CRS reporting in Ireland: Revenue, ROS and 30 June

CRS reporting in Ireland means one annual DAC2-CRS return to the Revenue Commissioners, filed through ROS by 30 June, and from the 2026 reporting year it reaches e-money institutions that used to sit outside it. Ireland adopts the CRS rules by reference to the OECD standard and the EU directive, so when those texts were updated, Finance Act 2025 and two statutory instruments effective 1 January 2026 brought Electronic Money and Central Bank Digital Currency into the Irish regime. The first return under the new rules covers 2026 and is due by 30 June 2027, in the CRS XML Schema version 3.0. An Irish reporting institution with nothing to report still files a nil return.

1. The legal basis: two sections, two sets of regulations

Two parallel instruments feed the same return, divided by the residence of the account holder.

• Section 891F TCA 1997, inserted by section 28 of Finance Act 2014, implements the OECD Common Reporting Standard. Its regulations are the Returns of Certain Information by Reporting Financial Institutions Regulations 2015, S.I. No. 583 of 2015, in force from 31 December 2015.
• Section 891G TCA 1997, inserted by section 74 of Finance Act 2015, implements Directive 2014/107/EU (DAC2). Its regulations are the Mandatory Automatic Exchange of Information in the Field of Taxation Regulations 2015, S.I. No. 609 of 2015, which cover EU Member State residents.
• The 2026 update: section 94 of Finance Act 2025 replaced the definition of “the standard” in section 891F(2) so that it now includes Part II of the OECD’s 2023 publication, the 2023 update to the CRS. S.I. No. 666 of 2025 made the same change in S.I. 583/2015, and S.I. No. 665 of 2025 updated S.I. 609/2015 so that “the Directive” includes Council Directive (EU) 2023/2226 (DAC8). Both came into operation on 1 January 2026.

Section 891F(10) and Regulation 2(3) of S.I. 583/2015 give every term the meaning it has in Section VIII of the standard. S.I. 609/2015 does the same by reference to Annex I of the directive. That is why the e-money definitions apply in Ireland without being copied into Irish text.

2. How DAC8 brings e-money into scope from 1 January 2026

Directive (EU) 2023/2226 rewrote Section VIII of Annex I to Directive 2011/16/EU. Article 2(1) required Member States to apply those changes from 1 January 2026. Four changes matter to an e-money business:

• Depository Institution now also means an entity that holds E-money or Central Bank Digital Currencies for the benefit of customers.
• Electronic Money is defined as a product that digitally represents a single fiat currency, is issued on receipt of funds to make payment transactions, is a claim on the issuer in that currency, is accepted by people other than the issuer and, because of the issuer’s regulatory regime, can be redeemed at par at any time. The OECD text calls these Specified Electronic Money Products.
• The transfer-only carve-out: a product created only to move a customer’s funds to another person on the customer’s instructions is not E-money. It loses that status if, in the ordinary course of business, the funds are held for more than 60 days after the instruction, or more than 60 days after receipt where no instruction comes.
• Depository Account now covers an account or notional account that represents all the E-money held for a customer.

S.I. 666/2025 and S.I. 665/2025 also stop central banks and governmental entities being non-reporting when they maintain Central Bank Digital Currencies for ordinary account holders.

3. The USD 10,000 exclusion and the new account timeline

DAC8 added a new Excluded Account. A Depository Account representing all the E-money held for a customer is excluded if its rolling 90-day average end-of-day balance never went above USD 10,000 on any day of the calendar year or other reporting period.

The test is daily and rolling, not a year-end snapshot, and runs per customer across all their e-money. It removes accounts, not institutions. An EMI whose wallets all stay small is still a Reporting Financial Institution with a filing obligation.

S.I. 666/2025 also sets the account timeline. An account that became a Financial Account solely because of the 2023 update is a Preexisting Account if it was maintained on 31 December 2025, and a New Account if it was opened on or after 1 January 2026. Regulation 6(7) of S.I. 583/2015 allows a euro equivalent of dollar thresholds at the prior year-end spot rate.

4. Who reports what: the wider approach

Revenue’s Tax and Duty Manual Part 38-03-23 confirms that Ireland adopted the “wider approach” to due diligence. S.I. 583/2015 defines a Reportable Jurisdiction as any jurisdiction other than the State and the United States. An Irish institution therefore collects residence and TIN for every non-resident customer and reports all of them except US persons, who are handled under FATCA. Revenue’s CRS page says exchanges take place by 30 September each year.

Two consequences for a payments business:

• Customer Information Notices. Individual account holders, and controlling persons asked for a self-certification, must receive one, and privacy notices must refer to CRS.
• No account without a self-certification. Revenue states that an account cannot be opened in Ireland without a valid self-certification. Where an institution follows the OECD’s FAQ 22 approach, the process to obtain and validate one should not take longer than 90 days. S.I. 665/2025 adds a fallback for DAC2: if a self-certification for a new account was not obtained in time, preexisting-account procedures apply until it is. Treat that as a safety net, not a process.

5. What the return must contain from 2026

S.I. 666/2025 and S.I. 665/2025 amend Regulation 3(2) of each set of regulations, with effect from 1 January 2026. Each reportable account must now show:

• for each individual reportable person: name, address, jurisdiction(s) of residence, TIN(s), date and place of birth, and whether a valid self-certification was provided;
• for each controlling person: the same identifiers, the role or roles that make them a controlling person, and whether a valid self-certification was provided;
• whether the account is joint and, if so, how many joint holders it has;
• the account number or its functional equivalent, the type of account, and whether it is preexisting or new;

For an EMI, the reported balance is the year-end value of the customer’s notional e-money account. The methodology for each field is covered in building the CRS return.

6. ROS: registration, upload and the 2027 schema

Regulation 4 of S.I. 583/2015 requires returns to be filed electronically in the form Revenue requires. In practice that means ROS, as set out in Tax and Duty Manual Part 38-03-26, the DAC2-CRS filing guidelines.

Corrections use CRS702 messages. Two traps: ROS accepts # but the OECD schema does not, and a CRS102 or CRS103 entity account without a ResCountryCode is rejected. Firms that already file CESOP through ROS will recognise the registration pattern. CRS needs its own reporting obligation.

7. Penalties and audit powers

Section 891F(7) and section 891G(7) apply section 898O TCA 1997 to a failure to deliver a return and to an incorrect or incomplete one. Revenue’s Notes for Guidance (Finance Act 2025 edition) put the penalty for failing, without reasonable excuse, to make a return, or for making an incorrect or incomplete one, at EUR 19,045. A further EUR 2,535 applies for each day the return remains outstanding. Failure to comply with a Revenue officer’s requirements, or with any other requirement of the regulations, carries a penalty of EUR 1,265.

Authorised Revenue officers may enter the premises to test the return, including what was left out, and the procedures behind it. Under Regulation 9 of S.I. 583/2015, a written request for information must give at least 14 days to respond. Regulation 7 requires records of the procedures applied and the information relied on to be kept for six years from the end of the year concerned. Section 891F(9) disregards arrangements made mainly to avoid the obligations.

8. Worked scenarios

A. An Irish-authorised EMI with mostly small balances.

Facts: an EMI authorised by the Central Bank of Ireland issues euro and sterling wallets to consumers in Ireland, Spain, France and Germany. Nearly all balances are a few hundred euros. About 40 business customers peak above USD 10,000 during 2026.

Applicable rule: holding E-money for customers makes the EMI a Depository Institution from 1 January 2026. Each customer’s e-money across both currencies is one Depository Account. It is excluded only if the rolling 90-day average never went above USD 10,000. Irish-resident and US customers are outside CRS reporting.

What the practitioner does: registers the DAC2-CRS obligation in ROS well before June. Computes the daily rolling average per customer for the whole of 2026 and flags every account that breached it on any day. Runs preexisting procedures on wallets held at 31 December 2025 and relies on self-certifications for later ones. Builds a schema 3.0 file.

Outcome: a short data return covering the non-resident customers that breached the threshold, filed by 30 June 2027, with the daily calculation kept as evidence for six years.

B. A payment institution that holds only payment accounts.

Facts: an Irish payment institution runs payment accounts used only to execute transfers. Its ledger shows client funds are normally held for a few days at most.

Applicable rule: a product created only to transfer funds on the customer’s instructions is not E-money. The carve-out is lost only if funds are ordinarily held for more than 60 days after the instruction, or after receipt where there is none. Without E-money or deposits, the institution is not a Depository Institution.

What the practitioner does: extracts holding periods from the ledger and writes a scoping memo concluding that the institution is not a Financial Institution. Checks no other activity, such as custody, changes that. Reviews it after any product change.

Outcome: no DAC2-CRS obligation and no nil return, because the regulations bind only Reporting Financial Institutions. A reasoned memo stands ready for a Revenue audit.

C. A nil-return year.

Facts: an Irish EMI concludes that no customer’s rolling 90-day e-money balance exceeded USD 10,000 in 2026.

Applicable rule: Regulation 3(1)(b) of both sets of regulations requires a return stating that there were no reportable accounts. Missing it brings section 898O into play.

What the practitioner does: checks the DAC2-CRS obligation is registered (allowing three working days), files the nil return in ROS before 30 June 2027 and keeps the threshold calculation with the ROS notice.

Outcome: the EMI is on record as compliant, rather than indistinguishable from one that never filed.

9. FAQ

10. What to do, today

• Head of compliance: write a 2026 CRS scoping memo under the amended definitions, covering e-money, the 60-day transfer carve-out and any other activity.
• Data lead: build the daily rolling 90-day balance per customer across all currencies, back to 1 January 2026, and tag every account as preexisting or new.
• Onboarding: block account opening without a valid self-certification, issue Customer Information Notices, and record whether each self-certification was obtained, because the return now says so.
• Head of reporting: confirm ROS access and the DAC2-CRS obligation now, and test a schema 3.0 file before the spring. If nothing is reportable, diary the nil return.

Related: CRS reporting compared across six EU states · ACD CRS reporting in Luxembourg · CRS for EMIs · CESOP in Ireland through ROS