Compliance
Preparing for Changes to Common Reporting Standard: What Financial Institutions Must Do
Draft amendments to Canada’s reporting requirements under the Common Reporting Standard are open for consultation—this guide helps financial institutions plan for new schema and expanded reporting.
By NomadicTax Research Team • 5-8 min read • November 19, 2025
## What institutions need to know about the CRS amendments
The **Common Reporting Standard (CRS)** is a global framework developed by the OECD for automatic exchange of information between tax authorities to combat tax evasion and avoidance. Canada is rolling out **draft legislative amendments** to CRS and has requested feedback from financial institutions. Under consultations running **October 27 to November 26, 2025**, the CRA seeks input on both revised reporting guidance and updated technical schema.([canada.ca](https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-agency-cra/transparency-proactive-disclosure-canada-revenue-agency/consultations-engagement-canada-revenue-agency/consultation-guidance-related-draft-common-reporting-standard-amendments.html?utm_source=openai))
### Key proposed changes
- Expanded scope of financial account information to better align with the **new OECD CRS schema**.([canada.ca](https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-agency-cra/transparency-proactive-disclosure-canada-revenue-agency/consultations-engagement-canada-revenue-agency/consultation-guidance-related-draft-common-reporting-standard-amendments.html?utm_source=openai))
- Changes to domestic reporting rules and forms to capture additional data elements.([canada.ca](https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-agency-cra/transparency-proactive-disclosure-canada-revenue-agency/consultations-engagement-canada-revenue-agency/consultation-guidance-related-draft-common-reporting-standard-amendments.html?utm_source=openai))
- The guidance under review will affect compliance practices for reporting institutions once legislation passes and becomes enforceable.([canada.ca](https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-agency-cra/transparency-proactive-disclosure-canada-revenue-agency/consultations-engagement-canada-revenue-agency/consultation-guidance-related-draft-common-reporting-standard-amendments.html?utm_source=openai))
## Action steps for financial institutions
- Ensure your **compliance team** reviews the draft guidance as soon as possible. Examine how your current reporting systems map to the new schema.
- Participate in the feedback period if invited, or engage with industry associations that are contributing to the consultation.
- Update internal data collection and retention practices to capture additional fields likely required under the new schema.
- Train staff in relevant departments (compliance, IT, risk) on upcoming changes so operations are not caught flat-footed once requirements are finalized.
## Example of likely operational impact
- Suppose your institution currently reports basic account holder name, address, tax ID, and account balances. Under expanded CRS reporting, you may need to report **additional identifying data** such as multiple tax residence indicators, date of birth, or country of birth.
- Data system upgrades may be necessary—including integrated workflows between onboarding, KYC (Know Your Customer), and tax-reporting functions.
- Testing the updated schema early (in mock-filing mode) can reduce errors when full compliance begins.
## Timeline & compliance landscape
- The consultation closes **November 26, 2025**. Legislation has not yet been passed.([canada.ca](https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-agency-cra/transparency-proactive-disclosure-canada-revenue-agency/consultations-engagement-canada-revenue-agency/consultation-guidance-related-draft-common-reporting-standard-amendments.html?utm_source=openai))
- Once royal assent is secured, compliance obligations will become effective according to the timelines in the legislation and CRA guidance.
- Expect phased implementation, as institutions bring systems up to speed.
**Final thought:** These changes to CRS are a big deal for financial institutions. The key to staying ahead is early preparation—review the draft, adjust systems and processes, and deliver accurate reports when required. Non-compliance when the rules take effect could bring penalties, so this is not just a regulatory exercise—it’s essential risk management.