Navigating the amendments to the CRS: impact on e-money providers

The OECD’s CRS has undergone significant amendments to enhance transparency and combat tax evasion. These changes are particularly impactful for e-money providers, who must now navigate new reporting obligations and compliance requirements.

E-money providers have not historically been subject to the same level of scrutiny as traditional financial institutions. However, with the rise of digital transactions, tax authorities have recognised the need for comprehensive reporting to monitor e-money flows and ensure tax compliance. The amendments to the CRS aim to close gaps in information and bring e-money providers into the fold of global tax transparency.

The UK has published draft regulations  and adoption of the amendments is expected by over 100 jurisdictions which have already adopted the CRS.

The CRS amendments extend the scope of reportable financial accounts to include e-money products, Central Bank Digital Currencies (CBDCs), and investments in crypto-assets. They also increase the scope of reporting on due diligence for all existing financial accounts.

• Onboarding: Enhance customer due diligence procedures to align with the new requirements. This includes collecting detailed information regarding account holders and obtaining and validating self-certification documents
• Data gathering: Develop or update systems to capture the required data. This includes personal information, such as tax residence, account balances, payment information and information on controlling persons of entity accounts
• Submission and acceptance: The electronic files will be submitted to the e-money provider’s local competent authority via their existing CRS exchange on information process. The local authority will confirm acceptance of the reported details and follow up with queries should any discrepancies be identified

Penalties established under CRS will now apply to e-money providers. The exact amount varies depending on jurisdiction but can be significant. Tax authorities are also looking to increase penalties – for instance, HMRC is considering implementing per-account penalties.
Non-compliance can also lead to reputational harm, impacting the e-money provider’s relationship with its tax authority and its position in the market.

Alongside the CRS amendments, the OECD has introduced the Crypto-Asset Reporting Framework (CARF). CARF requires business providing crypto-asset services to report information regarding cryptocurrency transactions. The framework will operate in a similar way to CRS, and an institution could be required to report under both CRS and CARF.

For more in-depth information about the CARF, you can read our insight article here.

The new rules and reporting requirements for e-money providers will apply from 1 January 2026.

That means that before 31 December 2025, all e-money providers will need to be capable of capturing and holding the required information that will need to be reported. E-money accounts open on 31 December 2026, or closed during that year, will be in scope for reporting.

Data reports will need to be extracted after 1 January 2027 and prepared as .XML files ready for electronic submission to the local tax authorities. The first submissions will need to be made during 2027.

Our Digital Services and Operational Taxes teams already support clients with their reporting obligations taking into account their business models.

We work with clients in the UK, all 27 EU Member States, as well as globally, continuing to support them as new reporting obligations are issued by the OECD, HMRC and other tax authorities.

We have the experts who can help. You can speak to your usual contact or the contacts listed.

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1 - https://www.gov.uk/government/consultations/draft-regulations-the-international-tax-compliance-amendment-regulations-2025