CRS (Common Reporting Standard)

By Manu Rao | Updated March 2026

What Is the Common Reporting Standard?

The Common Reporting Standard (CRS) is a global framework developed by the Organisation for Economic Co-operation and Development (OECD) that requires financial institutions to identify accounts held by tax residents of other countries and report that information to their local tax authority, which then exchanges it with the account holder's home country tax authority.

In practical terms: if you are a US or UK tax resident who has a bank account, mutual fund investment, or demat account in India, the Indian financial institution reports your account details — balance, interest earned, dividends received — to the Indian tax authority (CBDT), which transmits it to HMRC or the IRS (through FATCA in the US case, CRS for most other countries).

For foreign investors with Indian companies, CRS means your financial footprint in India is automatically visible to your home country's tax authority. There is no hiding — the system is designed to be comprehensive, automatic, and global.

Legal Framework

India implemented CRS through domestic legislation and international agreements:

• Section 285BA of the Income Tax Act, 1961 — Requires specified financial institutions to furnish a Statement of Financial Transactions (SFT) or a reportable account statement
• Rule 114F to 114H of the Income Tax Rules — Define reporting financial institutions, reportable accounts, due diligence procedures, and reporting formats
• The Income Tax (15th Amendment) Rules, 2015 — Incorporated CRS requirements into Indian domestic law
• CBDT Notification No. 62/2015 — Notified the list of participating jurisdictions (over 100 countries as of 2026)
• Multilateral Competent Authority Agreement (MCAA) — India signed the MCAA in June 2015 under the Convention on Mutual Administrative Assistance in Tax Matters, enabling automatic exchange with all signatory jurisdictions
• CBDT Guidance Note on CRS — Issued in November 2016 and updated periodically, providing detailed instructions to financial institutions on due diligence and reporting

India began its first automatic exchange of CRS information in September 2017 for the reporting period 2016-17.

How CRS Works

The CRS process has three steps:

Step 1 — Due Diligence

Indian financial institutions (banks, mutual funds, insurance companies, custodians, NBFCs with deposit-taking licenses) must identify whether an account holder is a tax resident of another country. They do this by:

• Collecting self-certification from the account holder (a CRS Self-Certification Form asking for tax residency, Tax Identification Number, and country of birth)
• Reviewing existing records for "indicia" of foreign tax residency — foreign address, foreign telephone number, standing instructions to transfer funds abroad, power of attorney to a foreign person, or a "hold mail" or "in care of" address
• For high-value accounts (over USD 1 million), conducting enhanced due diligence including a review by the relationship manager

Step 2 — Reporting

For accounts identified as reportable (i.e., held by or controlled by foreign tax residents), the financial institution reports the following to CBDT:

• Name, address, jurisdiction of residence, and Tax Identification Number (TIN) of the account holder
• Account number
• Account balance or value at year-end
• Total gross amount of interest, dividends, or other income credited during the year
• Gross proceeds from the sale or redemption of financial assets

Reporting is done annually by May 31 of the following year through the income tax reporting portal.

Step 3 — Automatic Exchange

CBDT compiles the data from all Indian financial institutions and transmits it to the tax authorities of participating jurisdictions through secure channels established under the MCAA. Simultaneously, India receives data about Indian tax residents holding accounts abroad from the tax authorities of other CRS-participating countries.

Who Must Comply With CRS in India?

CRS obligations fall on Reporting Financial Institutions, which include:

Non-financial entities (like your Indian operating company) do not report under CRS directly. However, when the Indian company opens a bank account or holds investments, the bank or custodian performs CRS due diligence on the entity and its controlling persons — which includes the foreign shareholders and directors.

CRS and the Foreign Investor — What Gets Reported?

Here is what a foreign investor in India should expect to be reported under CRS:

Personal Bank Accounts

If you, as a foreign national, open an NRE account, NRO account, or FCNR account in India, the bank reports your account details to CBDT, which exchanges it with your home country. Every year, your home tax authority receives your Indian bank balance and interest income data.

Company Bank Accounts

When your Indian Private Limited Company opens a current account, the bank identifies the controlling persons — shareholders holding 25% or more (or the management team if no individual holds 25%). If the controlling person is a foreign tax resident, the account is reportable under CRS. The reported information includes the company's account balance and transactions, attributed to the controlling person's home jurisdiction.

Investment Accounts

If you hold Indian mutual funds, demat accounts, or insurance policies, these are reported. The reporting includes year-end values and income earned.

Controlling Person Reporting

This is the critical aspect for foreign investors who set up Indian companies. Even though the bank account is in the company's name, the bank identifies the foreign UBO as the controlling person and reports the account under CRS to the UBO's home jurisdiction. The threshold for "controlling person" under CRS aligns with the FATF recommendation — 25% ownership (note: this is different from the 10% UBO threshold under India's PMLA Rules).

Participating Jurisdictions

Over 100 jurisdictions participate in CRS automatic exchange with India. Key jurisdictions for foreign investors include:

The United States is the notable exception — it did not adopt CRS, relying instead on its own FATCA regime. However, India and the US exchange information bilaterally under the FATCA Intergovernmental Agreement (IGA).

CRS Self-Certification

When opening any financial account in India, you will be asked to complete a CRS Self-Certification Form. This form asks:

• Your country(ies) of tax residence
• Your Tax Identification Number (TIN) in each country of tax residence
• Your place and date of birth
• Whether you are a Politically Exposed Person (PEP)
• For entities — the entity type (active NFE, passive NFE, financial institution) and controlling person details

Providing false information on the self-certification is a punishable offense under Section 285BA(7) of the Income Tax Act — a penalty of INR 50,000 for each instance of false reporting.

What Happens With the Information?

Once your home country's tax authority receives CRS data about your Indian accounts, it uses the information for:

• Cross-matching with tax returns: If your Indian bank interest or dividend income does not appear on your home country tax return, you may receive a query or audit notice
• Wealth tracking: Year-end account balances help tax authorities verify reported net worth and identify potential undisclosed assets
• Risk scoring: Taxpayers with foreign accounts are flagged for higher scrutiny in many jurisdictions

India similarly receives CRS data from other countries about Indian tax residents holding foreign accounts — this data feeds into the Indian Income Tax Department's analytics and is used to identify undisclosed foreign income under the Black Money Act, 2015.

CRS and DTAA Implications

CRS data exchange does not itself create a tax liability. It is purely an information-sharing mechanism. Whether the income is taxable depends on the domestic tax laws and the applicable DTAA. However, CRS ensures that tax authorities have the information they need to apply their laws — the era of banking secrecy is effectively over for any CRS-participating jurisdiction.

Common Mistakes

• Not completing the self-certification form. Financial institutions are required to close or restrict accounts if the account holder fails to provide a self-certification within a reasonable period. Many foreign investors ignore these forms and then find their accounts frozen.
• Declaring the wrong tax residency. A UK citizen living in Dubai who has not properly terminated UK tax residency is still a UK tax resident for CRS purposes. CRS follows tax residency, not citizenship or physical residence.
• Forgetting that entity accounts are also reported. Many foreign investors assume CRS only applies to personal accounts. The Indian company's bank account is also reported if the controlling person is a foreign tax resident.
• Not reporting Indian income on home country tax returns. CRS means your home tax authority already has the data. Failing to report Indian bank interest, dividends, or capital gains on your home country return is now almost certain to be caught.
• Assuming small accounts are exempt. Unlike FATCA, CRS has no general de minimis threshold for individual accounts. Pre-existing entity accounts below USD 250,000 may be excluded from review, but new accounts of any size are subject to due diligence.

Practical Example

Yuki, a Japanese national and tax resident, owns 60% of an Indian SaaS company. Her Indian company has a current account with HDFC Bank with an average balance of INR 2.5 crores. Yuki also has a personal NRO account with INR 15 lakh.

What gets reported:

• Company account: HDFC Bank identifies Yuki as the controlling person (60% shareholder). The account is reportable under CRS. HDFC reports the company's account balance (INR 2.5 crores) and any interest earned to CBDT, identifying Yuki's Japanese TIN and tax residency.
• Personal NRO account: The NRO account is directly reportable. HDFC reports the balance (INR 15 lakh) and interest earned to CBDT.
• CBDT exchanges this data with Japan's National Tax Agency (NTA) by September 2026 for the reporting year ending March 2026.
• Japan's NTA cross-references this data with Yuki's Japanese tax return. If she has reported her Indian interest income and claimed tax credit under the India-Japan DTAA, no issue arises. If she has not reported it, she may receive a notice from the NTA.

Key Takeaways

• CRS is a global automatic exchange standard — over 100 jurisdictions exchange data with India
• Indian financial institutions report account balances, interest, dividends, and proceeds to CBDT annually
• Foreign investors are identified through self-certification and indicia reviews
• Entity accounts are also reported — the foreign UBO/controlling person is identified and reported
• CRS self-certification is mandatory — failure can result in account restrictions and penalties
• The US uses FATCA instead of CRS, but India-US data exchange still occurs under the FATCA IGA
• CRS data is used for cross-matching with home country tax returns — non-disclosure is risky
• There is no general de minimis threshold for individual accounts under CRS

Need guidance on CRS compliance and reporting obligations for your India investment? Beacon Filing advises foreign investors on cross-border tax reporting and ensures your Indian accounts are properly declared.