Introduction

Digitalisation has transformed how people hold and move money, and now tax transparency rules are catching up. The latest update to the Common Reporting Standard (CRS 2.0) brings e-money providers and digital payment services into scope for global tax reporting.

These changes mean that organisations offering products such as digital wallets, prepaid cards, or central bank digital currency services may now be treated as Reporting Financial Institutions. With new due diligence, onboarding, and reporting obligations taking effect from 1 January 2026, now is the time to assess your readiness.

What is CRS 2.0?

The Common Reporting Standard (CRS) has been updated in both scope and application to align with financial and technological developments globally.

The CRS evolution follows the implementation of the OECD’s Crypto-Asset Reporting Framework (CARF) and its EU counterpart, DAC 8, which introduced similar reporting rules applicable to crypto-asset service providers. [See further here – link to CARF flyer]

The new CRS and CARF rules will be effective from 1 January 2026, with the first reports required to be filed in 2027. While the CRS reporting deadline remains at 30 June following the relevant year-end, the annual deadline date for CARF reporting in Ireland will only be confirmed when the required legislation is enacted before the end of 2025.

How EY can support you

Understanding whether and how you are impacted by these requirements might not be straightforward.

With over a decade of experience navigating global tax transparency regimes, we understand the challenges and complexities these frameworks bring. Our expertise, global reach, and purpose-built technology enable us to support you throughout the entire compliance journey, including by:

  • Conducting entity and product analysis to establish which of your offered services or products are within or outside the scope

  • Assisting with the review or design and implementation of onboarding and due diligence procedures and governance frameworks for compliance, including designing and reviewing self-certifications and staff training

  • Performing data health checks to evaluate the quality and completeness of data and preparing the data for submission

  • Registering with the competent authorities and managing multi-country reporting requirements using our reporting tool, EY FIRST

  • Advising on the requirements and their application, together with tracking legislative and guidance updates with our monitoring tool, EY Analyzer