OECD CRS & CARF 2025 Updates | A New Era of Global Tax Transparency

OECD CRS and CARF 2025 Updates: Ushering in a New Era of Global Tax Transparency

The Organisation for Economic Co-operation and Development (OECD) last week has released three pivotal documents that aim to define how jurisdictions handle the automatic exchange of CRS financial and CARF crypto-asset information. These updates provide technical enhancements, as well as representing the strategic evolution in the global fight against tax evasion and financial opacity.

In this article, we break down the key updates for tax authorities, explore their implications for financial institutions (FIs), and explain how they fit into the broader regulatory ecosystem.

The Three Cornerstone Documents

The OECD’s 2025 updates are centered around three core publications:

1. Crypto-Asset Reporting Framework (CARF) – Status Message XML Schema
2. Common Reporting Standard (CRS) – 2025 Consolidated Text
3. CRS Status Message XML Schema – Version 3.0

Each of these documents plays a distinct role in enhancing transparency, improving data quality, and expanding the scope of reportable assets.

1. CARF Status Message XML Schema:

The Crypto-Asset Reporting Framework (CARF) was introduced to address the growing use of crypto-assets in cross-border financial activity. While CARF itself was introduced in 2023, the 2025 Status Message XML Schema is a critical technical addition that enables tax authorities to provide structured feedback on FI data submissions.

Key Features:

• Structured Error Reporting: Allows jurisdictions to send detailed error messages when crypto-asset data submissions fail validation or contain inconsistencies.

• File-Level and Record-Level Feedback: Supports granular error identification, improving the accuracy and reliability of data exchanges.

• Interoperability: Designed to work seamlessly with existing tax reporting systems and the CRS infrastructure.

Why It Matters:

Crypto-assets are inherently decentralized and pseudonymous, making them attractive for tax evasion. By introducing a robust error feedback mechanism, the OECD is ensuring that CARF data exchanges are not only comprehensive but also verifiable and auditable.

2. CRS 2025 Consolidated Text

The Common Reporting Standard (CRS) has been the backbone of global tax transparency since its adoption in 2014. The 2025 consolidated text represents the most significant overhaul of the standard to date.

What’s New:

• Inclusion of Digital Assets: The updated CRS now explicitly covers electronic money products and central bank digital currencies (CBDCs).

• Indirect Crypto Exposure: Financial institutions must now report on indirect investments in crypto-assets, such as those held through derivatives or pooled investment vehicles.

• Non-Profit Carve-Out: Genuine non-profit organizations are now exempt from certain reporting obligations, reducing administrative burdens while maintaining transparency.

• Alignment with CARF: The CRS has been updated to ensure it complements, rather than duplicates, the CARF framework.

Strategic Implications:

This update reflects the OECD’s recognition that the financial landscape has evolved dramatically. With the rise of fintech, digital wallets, and tokenized assets, the CRS needed to be modernized to remain effective. The inclusion of CBDCs and e-money ensures that the standard remains future-proof.

3. CRS Status Message XML Schema v3.0

The third document, the CRS Status Message XML Schema Version 3.0, is a technical specification that enables jurisdictions to send structured feedback on CRS data submissions.

Key Enhancements:

• New Error Codes: More granular error identification helps institutions quickly pinpoint and resolve issues.

• Expanded Metadata: Additional fields improve traceability and auditability.

• Automation-Ready: Designed to support automated workflows, reducing manual intervention and improving efficiency.

• Future Compatibility: Fully aligned with the 2025 CRS updates and CARF, ensuring long-term inter-operability.

Why It’s Important:

As the volume and complexity of data exchanges grow, so does the risk of errors. This schema empowers tax authorities to maintain high data quality standards, which is essential for effective compliance monitoring and enforcement of FI reporting.

Why These Changes Were Introduced

1. Responding to the Rise of Crypto Crypto-assets have moved from the fringes of finance to the mainstream. With billions of dollars flowing through decentralized platforms, regulators needed a framework to ensure these assets are not used to evade taxes.

2. Improving Data Quality The introduction of status message schemas for both CARF and CRS reflects a broader push toward data integrity. Structured error reporting ensures that data exchanges are not only complete but also accurate.

3. Modernizing Global Standards The financial world has changed dramatically since 2014. The updated CRS reflects this new reality, incorporating digital assets and aligning with emerging technologies.

4. Supporting Compliance and Enforcement These updates give tax authorities the tools they need to identify non-compliance, enforce reporting obligations, and close loopholes that previously allowed certain assets to go unreported.

What This Means for Financial Institutions

For financial institutions, these changes are both a challenge and an opportunity. On one hand, they introduce new reporting obligations and technical requirements. On the other, they offer a chance to modernize compliance systems and build trust with regulators.

Key Considerations:

• System Upgrades: Institutions will need to update their reporting systems to accommodate the new schemas and data fields.

• Staff Training: Compliance teams must be trained on the new requirements, especially around crypto-assets and digital currencies.

• Vendor Coordination: Firms working with third-party compliance platforms (like TAINA) should ensure their vendors are aligned with the new standards.

• Early Adoption: While some changes won’t be mandatory until reporting in 2027, early adoption can reduce risk and improve operational readiness when many jurisdictions will require collection in 2026.

Final Thoughts

The 2025 OECD updates are more than just regulatory changes, they are a blueprint for the future of global tax transparency. By expanding the scope of reportable assets, improving data quality, and embracing automation, the OECD is setting a new standard for compliance in the digital age.

How can TAINA help? 

The changing legislation around CRS and CARF, paired with the increased CRS enforcement seen around the world, has further increased the risk for financial institutions. It is more important now than ever to address your CRS validation process. The TAINA Platform takes care of your CRS self-certification compliance in a seamless end-to-end process whilst maintaining an up to date, robust and detailed CRS ruleset. 

TAINA’s fully automated FATCA and CRS Validation Platform can help financial institutions lighten their compliance burden whilst improving efficiency, reducing cost, mitigating risk, and improving their overall customer and investor experience. 

Using our flexible and lightweight platform you can automate and streamline your FATCA and CRS validation process whilst ensuring you have good year-end data that will result in clean FATCA and CRS reporting to tax authorities all year round.

We would love to talk to you more about your current documentation validation process and how our award-winning FATCA and CRS Validation platform may add value to your organisation.

For more information on how our fully automated FATCA and CRS Validation platform can add value to your business, get in touch or request a demo to see it in action.