The webinar underscored important alterations to the CRS reporting framework, set to take effect from June 2025. These updates demand careful preparation and proactive policy reviews by all reporting and non-reporting FIs.

1. Introduction of a new CRS form

Effective June 2025, FIs will be required to complete the new CRS form annually via the BVIFARs reporting portal. This comprehensive form requires detailed accounts of how CRS obligations are being fulfilled. Separate sections for reporting and non-reporting FIs further tailor the form’s requirements. While the submission deadline is yet to be formally announced, it is expected to follow the 31 May CRS reporting deadline.

2. CRS risk assessment and enforcement activities

The BVI ITA revealed its new CRS risk assessment system, aimed at improving compliance enforcement and oversight. FIs will be assigned one of three risk ratings based on submitted data, CRS responses, and additional ITA queries:

• Low risk: Reviewed approximately every five years unless specific triggers necessitate earlier action.
• Medium risk: Reviewed every one to two years due to moderate risk factors.
• High risk: Reviewed annually until compliance is consistently achieved.

FIs identified as medium or high risk may undergo compliance inspections. These can be desk-based (remote reviews of submitted data) or onsite (either physical or virtual). Inspections will focus on all aspects of CRS compliance or specific risk-prone areas, depending on the findings from the risk assessment.

3. Updating CRS policies and procedures

The ITA emphasised the importance of reviewing CRS-related policies to align with the expanded reporting obligations. Institutions must ensure consistent application of these policies to avoid administrative fines or enforcement actions.

Alongside the CRS updates, financial institutions should note the following deadlines to ensure full compliance with annual regulatory requirements.

31 March 2025

• Compliance report: A mandatory submission for licensed entities summarising their compliance efforts for the prior calendar year.
• Investment business annual return: Requires reporting on business operations for the calendar year ending December 2024.
• AML/CFT return: Outlines adherence to Anti-Money Laundering and Countering the Financing of Terrorism regulations.

30 June 2025

• Audited accounts: Funds and Licensees with 31 December fiscal year-ends must file audited financials by this date.
• Unaudited accounts: Approved and Incubator Funds, as well as Approved Managers, must submit their non-audited accounts.
• Mutual fund annual return: This return provides a detailed summary of financial performance, operational updates, and governance information.

With changes to CRS reporting and ongoing regulatory requirements, FIs must take deliberate steps to ensure readiness:

• Review and update CRS policies and procedures in line with the ITA’s new expectations.
• Prepare for compliance reviews based on the CRS risk assessments and assigned ratings.
• Meet submission deadlines to avoid penalties and maintain regulatory standing.

For further details and assistance, the BVI CRS webinar and a comprehensive Q&A section can be found here.