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Cayman Investment Funds — CARF and Amended CRS Go Live 1 January 2026

The Cayman Islands has implemented the Organisation for Economic Co-operation and Development’s (“OECD”) Crypto-Asset Reporting Framework (“CARF”) and made complementary changes to the Common Reporting Standard (“CRS”), which will each come into effect from 1 January 2026.

What this means for funds: Most Cayman investment funds will continue as Reporting Financial Institutions under the amended CRS and will not be CARF reporting entities unless they (or affiliates) operate exchange, brokerage, or intermediation services for crypto transactions as RCASPs (defined below). Funds trading crypto solely on their own account are generally outside CARF but remain in scope for CRS, including for indirect crypto exposures.

Key dates at a glance:

  • Go live 1 January 2026;
  • RCASP registration 30 April 2026;
  • CRS registration for new FIs 31 January in next calendar year;
  • First CARF and amended CRS reporting 30 June 2027;
  • Cayman resident PPoC notification 31 January 2027.

Click here to read the full advisory.

Simon Thomas - Partner, Campbells Grand Cayman - Private Equity

Simon Thomas

Partner, Head of Investment Funds & Co-Head of Corporate
+1 345 914 5843

Tim Dawson

Partner
+1 345 914 6941

Michelle Richie

Partner
+1 345 914 6933

Krista Wight

Counsel
+1 345 914 9621

Myfanwy Leggatt

Senior Associate
+1 345 914 6924