British Virgin Islands (BVI) CRS reporting: XML Schema 3.0 becomes mandatory from 1 January 2027

The British Virgin Islands (BVI) International Tax Authority (ITA) has confirmed that, from 1 January 2027, all Common Reporting Standard (CRS) reports submitted through the BVI Financial Account Reporting System (BVIFARS) Portal must use CRS XML Schema 3.0.

The announcement, published on 16 October 2026, forms part of the BVI's implementation of the Amended CRS (CRS 2.0) and highlights the need for Reporting Financial Institutions (RFIs) to prepare for changes to reporting systems, due diligence processes and information requirements.

What is changing?

From 1 January 2027, the BVIFARS Portal will no longer accept CRS reports prepared using earlier XML schema versions. All submissions, including corrections to historical filings, must use XML Schema 3.0.

The change follows the introduction of the Amended CRS, which took effect in the BVI on 1 January 2026. The updated reporting requirements will first apply to financial account information for the 2026 calendar year, with submissions due by 31 May 2027.

The ITA encourages RFIs to engage with their software vendors, administrators and service providers to ensure reporting systems are ready for the transition.

Additional reporting requirements under the Amended CRS

Beyond the technical schema upgrade, the Amended CRS introduces expanded information collection, due diligence and reporting requirements.

Depending on the type of financial account and applicable obligations, RFIs may need to capture additional information relating to:

• Financial account classifications: Including account types and whether accounts are classified as New or Preexisting Accounts.
• Self-certification information: Confirmation of whether valid self-certifications have been obtained for Account Holders and, where applicable, Controlling Persons.
• Controlling Person and Equity Interest Holder roles: Additional details regarding the capacities in which Reportable Persons are connected to entities, investment arrangements or trusts.
• Other reporting information: Including joint account details and certain electronic money products and central bank digital currencies (CBDCs).

Certain requirements are subject to transitional provisions for pre-existing accounts.

Importantly, upgrading reporting software alone may not be sufficient. RFIs should also assess whether their existing account and investor records contain the information necessary to satisfy the updated reporting requirements.

Key dates to remember

RFIs should review historical submissions and address any errors or omissions in accordance with the ITA's transitional instructions.

What should RFIs do now?

To prepare for the transition, RFIs should consider the following:

• • Review historical filings: Identify any errors, omissions or previously unreported accounts requiring correction.
  • Confirm system readiness: Ensure reporting software and service providers can support XML Schema 3.0 and its updated validation requirements.
  • Assess data completeness: Review account and investor records, self-certifications and due diligence documentation to identify information gaps.
  • Update procedures and coordinate responsibilities: Align internal AEOI policies, onboarding processes and reporting arrangements with the Amended CRS requirements.

Early preparation will help reduce the risk of reporting delays, validation errors and last-minute remediation during the 2027 filing cycle.

How Ascentium Fiduciary can help

Our experienced Automatic Exchange of Information (AEOI) team supports BVI entities with their Foreign Account Tax Compliance Act (FATCA) and CRS obligations, including entity classification, investor due diligence reviews, preparation of AEOI policies and procedures, and regulatory reporting to the ITA.

As the BVI transitions to the Amended CRS and XML Schema 3.0, we can assist clients in assessing their obligations, identifying potential data gaps and preparing for the updated reporting requirements.

To discuss how these changes may affect your entities, please contact your usual Ascentium Fiduciary representative or our team.