is 30 June 2014 for the FATCA and 31 December 2015 for CRS.
From 16 July 2025, a UK Financial Institution can meet the definition of QCCI for a reporting period provided that it meets the requirements set out in the CRS Section VIII(B)(8) and has implemented the required policies and procedures by the end of the calendar year before the start of that reporting period.
Example
A UK credit card issuer meets the requirements set out in the CRS Section VIII(B)(8)except that the required policies and procedures were not implemented until the calendar year 2025. For the reporting years before 2026, the Financial Institution does not meet the conditions to be a QCCI. However, since the policies and procedures were in place by the end of the calendar year 2025, the Financial Institution does meet the conditions to be a QCCI for the reporting year 2026.
Where a Financial Institution is not a QCCI within this definition but issues credit cards or electronic money as part of its business, the financial accounts that result may not be reportable if they meet the conditions to be an excluded account [see IEIM401720].