IEIM405101 - CRS 2.0 Compliance: Initial Period
CRS 2.0 Compliance: Initial Period
CRS2.0 brings new Financial Institutions into scope and covers new types of financial products. HMRC understands that some Financial Institutions may face difficulties in meeting these new reporting obligations. Therefore, HMRC will take a ‘soft landing’ approach to penalties in the initial period of CRS2.0 implementation.
This means that for the first two reportable periods, if a Financial Institution has failed to meet their reporting obligations in respect of the new requirements of CRS2.0, HMRC may establish contact with them to understand the reasons for the failure. If the Financial Institution can demonstrate that they have taken all reasonable steps to comply a penalty may not be charged.
After the initial period, Financial Institutions should generally have had sufficient time to become familiar with the requirements of the new rules and develop their systems to comply. The expectation is therefore that Financial Institutions can then report accurate information in a timely manner.