UAE Joins CRS 2.0 Automatic Exchange of Information

In August 2025, the Ministry of Finance of the United Arab Emirates signed the Addendum to the Multilateral Competent Authority Agreement (MCAA) on the Automatic Exchange of Financial Account Information. This Addendum provides for an obligation to implement the automatic exchange in accordance with the updated Common Reporting Standard, known as “CRS 2.0”.

What is CRS 2.0?

The Common Reporting Standard (CRS) outlines the obligations of national financial institutions, the categories of accounts subject to reporting, and the specific information to be exchanged automatically between the tax authorities of participating jurisdictions. Its original version was adopted in 2014, and since then, more than 120 jurisdictions have implemented it. 

In 2022-2023, the Organisation for Economic Co-operation and Development (OECD) updated the CRS, adapting it to the rapid development of digital financial products and crypto-assets.

The new version of the CRS includes:

• New types of assets.
• Additional data points subject to exchange.
• Enhanced due diligence requirements for account holders and controlling persons.
• Refined definitions affecting the scope and content of the automatic exchange.

As of December 2025, 67 countries have signed the Addendum to the MCAA.

Implementation deadlines for CRS 2.0 in the UAE

The UAE Finance Ministry signed the Addendum to the MCAA on 11 August 2025, committing to start automatic exchange under CRS 2.0 in 2028. Data for the 2027 calendar year will be subject to exchange.

As noted in a press release from the UAE Ministry of Finance, the adoption of the updated CRS demonstrates the UAE’s commitment to the highest international standards of tax transparency and expanded cooperation with the OECD.

The UAE has been participating in the original version of the MCAA since 2017, and the first exchange took place in 2018. According to the OECD portal, the UAE currently has over 80 countries among its exchange partners.

Key changes to the CRS 

Electronic Money and Central Bank Digital Currencies

CRS 2.0 expands the definition of a depository account. It now includes not only traditional bank accounts and deposits opened for clients as part of ordinary banking activities, but also:

• Specified Electronic Money Product (SEMP) accounts and 
• Central Bank Digital Currencies (CBDC) accounts. 

The term Specified Electronic Money Product (SEMP) means any product that is:

• a digital representation of a single fiat currency;
• issued after receipt of funds for the purpose of making payment transactions;
• represented as a claim against the issuer denominated in the same fiat currency;
• accepted as payment by a natural or legal person other than the issuer; and 
• by virtue of the regulatory requirements to which the issuer is subject, can be redeemed at any time at par value for the same fiat currency upon request of the product holder. 

The term Central Bank Digital Currency (CBDC) means a digital fiat currency issued by the Central Bank of a particular country.

Financial assets and crypto-assets

The term financial asset now includes not only securities, partnership interests, swaps, insurance contracts or annuity contracts, but also any interest (including futures and options) in “relevant crypto-assets”. 

A relevant crypto-asset is any crypto-asset that can be used for payments or investment, excluding Central Bank Digital Currencies and Electronic Money.

Does CRS 2.0 apply to crypto-assets?

Crypto-assets and direct crypto-transactions are generally outside the scope of CRS 2.0. These will be handled within a separate mechanism — CARF (Crypto-Asset Reporting Framework).

However, CRS 2.0 covers financial accounts holding crypto-derivatives or investment instruments utilising crypto-strategies.

Due diligence and determining tax residency

CRS 2.0 imposes stricter due diligence procedures on financial institutions. Particular attention is paid to the verification of the tax residency of account holders and their controlling persons. A person’s residency determines the jurisdiction to which the data will be sent via automatic exchange.

Aspect	Changes under CRS 2.0
Determination of controlling persons	To determine the controlling persons of the account holder, a financial institution may rely on client information obtained within its AML/KYC procedures only if such procedures comply with FATF Recommendations.
Claiming no residency	If an account holder claims no tax residency in their self-certification, the financial institution must verify this against other AML/KYC documents. If unverified, the self-certification cannot be relied upon.
Cases of dual residency	If an entity (account holder) turns out to be a tax resident of more than one jurisdiction, it can no longer choose only one of them according to the tie-breaker rules provided for by international tax treaties. Such an entity must declare all jurisdictions where it is considered a tax resident.
Residency in countries with CBI / RBI programs	If an account holder or controlling person has declared that they are tax residents in a jurisdiction that offers “potentially high-risk citizenship or residence by investment programs” (CBI / RBI), the financial institution may not rely on such self-certification until it takes further measures to clarify the residency of such person (through additional questions to the client and requesting supporting documents).
Government verification service	Financial institutions will be able to verify identity and residency of account holders and controlling persons directly with the jurisdiction where the person is declared resident (through a special interface).

Additional reporting requirements

In addition to information currently required, financial institutions will provide the following for each reportable account:

• Confirmation of whether a valid self-certification was obtained.
• The specific role of each controlling person and their self-certification status.
• Whether the account is a joint account and the number of joint holders.
• The type of account (e.g., depository, custodial) and whether it is a “pre-existing” or “new” account.
• The specific role of an individual holding an interest in an investment entity.

Conclusion

The CRS 2.0 expands the scope of automatic exchange to new types of accounts and assets, including e-money, official digital currencies, and investment instruments linked to crypto-assets. The UAE’s accession to CRS 2.0 will entail changes to customer due diligence rules for banks and other financial institutions.

Individuals and businesses in the UAE are advised to review how the updated CRS affects them and ensure they are ready to provide the necessary information to their financial institutions.