Common Reporting Standards Update And An Introduction To Our New Online CRS Portal

First and foremost, there is the move to capture the role and other information relating to controlling persons for entities on the register, as well as the presence and details of joint holders on all accounts. Equiniti is ahead of the game here as this data is already captured by our self-certification forms (where appropriate) and has been part of our reporting and submission processes for previous years.  

We’re also happy to confirm that our clients were registered successfully with HMRC by the 31 December 2025 deadline.   

So, what are the other changes? 

There is now a stronger emphasis on due diligence when processing customer (shareholder) information rather than accepting self-certifications at face value. We’ve therefore increased our scrutiny at the point of processing, so that we challenge more claims where appropriate and have expanded the scenarios where we request supporting documents. Whilst already present in our procedures, the enhancements here will better ensure the reliability of shareholder information and provide better protection, such as against the abuse of Citizenship-by-Investment and Residence-by-Investment schemes, as emphasised in the OECD guidance. 

In tandem, engagement from the shareholder is required more than ever as we are reliant on them providing their information to us. Unlike online broker platforms we are unable, as Registrar, to refuse service until we have received the information. Shareholders therefore arrive on the Register of Members first and are asked to provide the required information after the fact.  

It’s welcome then that CRS 2.0 sees the introduction of fines for which shareholders would be held personally liable if they don’t comply. We are ensuring that shareholders are fully aware of these consequences and understand the importance of completing the self-certification process. We have explained the potential fines which were introduced with CRS 2.0 already seeing a marked rise in the returns received in February and March, doubling what we had seen last year.  

A continual improvement exercise covering all our CRS communications has also been implemented alongside an increase in the frequency of our chaser mailings over the year.  

What’s next?

We’re very excited to be introducing our new online platform which will enable shareholders to provide their CRS and FATCA self-certification information digitally.  

The award-winning regulatory platform supported by Taina, has been in use by our US business for several years and it has proven to work extremely well as a smart and intuitive interface for US investors to submit their tax forms for the IRS. Integrated with our internal changes, the platform will further enhance our validation process ready for the 2026 submission in 2027 and just as importantly, help us be more efficient with reporting submissions and responses to HMRC queries. We also expect that removing the requirement for the return of a physical form will improve shareholder engagement and improve the quality of data that we receive.  

If you have any questions, please speak to your Relationship Manager. Otherwise, please look out for a further update very soon once the online portal is live!