CRS Filing Errors: A Self-Check Guide Based on OECD Guidance

Why CRS Filings Get Rejected

Financial institutions often make repeated errors when submitting Common Reporting Standard (CRS) data. The OECD's frequently asked questions and country practices point to several recurring problem areas. For compliance teams, knowing these pitfalls is the first step to reducing rejection rates.

High-Frequency Error Types

Missing or Invalid Tax Identification Numbers (TINs)

One of the most common issues is a missing Tax Identification Number (TIN) for account holders. Some filers leave the field blank when the holder has a TIN, or they enter an incorrect one. Always verify that the TIN exists and matches the format of the relevant jurisdiction.

Incorrect Date of Birth Format

The OECD guidance stresses using the standard date format (YYYY-MM-DD). Many errors occur when institutions enter dates in national formats, such as MM/DD/YYYY or DD/MM/YYYY, leading to confusion and rejection. Standardize all date fields.

Confusion in Account Holder Classification

Another frequent error is misclassifying the type of account holder. For example, an entity may be incorrectly classified as an individual or vice versa, or a trust may be tagged as a Financial Institution (FI) when it is actually a Non-Financial Entity (NFE). Accurate classification is critical because it determines the reporting obligations.

Self-Check Checklist for Compliance Staff

Use this checklist to review your CRS filings before submission:

• Verify that all required TINs are present and in the correct syntax for the holder's country.
• Confirm that all dates of birth are in the YYYY-MM-DD format.
• Double-check the classification of each account holder: individual, entity, FI, or NFE.
• Compare your data with the OECD's FAQs to resolve ambiguity.
• Ensure your records reflect the latest guidance from relevant tax authorities.

Corrective Actions

If you identify errors, take immediate corrective steps:

• For missing TINs, request the TIN from the account holder and update the system.
• For date format issues, convert all dates to the international standard.
• For classification errors, review the OECD definitions and reclassify the account accordingly.

Conclusion

Reducing CRS filing errors requires attention to common pitfalls and a systematic review process. By following a checklist based on OECD guidance and national practices, compliance staff can improve the accuracy of their submissions and minimize costly mistakes.