The International Tax Authority (ITA) of the British Virgin Islands (BVI) has announced the introduction of a new reporting obligation under the Common Reporting Standard (CRS): the submission of a new CRS form. This form contains different sets of questions for Reporting Financial Institutions (RFIs) and Non-Reporting Financial Institutions (NRFIs). In particular, it includes several inquiries requiring Financial Institutions to explain how they comply with their obligations under the CRS. Both RFIs and NRFIs will be required to complete this form on an annual basis.
To support this process, the ITA has published a guide outlining the steps for filing.
Although the submission deadline has not yet been formally announced, the form is expected to be available on the ITA portal as of June 2025, and the information will need to be submitted within nine months following the end of the relevant Financial Institution’s fiscal year.
In addition, the ITA has implemented a new CRS risk assessment system, aimed at strengthening compliance oversight and supervision. Financial Institutions will be assigned a risk rating — low, medium, or high — based on the data submitted, the responses provided in the CRS form, and any follow-up queries from the ITA:
- Low risk: review every five years, unless there are factors justifying an earlier review.
- Medium risk: review every one to two years, unless there are factors justifying an earlier review.
- High risk: annual review until sustained compliance is achieved.
These updates call for proactive preparation and a thorough review of internal policies by both RFIs and NRFIs. It is essential to ensure consistent application of such policies in order to avoid administrative penalties or enforcement measures.
At UNTITLED, we are fully available to provide any clarification and/or assistance you may need to understand and comply with this new requirement.