Clarification on CRS Reporting Thresholds

[Var12]

Hi everyone!!
I’ve come across several discussions suggesting that under the CRS, accounts with an average balance below 10,000 USD are not reported. However, there seems to be some confusion regarding the timeframe for calculating the average balance. some sources mention it refers to a year, while others suggest it’s based on a 3-month period. Does anyone know whether these rules are already in effect or if they will apply starting next year? Additionally, are these thresholds relevant only for EMI accounts, or do they also apply to crypto accounts?
Looking forward to your insights!

 

[Martin Everson]

Speak to bank or EMI you use to see how they have implemented CRS reporting if your concerned. Alternatively look for CRS country guidance paper in country where your account is based.

For example Bank of Cyprus offers a CRS faq document explaining how they handle CRS.

https://www.bankofcyprus.com/globalassets/who-we-are/our-governance/fatca-crs-faq-website-en.pdf

Additionally, are these thresholds relevant only for EMI accounts, or do they also apply to crypto accounts?

An amendment to CRS reporting to include crypto assets is coming. But right now no it will commence in 2027

https://www.oecd.org/en/about/news/...ation-and-issues-interpretative-guidance.html

 

[daniels27]

For example Bank of Cyprus offers a CRS faq document explaining how they handle CRS.
https://www.bankofcyprus.com/globalassets/who-we-are/our-governance/fatca-crs-faq-website-en.pdf

Please note that AFAIK the preexisting client threshold of 250,000 USD is for exclusion from due diligence, not from reporting.

https://www.oecd.org/content/dam/oe...ssue-focus/aeoi/jersey-guidance-notes-crs.pdf
A jurisdiction may allow Financial Institutions to exclude from its due diligence procedures pre-existing Entity Accounts with an aggregate account balance or value of $250,000 or less as of a specified date. If, at the end of a subsequent calendar year, the aggregate account balance or value exceeds $250,000, the Financial Institution must apply the due diligence procedures to identify whether the account is a Reportable Account. If this option is not adopted, a Financial Institution must apply the due diligence procedures to all Preexisting Entity Accounts.

If you have a look at the OECS FAQ

https://www.oecd.org/content/dam/oe...ternational-co-operation/crs-related-faqs.pdf

3. Excluded Account – Dormant accounts
The Standard provides, as an example of a Low-risk Excluded Account, a dormant account with an annual balance that does not exceed USD 1000. See Commentary on Section VIII, paragraph 103, Example 6. In light of the fact that the USD 1000 threshold is provided as an example, to what extent can jurisdictions electing to include dormant accounts as a Low-risk Excluded Account fix a higher threshold? Even though the USD 1000 amount is only indicative it is expected that jurisdictions electing to include dormant accounts as a Low-risk Excluded Account do not fix a threshold that substantially exceeds this amount.

I would not expect much to be exluded unless dormant and under $2500.

Also note that CRS is generally applying year end balances. FBAR reporting requirements have a $10,000 threshold for balance at any time of the year, maybe OP had this in mind.