Article by Andy Hatton, Director, Funds

Automatic Exchange of Information has been part of Guernsey’s fund administration landscape for many years. FATCA and CRS are familiar to most of us now, but 2026 feels different.

The introduction of CRS 2.0, the continuing evolution of FATCA reporting, and the increasing focus on data quality mean AEOI can no longer be treated as a once-a-year reporting exercise. For Guernsey, CRS 2.0 became effective from 1 January 2026 through amendments implementing the OECD’s 2023 revisions to the Common Reporting Standard.

For fund administrators, the focus is shifting. It is no longer just about getting a file submitted by the deadline. It is about having the right framework, the right data, the right controls and the right culture in place throughout the year.

Starting with a blank canvas

When Imperium Funds was set up as a greenfield business, we had the opportunity to build our FATCA and CRS approach from the ground up.

That meant creating policies, procedures and manuals that were practical, not theoretical. The aim was to give staff a clear framework for consistent investor classification, self-certification review, reporting preparation and escalation.

It also meant designing the operational process properly from the start. Rather than relying on manual preparation at the reporting deadline, we built a process centred on automation from one core system. That gives greater efficiency, reduces the risk of transcription errors and puts the focus where it should be: ensuring the source data is accurate throughout the year.

This is a key point. If the source data is wrong, the report will be wrong. Automation does not remove the need for oversight, it makes data quality more visible. It encourages better onboarding, better ongoing review, trigger event review and fewer last-minute scrambles to complete all of the filing by the deadline.

In my role at Imperium, I can attest that the final filing is only one part of the journey. The real work starts much earlier, with onboarding, investor data, system records, exception management and ongoing review.

What is changing now?

CRS 2.0 brings a sharper focus on data completeness and accuracy. Areas such as self-certification, Controlling Person information, account type, joint account indicators and whether an account is new or pre-existing all become more important operationally.

The OECD has also released the amended CRS XML Schema and User Guide to support the updated CRS framework. In parallel, FATCA remains its own reporting regime, with separate IRS schema and validation requirements.

For Guernsey Reporting Financial Institutions, the immediate 2026 task remains the 2025 FATCA and CRS reporting cycle, with reports due by 30 June 2026 and late filing penalties applying after that date.

But the wider point is that the quality of the June submission is determined long before June.

The real challenge for fund administrators

The challenge we all face is that AEOI sits across multiple parts of the business. Investor services, onboarding, compliance, operations, systems, relationship teams and senior management all play a part.

A self-certification may be collected by one team, reviewed by another, stored in a system, referenced in a report and relied upon by the Responsible Officer. If any part of that chain is weak, the final reporting process becomes harder.

That is why I believe AEOI should be viewed as an operational framework, not just an end of cycle tax reporting obligation.

Some of the common pressure points are:

●      incomplete or outdated self-certifications

●      investor data held outside core systems

●      unclear entity classifications

●      Passive NFE and Controlling Person analysis

●      country code or currency errors

●      inconsistent name or account identifier data

●      late queries close to the reporting deadline

●      reliance on manual spreadsheets rather than embedded controls

These are not just technical issues. They are governance issues.

Building a framework that improves over time

No framework is perfect on day one. The important thing is to build something structured, use it, test it and improve it.

A strong FATCA and CRS framework should be reviewed regularly. It should capture lessons from each reporting cycle. It should identify recurring data issues. It should feed back into onboarding, training, system design and management reporting.

In practical terms, that means asking questions such as:

●      Are our self-certification forms still fit for purpose?

●      Can we extract the required CRS 2.0 data from our systems?

●      Are Controlling Person roles clearly recorded?

●      Do our teams understand the difference between FATCA and CRS?

●      Are board and management updates focused on risk, not just completion?

Final thought

AEOI in Guernsey is entering a new phase.

The focus for fund administrators should not simply be “Can we file by the deadline?” It should be “Do we have a framework that gives us confidence in the data, the process and the evidence behind the filing?”

That takes planning, stakeholder engagement, training, system discipline and continuous improvement.

In my experience, the strongest compliance frameworks are not built overnight. They are built iteratively, with each reporting cycle teaching us something new. Progress, not perfection.

And that is where the real value sits: not just in submitting a report, but in building a process that is understood, trusted and capable of standing up to scrutiny.

This article is a general reflection and not tax or legal advice. Firms should always refer to the latest Guernsey Revenue Service, OECD and IRS guidance for their specific obligations.