The Cayman Islands Government published the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 in the Legislation Gazette on 27 November 2025, introducing significant changes to the timing and obligations of CRS filings. These amendments take effect from 1 January 2026, aligning Cayman with the OECD’s updated CRS 2.0 and the Crypto-Asset Reporting Framework (CARF).
Filing Deadlines
The Regulations advance the CRS filing timetable, requiring earlier submission of both returns and compliance forms:
| Reporting Year | CRS Return Deadline | CRS Compliance Form Deadline | Governing regulations |
| 2025 | 31 July 2025 | 15 September 2025 | Existing rules |
| 2026 | 31 July 2026 | 15 September 2026 | Transitional year |
| 2027 onwards | 30 June annually | 30 June annually | CRS Amendment Regulations 2025 |
Key Changes
- Earlier Reporting: From 2027, CRS returns and compliance forms must be filed by 30 June, one month earlier than the previous 31 July deadline.
- Declarations Required: Each return must be accompanied by a declaration confirming information is adequate, accurate and current.
- Crypto-Assets Included: The scope of CRS reporting now extends to digital finance products.
- Principal Point of Contact (PPOC): All Financial Institutions (FIs) must appoint a Cayman-based PPOC by 31 January 2027.
- Immediate Penalties: Breaches may attract fines of up to CI$50,000, enforceable without prior warning.
Practical Implications
Fund managers, administrators and directors should act now to prepare for the accelerated timetable:
- Adjust Compliance Calendars: Internal processes must be aligned to meet the 30 June deadline from 2027.
- Strengthen Due Diligence: Systems must verify self-certifications against documentary evidence and capture crypto-asset data.
- Ensure Local Representation: Appoint Cayman-based PPOCs to meet residency obligations.
- Mitigate Risk: With penalties enforceable immediately, proactive monitoring is essential.
Conclusion
The Cayman Islands’ CRS regime is entering a new phase of earlier reporting, expanded scope, and stricter enforcement. The shift to a 30 June deadline from 2027 marks a critical change, requiring institutions to accelerate compliance processes and enhance operational readiness.
Marbury, an Ascentium company, is able to provide a full suite of Regulatory Advisory Services including the appointment of local PPOCs, anti-money laundering compliance officers (AMLCOs) and deputy/money laundering reporting officers (D/MLROs) for Cayman, BVI and entities licensed in other jurisdictions. Our role is not only to ensure compliance but to help clients embed resilient frameworks, streamline reporting and anticipate regulatory change.
By combining local expertise with cross-border perspective, Marbury enables clients to reduce risk, enhance governance and maintain institutional credibility in an increasingly complex regulatory environment. We will continue to monitor developments and provide guidance to ensure clients remain compliant while navigating these changes with confidence.
For further information please refer to these Government Sources
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