IEIM402183 - Reportable Information: Validity of self-certification: Examples

Validity of self-certification: Examples

Example 1:

A preexisting account opened in 2014 was determined to be reportable to France based on the residence address test. In 2017, the financial institution was advised of a new address in Germany. A self-certification was obtained showing tax residence only in Germany, which passed the reasonableness test but did not include a German TIN. The financial institution has requested the TIN and continues to request the TIN whenever AML/KYC information is updated. The account is reportable to Germany as “true” in the “SelfCert” element of the XML schema. 

Example 2: 

A new account is opened in 2026 with a self-certification showing tax residences in Italy and Spain. The self-certification includes a TIN for Italy but not for Spain. Since Spain is a jurisdiction that issues TINs, and the Account Holder has not provided an explanation for why the TIN is not available, the self-certification is incomplete and therefore invalid. Until the Spanish TIN is obtained, or a reasonable explanation of why the TIN is not available, the account is reportable to both Italy and Spain as “false” in the “SelfCert” element of the XML schema. 

Example 3: 

The same facts as Example 2 above, except that the Account Holder has explained that they only recently moved to Spain and a TIN has not yet been issued. The account is reportable to both Italy and Spain as “true” in the “SelfCert” element of the XML schema.  The Financial Institution should treat the explanation as valid for only 12 months, after which the Financial Institution would have reason to know that the self-certification has become invalid and must obtain the Spanish TIN from the account holder. 

Example 4: 

A self-certification is received from a new individual Account Holder in 2025 showing Ireland as the jurisdiction of tax residence, which is reasonable based on AML/KYC information held by the Financial Institution. However, the entry for the TIN is “123456789”. Whilst the Financial Institution is not required to check the format of the TIN (which is incorrect) the TIN is in any case implausible. The self-certification is not valid and should be reported as “false” in the “SelfCert” element of the XML schema. 

Example 5: 

A lower value Preexisting Individual Account was opened in 2013 and the jurisdiction of tax residence was determined to be France using the residence address test. There has been no change in circumstances so a self-certification has never been required or obtained. The account should be reported as “false” in the “SelfCert” element of the XML schema. 

Example 6: 

An Entity Account was opened in 2024 for an Company incorporated on 1 February 2024. The Financial Institution obtained a self-certification  classifying the Entity as an Active NFE under Section VIII.D(9)(e) of the CRS, as a start upNFE not yet operating a business. On 2 February 2026 it is more than 24 months since the Entity’s incorporation so the Section VIII.D(9)(e) Active NFE status can no longer apply. This is a change in circumstances and the Financial Institution requests the Entity to provide an updated self-certification within 90 days, but receives no response. The self-certification is no longer valid and should be reported as “false” in the “SelfCert” element of the XML schema.