Compliance
Using Common Reporting Standard (CRS) Changes to Stay Compliant as a Cross-Border Saver
With enhanced financial account reporting coming into force January 1, 2027, savers with foreign connections need to adjust how they report and certify accounts under Canada’s CRS rules.
By NomadicTax Research Team • 5-8 min read • September 6, 2026
## What is changing under Part XIX of the Income Tax Act?
Starting **January 1, 2027**, amendments to Part XIX (Common Reporting Standard, or CRS) will require Canadian financial institutions to report additional account holder information. This includes whether a valid self-certification has been given, joint-account status, number of joint holders, type of account (new or pre-existing), and controlling-person data for entities. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/enhanced-financial-account-information-reporting/reporting-sharing-financial-account-information-other-jurisdictions/guidance-on-common-reporting-standard-part-income-tax-act.html?utm_source=openai))
## Who will this impact?
- Individuals with foreign financial accounts or residency ties.
- Entities (corporations, trusts, partnerships) with foreign owners or controlling persons.
- Reporting financial institutions, which must update due-diligence processes.
- Advisors assisting clients with multiple jurisdictions.
## Steps to stay compliant:
1. **Review your current accounts**
- If you are an account holder, ensure you have provided a valid self-certification to your financial institution. Institutions now require these certifications and will report whether they exist. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/enhanced-financial-account-information-reporting/reporting-sharing-financial-account-information-other-jurisdictions/guidance-on-common-reporting-standard-part-income-tax-act.html?utm_source=openai))
- For entity accounts, identify “controlling persons” and ensure they have self-certified. Institutions need to collect roles and whether these people complied. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/enhanced-financial-account-information-reporting/reporting-sharing-financial-account-information-other-jurisdictions/guidance-on-common-reporting-standard-part-income-tax-act.html?utm_source=openai))
2. **Understand joint accounts and account status**
- Any joint accounts must disclose number of holders. New accounts vs pre-existing ones are differentiated and reported differently. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/enhanced-financial-account-information-reporting/reporting-sharing-financial-account-information-other-jurisdictions/guidance-on-common-reporting-standard-part-income-tax-act.html?utm_source=openai))
3. **Penalties for non-compliance**
- Failing to provide required information—such as a valid self-certification or a taxpayer identification number (TIN)—can lead to financial penalties. The draft rules include potential fines for account holders who do not supply requested foreign TINs. ([fin.canada.ca](https://fin.canada.ca/drleg-apl/2025/ita-lir-0825-l-eng.html?utm_source=openai))
4. **Plan ahead with timing**
- Since the changes apply to reporting on **calendar year 2027**, institutions must have data ready by early 2028 for CRA filings. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/e-services/filing-information-returns-electronically-t4-t5-other-types-returns-overview/xml-specs/part-xix-2028.html?utm_source=openai))
## Practical example
Sarah is a Canadian resident who holds a foreign bank account through an institution in Canada. Before January 1, 2027, she has not submitted any self-certification. Under the new rules:
- The bank will request her to provide a self-certification, including whether she has a foreign TIN.
- If she refuses or cannot provide the TIN when her country issues it, she may be subject to penalties, and her account becomes reportable regardless.
For an entity, say GreenCo Inc. owned by two trusts, each trust must identify “controlling persons” and submit valid self-certifications. Otherwise, the entity will be reported with missing data.
## Actionable insights for cross-border savers
- Proactively contact financial institutions to ensure you have submitted required certifications and TINs.
- For entities, map ownership structures and identify controlling persons early.
- Maintain documentation showing compliance in case of CRA audits.
- Watch for updates to the guidance from CRA as final legislation receives Royal Assent.
**Bottom line**: The enhanced CRS reporting makes transparency non-optional. Individuals and entities with any foreign financial ties should act now to ensure full documentation and avoid surprises in 2027 and beyond.