THE REGULATORY 15/15
Podcast
December 2025
Speakers
Chris Capewell
Partner
+1 345 814 5666
chris.capewell@maples.com
Jo Ottaway Associate +1 345 814 5511
jo.ottaway@maples.com
Mariana Alves Associate +1 345 814 5429
mariana.alves@maples.com
Michelle Bailey Senior Vice President +1 345 814 5711
michelle.bailey@maples.com
Content
• 2026 Cayman Islands Regulatory Calendar
• Regulatory Round-Up Blog
• Year End Reminders
• Common Reporting Standard ("CRS") 2.0
Introduction
Introduction to the 15/15
• A 15-minute summary of the latest developments in the regulatory laws of the Cayman Islands released on the 15th day of every month
• A copy of the previous 15/15 released on 14 November can be accessed on our website: Maples 15/15
• Comments and suggestions to format of the 15/15 are always welcome –please email speakers directly
Maples Group Resources
• 2026 Cayman Islands Regulatory Calendar is now live on maples.com
• Access it here: 2026 Cayman Islands Regulatory Calendar
• Regulatory Round-Up Blog
• Visit our blog for continued, timely regulatory updates across the Cayman Islands, BVI, Jersey, Luxembourg and Ireland
• Subscribe for blog update for advance / exclusive access to Maples content
Regulatory Round-Up Blog
The latest developments and insights in the regulatory landscape.
Year-End Reminders
Year-End Reminders
• Economic Substance – Upcoming ESR filing deadline for entities with end of December fiscal year end
• Beneficial Ownership – Be aware of the new Act and requirements. Determine your obligations and provide information to your CSP now!
• Terminating Entities – Regulatory Obligations
• AEOI – Must complete filings and deactivate from the DITC Portal
• AML – Ensure all CDD records are complete prior to making final distributions and terminating the entity
• Economic Substance – Must satisfy all obligations (including the economic substance test) until wound up or dissolved
• CIMA-regulated entities (including mutual funds and private funds) must comply with all CIMA deregistration obligations
CRS 2.0
CRS 2.0 - Background
• "Common Reporting Standard" ("CRS") is a global standard for the automatic exchange of Financial Account information for tax purposes, which was developed by the OECD
• CRS has been in effect in the Cayman Islands since 1 January 2016
• It was implemented domestically by the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations (As Revised) ("CRS Regulations")
• OECD updated the CRS in 2023. The updated CRS is known as "CRS 2.0"
• Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 ("CRS Amendment Regulations") published in the Cayman Islands Gazette on 27 November 2025
• The CRS Amendment Regulations will take effect from 1 January 2026 (with certain items coming into effect in 2027).
CRS 2.0: Due diligence requirements
• Regulation 7 has been amended to make it clearer to FIs what activities need to be carried out from a due diligence perspective
Currently under CRS CRS 2.0
7. Required policies and procedures for Cayman Reporting Financial Institutions
(1) Each Cayman Reporting Financial Institution shall —
(a) establish and maintain written policies and procedures to comply with this Part; and
(b) implement and comply with the policies and procedures.
(2) Without limiting regulation 7(1), the policies and procedures shall —
(a) identify each jurisdiction in which an Account Holder or a Controlling Person is resident for income tax or corporation tax purposes or for the purpose of any tax imposed by the law of the jurisdiction that is of a similar character to either of those taxes;
(b) apply the due diligence procedures set out in the Common Reporting Standard; and
(c) ensure that any information obtained in accordance with this Part or a record of the steps taken to comply with this Part in respect of a Financial Account is kept for six years from the end of the year to which the information relates or during which the steps were taken.
7. Required due diligence for Cayman Financial Institutions
(1) Each Cayman Financial Institution shall establish, implement, maintain and comply with written policies and procedures that comply with the reporting and due diligence requirements set out in Sections II to VII of the Common Reporting Standard.
(2) Without limiting paragraph (1), the policies and procedures shall —
(a) identify each jurisdiction in which an Account Holder or a Controlling Person is resident for tax purposes;
(b) apply the due diligence procedures set out in Sections II to VII of the Common Reporting Standard;
(c) ensure that valid self-certifications, in accordance with paragraph (4) are collected; and
(d) ensure that any information obtained in accordance with this Part, or a record of the steps taken to comply with this Part, in respect of a Financial Account is kept for at least six years from the end of the year to which the information relates or during which the steps were taken.
CRS 2.0: Due diligence requirements (cont.)
• Regulation 7 also requires a Cayman FI to collect a "valid" self-certification for new accounts, and specifies what is required for a "self-certification" to be valid
under CRS
Regulation 7 (Cont'd)
(3) A Cayman Reporting Financial Institution is deemed to have contravened the policies and procedures relating to a self-certification or documentary evidence (the "instrument") if the institution
(a) knows, or has reason to believe, the instrument is inaccurate in a material way for the policies and procedures; and (b) it makes a return that relies on the instrument's accuracy.
Regulation 7 (Cont'd)
(3) Subject to the paragraph headed "Abis. Temporary lack of Self-Certification." set out in Section VII of the Common Reporting Standard, each Cayman Financial Institution shall collect a valid self-certification, in accordance with paragraph (4), for new accounts, on or before the date a Financial Account is opened.
(4) In order for a self-certification to be valid it shall include the following current information with respect to —
(a) Individual Account Holders and Controlling Persons —
(i) name; (ii) permanent residence address; (iii) the jurisdiction(s) of residence for tax purposes; (iv) TIN or functional equivalent for each Reportable Jurisdiction; (v) date of birth; (vi) place of birth; (vii) signature or attestation of the form; and
(viii) date of signature or attestation; and
(b) Entity Account Holders —
(i) name; (ii) address; (iii) the jurisdiction(s) of residence for tax purposes;
(iv) TIN or functional equivalent for each Reportable Jurisdiction;
(v) the type of Reporting Financial Institution, Non-Reporting Financial Institution or Non-Financial Entity, the entity is;
(vi) signature or attestation of the form; and
(vii) date of signature or attestation.
(5) In this regulation, "resident for tax purposes" means resident for income tax or corporation tax purposes or for the purpose of any tax imposed by the law of the jurisdiction that is of a similar character to either of those taxes; and "residence for tax purposes" is to be construed accordingly.
CRS 2.0: Registration requirements
• Registration date for Cayman FIs will be 31st January (not 30th April)
• Changes to the "required information" must be submitted within 30 days of the change via a "change form"
Currently under CRS CRS 2.0
8. Obligation of Cayman Financial Institutions to notify certain information
(1) Each Cayman Financial Institution, other than an exempted body, shall give the Authority —
(a) a notice (an "information notice") stating the required information about the institution on or before —
(i) 30th April 2017; or (ii) if an entity becomes a Cayman Financial Institution after that date, the next 30th April after the entity became a Cayman Financial Institution; and (b) if any of the required information so notified changes, a notice stating details of the change (a "change notice").
8. Obligation of Cayman Financial Institutions to notify certain information
(1) Each Cayman Financial Institution, other than an exempted body, shall submit to the Authority —
(a) subject to paragraph (3A), a registration form stating the required information about the institution on or before the next 31st January, if the entity became a Financial Institution in the previous calendar year; and (b) if any of the required information so notified changes, a notice stating details of the change (a "change form"), and any change form shall be submitted within thirty days after the change occurring.
(2) A registration form or change form shall be adequate, accurate and current and shall be given through the electronic portal in the form and manner specified by the Authority.
…
(3A) A Cayman Financial Institution, other than an exempted body that became a Financial Institution in 2025, shall submit the registration form stating the required information about the institution on or before 30th April, 2026.
CRS 2.0: "Required information"
• A number of changes to the "required information" to be included in the registration form
• Importantly, PPoC must now be a person in the Cayman Islands
Regulation 8 (Cont'd)
(4) In this regulation –
"required information", for a Cayman Financial Institution, means —
(a) the institution's name and any number given to it by the Authority as a Financial Institution;
(b) whether the institution is a Cayman Reporting Financial Institution or a Non-Reporting Financial Institution; and
(c) if the institution is a Cayman Reporting Financial Institution, its type or types under paragraph B of Section VIII of the standard;
(d) if the institution is a Non-Reporting Financial Institution, its classification under paragraphA of Section VIII of the standard; and
(e) the full name, address, business entity, position and contact details (including an electronic address) of —
(i) a person the institution has authorised to be its principal point of contact for compliance with this Part; and
(ii) except in circumstances specified by the Authority, another person the institution has authorised to give change notices for its principal point of contact.
Regulation 8 (Cont'd)
(4) In this regulation –
"required information", for a Cayman Financial Institution, means —
(a) the institution's name and any number given to it by the General Registry, Cayman Islands MonetaryAuthority, or other regulatory or supervisory body;
(b) whether the institution is a Cayman Reporting Financial Institution or a NonReporting Financial Institution;
(c) if the institution is a Cayman Reporting Financial Institution, a correct statement of its classification under Section VIII(A) of the Common Reporting Standard;
(d) if the institution is a Non-Reporting Financial Institution, a correct statement of its classification under Section VIII(B) of the Common Reporting Standard;
(e) the date the entity became a Financial Institution; and
(f) the full name, address, business entity, position and contact details (including an electronic address) of —
(i) a person, in the Islands, that the institution has authorised to be its principal point of contact for compliance with this Part; and
(ii) except in circumstances specified by the Authority, another person the institution has authorised to give change forms for its principal point of contact.
CRS 2.0: "Required information" (cont.)
• There are transitional arrangements for the new PPoC requirement
• Entities registered as FIs with the DITC prior to the commencement of the CRS Amendment Regulations have until 31 January 2027 to notify the DITC of a PPoC in the Islands
None Regulation 8 (Cont'd)
(3B) Where, prior to the commencement of the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025, a Cayman Financial Institution —
(a) was registered with the Authority; and
(b) has not notified the Authority of a person in the Islands authorised to act as its principal point of contact for compliance with this Part, the Cayman Financial Institution shall, on or before 31st January 2027, submit a change form to the Authority notifying the Authority of the person in the Islands whom it has authorised to act as its principal point of contact for compliance with this Part.
CRS 2.0: Reporting requirements
• Reporting deadlines for CRS Returns and Compliance Form will be 30 June commencing 30 June 2027
Currently under CRS CRS 2.0
9. Obligation to make a return
(1) Each Cayman Reporting Financial Institution shall, for each calendar year —
(a) make a return to the Authority for each ReportableAccount the institution maintained during the year setting out the information required to be reported under the Common Reporting Standard; or
(b) if the institution did not maintain any Reportable Account in any Reportable Jurisdiction during the year, make a nil return, and provide to the Authority information reasonably required by the Authority to ensure effective implementation of, and compliance with, the reporting and due diligence procedures in accordance with the Common Reporting Standard.
(2) Repealed.
(3) Repealed.
(4) A Cayman Reporting Financial Institution shall make a return on or before 31st July of the year following the calendar year to which the return relates.
9. Obligation to make a return and a compliance form
(1) Each Cayman Financial Institution, shall in each calendar year —
(a) make a return to the Authority for each ReportableAccount the institution maintained during the year in accordance with the requirements specified in Section I of the Common Reporting Standard; or
(b) if the institution did not maintain any ReportableAccount in a Reportable Jurisdiction during the year, make a nil return for that Reportable Jurisdiction, on or before the 30th of June of the year following the calendar year to which the return relates, together with a declaration made by the Cayman Financial Institution that states that the information provided in the return is adequate, accurate and current.
(2) Subsequent to the filings required under paragraph (1), a Cayman Financial Institution shall, for each calendar year, make and submit to the Authority a compliance form on or before the 30th of June of the year following the year to which the compliance form relates, together with a declaration made by the Cayman Financial Institution that states that the information provided in the compliance form is adequate, accurate and current.
CRS 2.0: Reporting requirements (cont.)
• New requirement for information reported to be "adequate, accurate and current"
Currently under CRS
Regulation 9 (Cont'd)
(5) For the purposes of the information required to be reported under a relevant scheduled Agreement —
(a) a reference to the balance or value of an account includes a nil balance or value; and
(b) a reference to paying an amount includes crediting an amount.
Regulation 9 (Cont'd)
(3) A Cayman Financial Institution shall provide to the Authority information reasonably required by the Authority to ensure effective implementation of, and compliance with, the reporting and due diligence procedures in accordance with the Common Reporting Standard.
(4) For the purposes of the information required to be reported under the Common Reporting Standard —
(a) a reference to the balance or value of an account includes a nil balance or value; and
(b) a reference to paying an amount includes crediting an amount.
(5) The information provided under this regulation shall be adequate, accurate and current.
(6) The Authority may require corrections to the return and compliance form by notice issued to the relevant Cayman Financial Institution and shall, in the notice, specify the date by which the corrections shall be made.
CRS 2.0: Continuing penalties
• There will be a limit on the imposition of continuing penalties, which will effectively cap penalties at $50,000
Currently under CRS
24. Power to penalise
(1) Subject to complying with regulations 28 to 31, the Authority may impose a penalty of the following amount (a "primary penalty") for offences against Part 3
(a) for the following, $50,000 —
(i) for an offence by a body corporate; or
(ii) for an offence by an individual who forms, or forms part of, an unincorporated Cayman Financial Institution; or
(b) otherwise, $20,000.
(2) Also, if —
(a) a primary penalty has been imposed, which penalty has not been stayed;
(b) the contravention has not been remedied; and
(c) the party is capable of remedying the contravention, the Authority may impose further penalties on the party of $100 for each day the contravention continues (each a "continuing penalty").
(3) For regulation 24(2)(c), insufficiency of funds or reliance on an agent appointed under regulation 11 (or anyone else) does not, of itself, make the party incapable of remedying the contravention.
(4) A penalty becomes a debt owing by the party to the Crown thirty days after the penalty is imposed.
24. Power to penalise
CRS 2.0
(1) Subject to complying with regulations 28 to 31, the Authority may impose a penalty of the following amount (a "primary penalty") for offences against Part 3 —
(a) for the following, $50,000
(i) for an offence by a body corporate; or
(ii) for an offence by an individual who forms, or forms part of, an unincorporated Cayman Financial Institution; or (b) otherwise, $20,000.
(2) Also, if —
(a) a primary penalty has been imposed, which penalty has not been stayed; (b) the contravention has not been remedied; and (c) the party is capable of remedying the contravention, the Authority may impose further penalties on the party of $100 for each day the contravention continues (each a "continuing penalty").
(3) For regulation 24(2)(c), insufficiency of funds or reliance on an agent appointed under regulation 11 (or anyone else) does not, of itself, make the party incapable of remedying the contravention.
(3A) The Authority shall not impose a continuing penalty where a primary penalty in the amount of fifty thousand dollars is imposed under paragraph (1)(a).
(3B) Where the sum of the primary penalty and any continuing penalty imposed is fifty thousand dollars, the Authority shall not impose any additional continuing penalties.
(4) A penalty becomes a debt owing by the party to the Crown thirty days after the penalty is imposed.
CRS 2.0: Steps required to impose penalty
• The DITC is no longer required to issue a breach notice in relation to a breach of the reporting obligations
Currently under CRS CRS 2.0
Steps required to impose penalty
28. (1) The Authority can only impose a primary penalty by —
(a) giving the party a notice that complies with regulation 29 (a "breach notice");
(b) if regulation 30 applies, complying with that regulation; and
(c) giving the party a notice that complies with regulation 31 (a "penalty notice").
(2) The Authority can only impose a continuing penalty by giving the party a penalty notice.
(3) The same penalty notice may be given for two or more continuing penalties for the same primary penalty
Steps required to impose penalty
28. (1) Subject to paragraph (1A), where the Authority decides to impose a penalty, the Authority shall impose the primary penalty by —
(a) giving the party a breach notice;
(b) if regulation 30 applies, complying with that regulation; and
(c) giving the party a penalty notice.
(1A) In the case of a contravention of regulation 9, the Authority may impose a penalty by giving the party a penalty notice, without first having taken the steps under paragraph (1)(a) or (b).
(2) The Authority can only impose a continuing penalty by giving the party a penalty notice.
(3) The same penalty notice may be given for two or more continuing penalties for the same primary penalty
CRS 2.0: Interest
• The interest provision has been repealed
Currently under CRS
Interest
35. (1) Interest accrues on a penalty while all or any part of the penalty continues to be unpaid, starting on the day immediately after the penalty became owing under regulation 24(4) and ending on the day the penalty is paid in full, both days inclusive.
(2) The interest accrues at daily rests and as compound interest.
(3) The rate of the interest is the higher of the following —
(a) five percent; or
(b) the average percentage of the annual consumer price index and inflation rates for the most recent three calendar years published by —
(i) the Islands' Economics and Statistics Office (or any other similar body) under the Statistics Act (2016 Revision); or
(ii) if those rates cease to be published, the index that most closely performs the functions of publishing the rates.
(4) Payments relating to the penalty are to be applied to the interest first.
(5) The interest is also a debt owing to the Crown.
(6) The accruing of interest applies even if the penalty has been stayed, but is subject to regulation 34(3) and (4).
35. Repealed
CRS 2.0: New reporting requirements
• New information is required to be reported under CRS 2.0 in respect of each Reportable Account
Currently under CRS CRS 2.0
Section I: General Reporting Requirements
A. Subject to paragraphs C through E, each Reporting Financial Institution must report the following information with respect to each ReportableAccount of such Reporting Financial Institution:
1. the name, address, jurisdiction(s) of residence, TIN(s) and date and place of birth (in the case of an individual) of each Reportable Person that is an Account Holder of the account and, in the case of any Entity that is an Account Holder and that, after application of the due diligence procedures consistent with Sections V, VI and VII, is identified as having one or more Controlling Persons that is a Reportable Person, the name, address, jurisdiction(s) of residence and TIN(s) of the Entity and the name, address, jurisdiction(s) of residence, TIN(s) and date and place of birth of each Reportable Person; 2. the account number (or functional equivalent in the absence of an account number);
3. the name and identifying number (if any) of the Reporting Financial Institution;
4. the account balance or value (including, in the case of a Cash Value Insurance Contract or Annuity Contract, the Cash Value or surrender value) as of the end of the relevant calendar year or other appropriate reporting period or, if the account was closed during such year or period, the closure of the account;
Section I: General Reporting Requirements
A. Subject to paragraphs C through F, each Reporting Financial Institution must report the following information with respect to each ReportableAccount of such Reporting Financial Institution:
1. (a) the name, address, jurisdiction(s) of residence, TIN(s) and date and place of birth (in the case of an individual) of each Reportable Person that is an Account Holder of the account and whether the Account Holder has provided a valid self-certification;
(b) in the case of any Entity that is an Account Holder and that, after application of the due diligence procedures consistent with Sections V, VI and VII, is identified as having one or more Controlling Persons that is a Reportable Person, the name, address, jurisdiction(s) of residence and TIN(s) of the Entity and the name, address, jurisdiction(s) of residence, TIN(s) and date and place of birth of each Reportable Person, as well as the role(s) by virtue of which each Reportable Person is a Controlling Person of the Entity and whether a valid self-certification has been provided for each Reportable Person; and
(c) whether the account is a joint account, including the number of joint Account Holders.
2. the account number (or functional equivalent in the absence of an account number), the type of account and whether the account is a Pre-existing Account or a New Account;
3. the name and identifying number (if any) of the Reporting Financial Institution;
4. the account balance or value (including, in the case of a Cash Value Insurance Contract or Annuity Contract, the Cash Value or surrender value) as of the end of the relevant calendar year or other appropriate reporting period or, if the account was closed during such year or period, the closure of the account;
CRS 2.0: New reporting requirements
• New information is required to be reported under CRS 2.0 in respect of each Reportable Account
Currently under CRS
Section I: General Reporting Requirements (Cont'd)
5. in the case of any CustodialAccount:
a) the total gross amount of interest, the total gross amount of dividends, and the total gross amount of other income generated with respect to the assets held in the account, in each case paid or credited to the account (or with respect to the account) during the calendar year or other appropriate reporting period; and
b) the total gross proceeds from the sale or redemption of Financial Assets paid or credited to the account during the calendar year or other appropriate reporting period with respect to which the Reporting Financial Institution acted as a custodian, broker, nominee, or otherwise as an agent for the Account Holder;
6. in the case of any DepositoryAccount, the total gross amount of interest paid or credited to the account during the calendar year or other appropriate reporting period; and
7. in the case of any account not described in subparagraphA(5) or (6), the total gross amount paid or credited to the Account Holder with respect to the account during the calendar year or other appropriate reporting period with respect to which the Reporting Financial Institution is the obligor or debtor, including the aggregate amount of any redemption payments made to the Account Holder during the calendar year or other appropriate reporting period.
CRS 2.0
Section I: General Reporting Requirements (Cont'd)
5. in the case of any CustodialAccount:
a) the total gross amount of interest, the total gross amount of dividends, and the total gross amount of other income generated with respect to the assets held in the account, in each case paid or credited to the account (or with respect to the account) during the calendar year or other appropriate reporting period; and
b) the total gross proceeds from the sale or redemption of Financial Assets paid or credited to the account during the calendar year or other appropriate reporting period with respect to which the Reporting Financial Institution acted as a custodian, broker, nominee, or otherwise as an agent for the Account Holder;
6. in the case of any DepositoryAccount, the total gross amount of interest paid or credited to the account during the calendar year or other appropriate reporting period;
6bis in the case of any Equity Interest held in an Investment Entity that is a legal arrangement, the role(s) by virtue of which the Reportable Person is an Equity Interest holder; and
7. in the case of any account not described in subparagraphA(5) or (6), the total gross amount paid or credited to the Account Holder with respect to the account during the calendar year or other appropriate reporting period with respect to which the Reporting Financial Institution is the obligor or debtor, including the aggregate amount of any redemption payments made to the Account Holder during the calendar year or other appropriate reporting period.
CRS 2.0: Expanded to cover digital currencies
• CRS 2.0 updates the original CRS framework to reflect the evolving financial landscape
• It introduces new definitions, expands the scope to include Central Bank Digital Currencies (CBDCs), specified electronic money products, and derivatives referencing crypto-assets
CRS 2.0 - Practical considerations
• CRS Policies and procedures need to be updated to reflect CRS 2.0
• Self-certification templates will need to be updated
• Consider whether a new PPoC is required, and if so, submit a "change form" by 31 January 2027
• Make sure that CRS service providers are aware of CRS 2.0 and confirm whether the newly required data points are being collected
• Be aware of DITC Portal capacity issues – don't leave reporting to the last minute
• Remember any changes to the required information must be notified within 30 days
Key Dates
• 1 January 2026: CRS Amendment Regulations commence (other than Regulations 5 and 6)
• 30 April 2026: FIs that commence activities during 2025 will be required to register with the TIA by 30 April 2026
• 31 July 2026: CRS returns in respect of 2025 FY due
• 15 September: CRS compliance form in respect of 2025 FY due
• 1 January 2027: Regulations 5 and 6 of the CRS Amendment Regulations commence
• 31 January 2027: FIs registered with the TIA prior to the commencement of the CRS Amendment Regulations who have not appointed a PPoC in the Cayman Islands must appoint a PPOC in the Cayman Islands and notify the TIA by way of a change form by 31 January 2027
• 31 January 2027: FIs that commence activities during 2026 will be required to register with the TIA by 31 January 2027
• 30 June 2027: CRS returns and CRS compliance form in respect of 2026 FY due
This presentation was presented on, and is only accurate to [11] December 2025. The information within this presentation is provided for general guidance only, is not intended to be comprehensive and does not constitute legal advice or give rise to an attorney / client relationship.
Specialist legal advice should be taken in relation to specific circumstances. If you require legal advice, please reach out to your usual Maples and Calder contact.
Published by Maples and Calder (Cayman) LLP.
December 2025
Global Presence
