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)
- 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)
- 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
- 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.
- Mark your calendar: ensure registration by 31 December 2025 or 31 January of the relevant year.
- Prepare required information: structure of entity, jurisdictions, regulatory status, contact persons.
- Register using HMRC-specified form/directions—don’t assume generic forms work for this purpose.
- Update internal processes: ensure account opening, customer due diligence, ongoing monitoring align with CRS/FATCA.
- 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.