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.
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