CRS Registration Now Required for Certain UK Investment Managers — Action Needed by 31 December 2025

The International Tax Compliance (Amendment) Regulations 2025, which came into force on 16 July 2025, introduce a new requirement for UK investment managers to register under the Common Reporting Standard (CRS) by 31 December 2025.

This is a shift from the previous position, under which UK asset managers were generally not obliged to register for CRS, and is aimed at increasing HMRC's visibility rather than creating new reporting obligations. In practice, as UK investment managers will generally maintain no 'financial accounts' on behalf of third parties for CRS purposes (such accounts instead being at the fund/SMA level), the new regulations should impose no additional reporting requirement following the initial registration. Similarly, for certain non-reporting financial institutions, there is a one-off registration requirement but generally no obligations to file nil CRS returns.

CRS is the OECD's Common Reporting Standard for the automatic exchange of financial account information between tax authorities. The UK signed up for the CRS regime in October of 2014 and began exchanging information with other jurisdictions from 2017.

For fund managers, the practical task is to identify all UK entities in the group that are treated as reporting financial institutions, confirm that classification, and register each such entity under CRS with HMRC. Registration can be made at this LINK. Failure to register may result in a civil penalty of up to £1,000 per entity, with additional daily penalties possible for continued non-compliance.

For any questions, please contact your usual Dechert team.