On 22 September 2026, the State Tax Service of Ukraine (STS) published an official announcement inviting reporting financial institutions and their authorized intermediaries to a dedicated workshop on the application of CRS 2.0, the updated Common Reporting Standard developed by the OECD for the automatic exchange of financial account information. The workshop is scheduled to address the significant enhancements introduced in the second edition of the CRS, which expand the scope of reportable accounts, strengthen due diligence procedures for identifying controlling persons of passive entities, and impose stricter data quality and validation requirements. Ukraine, as a committed participant in the Multilateral Competent Authority Agreement (MCAA) on Automatic Exchange of Financial Account Information, is aligning its domestic legislation and reporting infrastructure to meet the CRS 2.0 implementation timeline, with the first reporting under the new standard due in 2028 for the 2027 calendar year. The STS emphasized that the workshop will cover both the legislative amendments to the Tax Code of Ukraine that transpose CRS 2.0 into national law and the technical specifications for reporting via the STS Electronic Cabinet, including the updated XML schema and validation rules. This initiative forms part of the broader National Revenue Strategy to enhance international tax transparency and combat cross-border tax evasion.
Key Takeaways
- Mandatory Participation for Reporting Financial Institutions: The STS has indicated that all Ukrainian financial institutions — including banks, custodial institutions, investment entities, and specified insurance companies — as well as non-resident financial intermediaries providing services to Ukrainian reportable persons, are expected to attend. The workshop will detail the expanded due diligence procedures for new and pre-existing accounts, the revised definition of “Reportable Person” to include additional entity types, and the enhanced requirements for identifying controlling persons of passive non-financial entities.
- Technical Implementation and Reporting Timeline: A core focus of the workshop will be the technical migration from CRS 1.0 to CRS 2.0 reporting formats. The STS will present the updated XML schema (CRS 2.0), new validation rules, and the mandatory data elements such as the CRS 2.0 specific “Account Holder Type” codes and “Controlling Person Type” codes. Participants will receive guidance on the transition timeline, including the final deadline for updating internal systems and the schedule for test submissions through the STS Electronic Cabinet before the first live reporting period in 2028.
- Compliance Enforcement and Penalty Framework: The announcement reiterated that failure to comply with CRS 2.0 obligations will attract administrative penalties under Article 123 of the Tax Code of Ukraine, including fines for late, incomplete, or inaccurate reporting. The STS urged institutions to conduct immediate gap analyses of their current compliance programs, update client onboarding and account opening procedures, and ensure staff training is completed by 1 January 2027. The workshop will also address the interplay between CRS 2.0 and existing FATCA obligations, highlighting areas where streamlined compliance processes can be achieved.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement