Tax information exchange and FATCA

FORTHCOMING CHANGES: The UK is due to implement the OECD’s Cryptoasset Reporting Framework (CARF) into domestic law with effect from 1 January 2026. The implementing measure is the Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744), which was laid before the House of Commons on 25 June 2025. On the same day, HMRC published tax impact and information notes (TIIN) for the measure. HMRC has also published guidance on reporting under the CARF.

The government has also introduced legislation amending the domestic law implementing the OECD’s Common Reporting Standard (CRS) and the UK’s obligations under the Intergovernmental Agreement with the US for the implementation of the US Foreign Account Tax Compliance Act (FATCA). The principal legislation is the International Tax Compliance Regulations 2015 (SI 2015/878) and the amending measure is the International Tax Compliance (Amendment) Regulations 2025 (SI 2025/740). The amendments implement the OECD’s 2023 changes to the CRS and introduce other changes ‘to make the UK’s implementation of the rules more effective’ (Explanatory Memorandum, para 5.5). The principal changes are to include e-money