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  • May 16, 2025

BVI Section | Key Updates on CRS (Common Reporting Standards) Reporting for 2025

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2025

BVI

CRS (Common Reporting Standards)

Key Points for 2025 Reporting Updates




Overview:：

The BVI International Tax Authority (ITA) held a sharing session in November 2024, during which they discussed important considerations for CRS (Common Reporting Standards) reporting and introduced new regulatory requirements.


The latest core requirements include:

-   Updated CRS Reporting Forms: All Financial Institutions (FIs), including both reporting and non-reporting entities, must submit the new CRS forms through the BVIFARS system.

-   Introduction of a Risk Rating System: To ensure that financial institutions comply with CRS reporting requirements, the ITA has published its new CRS risk assessment process.


01


Detailed Explanation of the Latest Core Requirements



· New CRS Compliance Reporting Forms

Also known as the Additional Information Form, all Financial Institutions (FIs), including both reporting and non-reporting entities, must submit the new CRS compliance reporting forms through the BVI Financial Account Reporting System (BVIFARS). The forms are divided into separate sections for "Reporting Financial Institutions" and "Non-Reporting Financial Institutions," requiring detailed descriptions of the fulfillment of CRS obligations (such as due diligence procedures, account information classification, etc.).

· Payment of ITA Annual Review Fee

All Financial Institutions (FIs) registered in BVIFARS, with FI accounts currently in Active status (including both reporting and non-reporting entities), are required to pay an annual review fee (US$185) starting this year. The payment window is now officially open, and fees can be paid normally. The annual review fee can be paid through the accounts of the Primary User and Secondary User (if appointed).

· CRS Compliance Policies and Procedures

Financial Institutions are required to establish and continuously maintain CRS compliance policies and procedures. They must ensure the implementation of corresponding compliance tasks, including due diligence measures, reporting measures, account information collection and review measures, as well as CRS compliance training measures, to ensure that financial institutions meet CRS compliance obligations and avoid administrative penalties or enforcement actions.

· CRSCRS Risk Assessment Updates

To ensure that Financial Institutions comply with CRS requirements, the ITA has announced its new CRS risk assessment process. Based on the information submitted by Financial Institutions through BVIFARS (via questionnaires/forms), the ITA will review all Financial Institutions and classify them into one of three risk ratings. Financial Institutions will perform regular compliance tasks based on the assigned risk rating. The risk levels are as follows:


  • Low Risk (minimal or no CRS compliance risk): Reviewed approximately every 5 years, unless a triggering event occurs.


  • Medium Risk (limited CRS compliance risk): Reviewed approximately every 1-2 years, unless a triggering event occurs.


  • High Risk (significant CRS compliance risk): Reviewed annually, until the Financial Institution demonstrates ongoing compliance with CRS obligations.


Financial Institutions classified as medium or high risk will trigger some form of compliance inspection based on the risk assessment. Compliance inspections are categorized into two types: Desk-based Compliance Inspection and Onsite Compliance Inspection.


02


Which BVI Entities Need to File CRS?



According to the BVI International Tax Authority (ITA) CRS regulations, all entities defined as Financial Institutions (FIs) are required to file CRS. This includes:


  • Special/Singular Investor Funds (e.g., funds structured as Limited Partnerships or Business Companies)


  • Approved Managers (whether acting as Managers or Advisors)


  • Funds regulated by the FSC (e.g., Approved Funds, Private Funds, Incubator Funds, etc.)


  • Other types (e.g., Trusts, Custodial Institutions, Depository Institutions, etc.)



03


BVI Fund and Manager Compliance Calendar





The GIL Compliance Team can provide you with the following solutions:

  • Investor KYC

  • Appoint GIL as the ITA contact to assist with the completion of relevant annual CRS filings.

  • Follow up on compliance upgrades, regulatory updates, and assist the fund in timely updating and improving the CRS Compliance Manual.




Amu James

Fund Operations



One-Stop Fund Solutions

01

Fund Structure Establishment and Maintenance

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•Establishment of fund entities, management companies, and SPVs.

•Follow-up changes and routine annual maintenance for all relevant entities across different jurisdictions.

02

Registration with CIMA/FSC and Other Regulatory Bodies

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•Registration and annual maintenance of Cayman Funds and Registered Persons.

•Registration and maintenance of BVI Funds and Approved Managers.

03

AML/AEOI Compliance

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•CRS/FATCA registration and filing.

•AML (Anti-Money Laundering) compliance support, annual maintenance, and AML training

•Investor KYC and re-evaluation, Risk Assessment.

•AML Surveys and Internal Audit support

04

Fund Administration Services

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•Capital Call Notices.

•Quarterly financial reports and assistance with annual audits.

•Calculation of performance allocations (carried interest) and investor reports, along with an online client portal.

05

Fund Structure Deregistration

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•Deregistration of CIMA/FSC licenses.

•Deregistration of fund-related entities.

06

Assistance with Custody Arrangements and Bank Account Setup

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•Provide fund custody account services.

•Assist with the establishment of bank accounts for funds or management companies.


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