Compliance
Compliance Guide: Navigating the International Tax Compliance (Amendment) Regulations SI 2025/740
New regulations require many financial institutions to register with HMRC by end-2025—mistakes can lead to penalties. Here's how to stay compliant under the latest rules.
By NomadicTax Research Team • 5-8 min read • November 18, 2025
## What Are the Regulations?
The *International Tax Compliance (Amendment) Regulations 2025* (SI 2025/740) implement obligations under the **Common Reporting Standard (CRS)** and **FATCA**. Among the key changes is regulation **10A**, which requires **reporting financial institutions** (and certain non-reporting ones) to **register with HM Revenue & Customs**. ([legislation.gov.uk](https://www.legislation.gov.uk/uksi/2025/740/regulation/6/made?utm_source=openai))
- Deadline: **31 December 2025**, or by **31 January of the year after** the year in which the institution first becomes subject to CRS or FATCA reporting. ([legislation.gov.uk](https://www.legislation.gov.uk/uksi/2025/740/regulation/6/made?utm_source=openai))
- Registration must follow format/directions given by HMRC.
## Who Needs to Register?
- Reporting financial institutions.
- Specified non-reporting financial institutions under COS/CRS or FATCA definitions.
Examples include banks, investment firms, custodians, some insurance companies. If you provide financial services involving cross-border investment or accounts, check whether the institution classification applies.
## Consequences of Non-Compliance
- Institutions failing to register by the deadline risk sanctions or enforcement action by HMRC.
- Delays or errors in registration may lead to penalties under CRS or FATCA compliance enforcement.
- Misreporting can trigger reputational risks and difficulties in cross-border cooperation agreements.
## Practical Steps to Ensure Compliance
1. **Audit your organisation**: figure out whether you’re a reporting financial institution or a specified non-reporting one, based on the definitions in CRS and FATCA.
2. **Mark your calendar**: ensure registration by **31 December 2025** or **31 January** of the relevant year.
3. **Prepare required information**: structure of entity, jurisdictions, regulatory status, contact persons.
4. **Register using HMRC-specified form/directions**—don’t assume generic forms work for this purpose.
5. **Update internal processes**: ensure account opening, customer due diligence, ongoing monitoring align with CRS/FATCA.
6. **Seek legal/tax advice** if uncertain about status, definitions, or timing.
## Example Scenario
*Global Investments Ltd* operates in two countries. It opens accounts for clients from jurisdictions under CRS. It determines it is a reporting financial institution. It must register with HMRC by **31 December 2025**. If it misses the date and continues operating, it may be liable to financial penalties and possibly complicate its clients’ cross-border tax compliance.
## Key Takeaways
- These regulations tighten up international tax compliance for many financial institutions.
- Missing the registration deadline could lead to significant consequences.
- Clear definitions under CRS and FATCA will affect which institutions are covered.
If you run or work for a financial institution with cross-border clients or funds, confirm your classifications and register in good time.