Understanding the CRS 2.0 Landscape

FINANCIAL SERVICES

Contents

Preparing Financial Institutions for the Next Era of Tax Transparency

The adoption of the Crypto-Asset Reporting Framework (CARF) and the updated Common Reporting Standard (CRS 2.0) through the EU Directive DAC8 mark a significant evolution in the international tax reporting landscape. In Greece, the new requirements have been incorporated into national legislation through Law 5301/2026, introducing enhanced reporting obligations for Financial Institutions from 1 January 2026. 

The expanded framework extends reporting obligations beyond traditional financial accounts to include crypto-assets, electronic money products and Central Bank Digital Currencies (CBDCs), while also introducing more detailed due diligence and reporting requirements. As reporting expectations continue to evolve, Financial Institutions should assess the impact of the new framework on their governance, processes, systems and data management capabilities. 

 

What CRS 2.0 means for Financial Institutions

  • Stronger self-certification controls
    Financial Institutions should strengthen validation procedures by implementing enhanced monitoring, documentation and control processes to ensure the accuracy of customer tax information. 

  • Expanded scope of reportable products
    The reporting framework now extends beyond traditional financial accounts to include digital wallets, electronic money products and Central Bank Digital Currencies (CBDCs). 

  • Increased reporting complexity
    Financial Institutions will be required to capture and report additional information, including account classifications, documentation status, controlling persons and joint account details.

 

Why organizations should prepare now

Although the first reporting will take place in 2027, the enhanced due diligence and reporting requirements apply from 1 January 2026, leaving Financial Institutions limited time to assess the impact of the new framework and implement the necessary operational changes. 

Early preparation will enable organizations to identify potential compliance gaps, strengthen governance and data quality frameworks, enhance reporting systems and equip their teams with the capabilities required to meet the new regulatory expectations. A proactive approach can also help minimize compliance risks and support a smoother transition to the enhanced reporting regime.

 

Understanding the CRS 2.0 Landscape

Understanding the CRS 2.0 Landscape

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