CRS 2.0—What’s changing and why Singapore needs to act now

Most Singapore financial institutions (FIs) are quietly assuming Common Reporting Standard (CRS 2.0) is a minor upgrade. It isn’t.

The Organisation for Economic Co-operation and Development (OECD)’s release of the Crypto-Asset Reporting Framework (CARF) and the amended CRS 2.0 signals a paradigm shift in global tax transparency. For many, the focus has been on crypto—understandably so. But the quiet transformation of CRS deserves more attention. It represents one of the most significant rewrites to automatic exchange obligations since the standard was first introduced.

Singapore has much to gain—or lose—depending on how quickly and strategically it prepares.

What’s changing under CRS 2.0?

At its core, CRS 2.0 builds on the foundations of Foreign Account Tax Compliance Act (FATCA) and original CRS, but introduces a more robust, digital-era-ready framework. Key changes include:

1. Expanded scope of reportable account types
   CRS 2.0 expands definitions to capture more sophisticated financial arrangements, including certain electronic money products and central bank digital currencies (CBDCs).
2. New crypto-asset classification and look-through rules
   While primarily housed in CARF, CRS 2.0 introduces overlapping due diligence and reporting expectations for financial institutions dealing indirectly with crypto holdings or derivatives.
3. Tax Identification Numbers (TINs) take center stage
   CRS 2.0 mandates expanded collection and verification of TINs, especially in cases where previously optional or discretionary.
4. Pre-existing account due diligence recalibrated
   The new standard reduces reliance on grandfathering rules, requiring more rigorous remediation of pre-existing accounts—a significant operational lift.
5. Third-party reliance and governance frameworks tightened
   Increased scrutiny is placed on how institutions rely on external vendors, service providers, and IT platforms—with expectations of documented controls and oversight.

Singapore’s CRS 2.0 & CARF implementation timeline

On 26 June 2025, the Inland Revenue Authority of Singapore (IRAS) officially confirmed that Singapore will implement the amended CRS. This follows its earlier signing of the CRS Addendum to the Multilateral Competent Authority Agreement (MCAA) in November 2024. Singapore has also signed on to the CARF MCAA, committing to enhanced transparency on crypto-asset holdings.

Important Note: While other jurisdictions may require earlier changes to data collection processes (e.g., from 2026), Singapore has not yet prescribed specific transitional requirements. FIs should therefore monitor IRAS guidance closely and assess timelines based on internal readiness and global best practices.

Why this matters to Singapore

While CRS 2.0 may appear incremental at first glance, it introduces changes that could materially reshape how Singapore-based FIs approach compliance. Here’s why:

1. Legacy assumptions don’t hold up anymore
   The old CRS design assumed relatively simple financial product structures. That’s no longer the case. Many Singapore FIs now deal with complex fund platforms, discretionary mandates, or trustee relationships that require careful re-mapping.
2. Regulatory momentum is picking up
   Jurisdictions like the European Union (EU), Australia, and Hong Kong have begun formal consultations or transition planning. Singapore has not yet released an implementation roadmap, but this may give a false sense of breathing room.
3. The cost of inaction can be high
   Waiting too long may force rushed implementation, creating gaps in controls, inaccurate reporting, or audit exposure. System overhauls require long lead times, hence early groundwork would help in smoother transitions later.

A new era for Automatic Exchange of Information (AEOI) governance

CRS 2.0 isn’t just about new data fields—it demands a shift in mindset. FIs will need to:

• Reassess their end-to-end reporting flows: From onboarding and classification to file generation and validation
• Build flexible data architectures: Especially to accommodate new asset types and look-through logic for enhanced reporting on controlling persons
• Embed defensible controls and key risk indicators (KRIs): To monitor data accuracy, timeliness, and residual tax risk exposure
• Training and board awareness: As part of wider tax governance and operational risk controls

Those that treat this as a compliance formality will miss the chance to future-proof their frameworks.

CRS 2.0 is not the end of tax transparency evolution; it is the beginning of a much more integrated, digital regime. Those who act early will not just comply—they will set the standard for the region.

Integrating CRS 2.0 into Existing CLM Processes

To maximise efficiency and avoid duplicative effort, financial institutions should embed CRS 2.0 requirements into their existing Customer Lifecycle Management (CLM) processes to the extent possible. This includes updating onboarding workflows to capture relevant CRS-related information upfront, and enhancing customer risk classification frameworks to reflect CRS, FATCA, and other relevant tax risk factors. Doing so ensures tax transparency considerations are integrated seamlessly into broader financial crime and compliance risk management practices.

How Deloitte can help

At Deloitte, we bring together deep AEOI expertise with practical implementation experience, collaborating across our Forensic, Financial Crime, and technology specialists to integrate CRS 2.0 requirements into clients’ customer lifecycle and risk management processes. As part of our end-to-end offerings, we work with clients to develop:

• CRS 2.0 impact assessments and roadmaps
• Governance and control frameworks with defensible KRIs
• Training sessions to equip the front-line staff and other relevant stakeholders
• Review internal controls, data dependencies, and perform reportability assessment

If you are unsure where your firm stands, we would be happy to explore a diagnostic approach tailored to your operating model and risk profile.