New Principal Point of Contact (PPC) requirement

A key change introduced by the amendments is the mandate for every Cayman Financial Institution to appoint a PPC located within the Cayman Islands. This ensures the Department for International Tax Cooperation (DITC) has a local contact for all communications.

• Transition period: FIs registered before 31 December 2025 have until 1 January 2027 to appoint a Cayman-based PPC.
• Notification of changes: You must notify the DITC of any change to your appointed PPC within 30 days.
• Penalty for non-compliance: Failure to appoint a Cayman-based PPC or notify the DITC of changes can result in administrative penalties of up to US$12,200 (CI$10,000).

Revised filing and registration deadlines

The compliance calendar is shifting. Beginning with the 2026 reporting year, the deadlines for submitting key CRS documentation will be consolidated and brought forward. This harmonisation is designed to streamline the reporting process.

• New consolidated deadline: From 2026 onwards, both the CRS Return and the CRS Compliance Form will be due by 30 June This replaces the previous separate deadlines of 31 July and 15 September.
• First consolidated filing: For the 2026 reporting period, both documents must be submitted by 30 June 2027.

Registration deadlines for new entities have also been updated.

• New FIs: Financial Institutions that commence activities on or after 1 January 2026, are required to complete their registration on the DITC portal by 31 January 2027.

Stricter penalties and enforcement

The amended regulations introduce a more stringent enforcement regime. The DITC now has the authority to impose immediate penalties for non-compliance, removing the previous practice of issuing a "breach notice" before acting.

An FI that fails to file its CRS Return and/or CRS Compliance Form by the statutory deadlines may be subject to immediate penalties of up to US$12,200 per breach. This also applies to the failure to keep registration details, such as the PPC and Authorising Person, current on the DITC portal.

Expanded scope: Digital and crypto-assets

In a significant move to modernise the CRS framework, the definition of "Financial Assets" has been expanded. This change brings the Cayman Islands' regime in line with the OECD’s Crypto-Asset Reporting Framework (CARF).

The regulations now formally recognise and include:

• Crypto-assets
• Specified electronic money products
• Central bank digital currencies

Entities dealing with these digital assets must now carefully evaluate their operations to determine if they have new or enhanced CRS obligations. This includes reviewing due diligence procedures and reporting capabilities to ensure they can capture and report on these newly included asset types.

Your guide to key compliance dates

To help you manage this transition, here is a summary of the most important dates:

• 1 January 2026: The amended CRS regulations officially come into force. New FIs must appoint a Cayman-based Principal Point of Contact from this date.
• 30 June 2027: First filing deadline under the new, consolidated schedule for the 2026 reporting year.
• 1 January 2027: Deadline for existing FIs to appoint a Cayman-based Principal Point of Contact.
• 31 January 2027: Registration deadline for new FIs that launched from 1 January 2026.

These amendments represent a significant step in the evolution of the Cayman Islands' tax transparency framework. We provide expert, efficient, and cost-effective services to guide you through these changes.