IEIM401875 - Financial Accounts: Excluded Accounts: Low value Specified Electronic Money Products
Excluded Accounts: Low value Specified Electronic Money Products
From 1 January 2026, the definition of Depository Account is expanded to include an account or notional account that represents all Specified Electronic Money Products (SEMPs) held for the benefit of a customer. However, there is a threshold that must be applied to determine whether such SEMPs are reportable or Excluded. Where the value of the account or notional account falls below the threshold, the SEMPs are Excluded Accounts and are not reportable.
The threshold is mandatory. SEMPs that are Excluded Accounts must not be reported.
A Depository Account representing all SEMPs of an Account Holder is Excluded if a rolling average 90 day end-of-day aggregate account balance or value during any period of 90 consecutive days did not exceed the equivalent of USD 10,000 at any day during the calendar year or other appropriate reporting period.
The requirement to monitor the end-of-day aggregate account balance or value starts from 1 January 2026, so that the first 90 day rolling average calculation will be 31 March 2026.
The fact that an account representing all SEMPs of an Account Holder exceeds the threshold and is reportable for a reporting period does not prevent the account from being Excluded in subsequent reporting periods.
The rolling average 90 day end-of-day account balance or value during a period of 90 consecutive days must be determined for every day and is obtained on a particular day by adding the end-of-day account balance of each of the last 90 consecutive days and then dividing the sum obtained by 90.
Example:
A Depository Account representing all Specified Electronic Money Products of an Account Holder is created on 12 October 2026. The end-of-day account balance or value is USD 10 over the remaining 81 days of 2026 (i.e. 12 October to 31 December 2026), and USD 100,000 over the first 9 days of 2027 (i.e. 1 January to 9 January 2027). The rolling average 90 day end-of day account balance or value during this period of 90 consecutive days is (10*81) + (100,000*9) = 900,810/90, i.e. USD 10,009. Therefore, the threshold is exceeded on 9 January 2027 and the Depository Account is not an Excluded Account as of that day.
The Depository Account is an Excluded Account in respect of the calendar year 2026, because the threshold was not exceeded on any day during 2026. It will be subject to CRS reporting in respect of the calendar year 2027.
If the rolling average 90 day end-of day account balance or value does not exceed the threshold on any day in 2028, then the account will not be reportable for the calendar year 2028.