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HMRC internal manual

International Exchange of Information Manual

Financial Institutions: Non-Participating Financial Institutions

Financial Institutions: Non-Participating Financial Institutions


A Non-Participating Financial Institution (NPFI) is a Financial Institution that is not FATCA compliant.  This non-compliance arises either where:

  • the Financial Institution is located in a jurisdiction that does not have an Intergovernmental Agreement with the US and the Financial Institution has not entered into a FATCA agreement with the US that requires direct reporting of information to the IRS, or,


  • the Financial Institution is classified by the IRS as being a NPFI following the conclusion of the procedures for significant non-compliance being undertaken [see IEIM405040]. In this case a UK Financial Institution will only be classed as an NPFI where there is significant non-compliance with the UK legislation and, after a period of enquiry, that non-compliance has not been addressed to HMRC’s satisfaction.  In such circumstances the UK Financial Institution’s details may be published electronically by the IRS and the Financial Institution will cease to be covered by the Agreement.


Reporting Financial Institutions that make payments to NPFIs will have reporting obligations in respect of the 2015 and 2016 reporting periods. [see IEIM402360]