Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2026 Update (June)

Cayman Islands

(Adopted by the Global Forum in June 2026)

The Cayman Islands joined the Global Forum in 2009. The Cayman Islands underwent its Second Round of EOIR Peer Review in 2017 (Cayman Islands’ 2017 Report),1 which assessed its legal and regulatory framework in force as of 24 May 2017 and its practical implementation, including in respect of EOI requests received and sent during the period from 1 April 2013 to 31 March 2016. The Cayman Islands received an overall rating of Largely Compliant, and the individual Elements were rated as follows:

 

	A.1	A.2	A.3	B.1	B.2	C.1	C.2	C.3	C.4	C.5	Overall
Determinations	i.p	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	n.a.	LC
Ratings	LC	LC	C	LC	C	C	C	C	C	C

Status of implementation of recommendations issued in the peer review report

The Cayman Islands received three in-box recommendations in relation to Elements A.1, A.2 and B.1.

This monitoring report assesses actions taken by the Cayman Islands to address the recommendations issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.

The report concludes that one recommendation is “in the process of being addressed”, while the other two recommendations “have not been addressed”. In addition, two new recommendations are issued to the Cayman Islands on timeliness of responses and provision of status updates. The report advises on actions required.

Element A.1: Availability of ownership and identity information

1. Implementation of the company approach and central register of beneficial ownership information

 

Recommendation (A.1, practice)	The Cayman Islands is recommended to monitor the practical implementation of the 2017 amendments to its company laws to ensure that beneficial ownership information is available for all relevant entities.
Underlying factor	Over the review period, whilst the Cayman Islands had a legal framework in place for beneficial ownership information to be maintained by almost all entities, there may have been a gap regarding a small number of ordinary resident and non-resident companies that did not engage a service provider. In 2017, the Cayman Islands introduced legal amendments to its company laws clarifying that all companies are now required to maintain beneficial ownership information. (see paragraphs 50, 86-88, 119-120, 132, 149, 166-167, 188 of the Cayman Islands’ 2017 Report for more information)
Summary of actions reported	Since 2020, all legal persons, including resident and non-resident companies, are required to keep a beneficial ownership register and report beneficial ownership information to the General Registry. To comply with these obligations, non-resident companies always engage a corporate service provider licensed and regulated by the Cayman Islands Monetary Authority, while around 46% of resident companies do so. In case of non-compliance, companies will not be able to file their annual returns, which may lead to their strike-off from the General Register. The consolidated Beneficial Ownership Transparency Act is in force since 31 July 2024 and has been updated in 2025 and 2026. Regulations and a binding guidance are in place to support the act. The Registrar monitors compliance through a system that does not allow entities to file annual returns if beneficial ownership information is missing. Non-compliance with annual return filing requirements may lead to striking off from the register. Further, since 2024, the regulations require any person having access to the beneficial ownership register (financial and non-financial AML-obliged persons and public authorities) to notify the Registrar of any identified discrepancies. The Registrar has imposed penalties for non-compliance with the beneficial ownership reporting obligations since December 2020. As of mid-2025, a total of nearly EUR 9 million fines had been issued to legal persons, corporate service providers and beneficial owners.
Conclusion	The Cayman Islands has made progress to address the recommendation through the implementation of the central beneficial ownership register and the enactment of a consolidated Beneficial Ownership Transparency Act. The revised definition of beneficial ownership of legal persons under the act is largely in line with the standard but does not provide for identification of all beneficial owners in line with the standard, especially if a trust is in the legal person’s ownership chain. Limited information is available on the supervision and enforcement of the beneficial ownership identification, reporting and updating requirements. Information has not been provided on the population of the beneficial ownership register, types of deficiencies noted and corrective actions undertaken where sanctions were imposed, the practical aspects of updating of beneficial ownership information and the mechanism in place to allow corporate service providers to issue restriction notices to beneficial owners that do not comply or cooperate in updating such information. The Cayman Islands should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, the Cayman Islands should – Clarify how the definition of beneficial owners under the legal framework will allow for identification of all beneficial owners in line with the standard, including where a trust is in a legal person’s ownership chain. Report on supervision of the obligations linked to the beneficial ownership register, including compliance rates and extent of population of the beneficial ownership register, updating of this information and outcomes of the supervisory activity and the enforcement measures taken.

Element A.2: Availability of accounting information

2. Monitoring compliance with requirements to keep accounting records, including those kept abroad

 

Recommendation (A.2, practice)	The Cayman Islands is recommended to implement an effective system of oversight and enforcement to support the legal requirements which ensure the availability of accounting information in all cases.
Underlying factor	Except for those entities that are subject to licensing with the CIMA [Cayman Islands Monetary Authority], no system of monitoring of compliance with accounting record keeping requirements is in place. In one case over the review period, the Cayman Islands was unable to access accounting information that was held outside the Cayman Islands by an exempted entity to provide to its treaty partner. Therefore, the lack of a comprehensive system of oversight of accounting obligations for all entities may not ensure that accounting information will be available in all cases. (see paragraphs 225-227, 238 of the Cayman Islands’ 2017 Report for more information)
Summary of actions reported	The Ministry of Financial Services and Commerce is working on introducing a mandatory obligation for all companies to annually file financial statements with the Registrar. This will be complemented by policies and procedures for monitoring compliance with this new obligation. Consultations on the project have taken place and data collection is planned to start by the end of 2026. During the monitoring period, the Cayman Islands did not face issues with obtaining accounting records for EOI purposes. In 2023 and 2024, the Cayman Islands received over 250 requests for accounting records and has responded to almost all of them, with less than ten remaining pending.
Conclusion	The Cayman Islands has taken preliminary steps to address the recommendation, but no material progress has been reported for a period of eight years. No specific measures to implement and enforce obligations to maintain accounting records have been provided. The planned policy and legislative changes are yet to take place. The Cayman Islands is urged to make substantive progress before its next self-assessment.
Status determined	Has not been addressed
Actions required	The Cayman Islands should submit a schedule for completion of steps to address the recommendation and an update on its progress made to address the recommendation by 31 March 2027. In particular, the Cayman Islands should – Report progress on the development and implementation of the planned changes in policy and the legal framework to ensure availability of accounting information with the General Registry. Report on steps taken to ensure availability of underlying documentation. Report on any EOI requests where accounting information could not be provided and the reasons for the failure.

Element B.1: Access to information

3. Use of enforcement powers to access information not maintained in the Cayman Islands

 

Recommendation (B.1, practice)	In those cases where information is not maintained in the Cayman Islands, the Cayman Islands should ensure that its enforcement powers are sufficiently exercised to ensure that it can access all information in all cases.
Underlying factor	In one case over the review period, the CITIA [Cayman Islands Tax Information Authority] was unable to access accounting information where the information was not held in the Cayman Islands and no one within the Cayman Islands was obliged to provide it. Although the CITIA [Cayman Islands Tax Information Authority] successfully accessed and exchanged all of the requested information in all other cases over the review period, as the Cayman Islands did not make use of its enforcement powers, this could become a wider problem in practice. (see paragraphs 278-281 and 289 of the Cayman Islands’ 2017 Report for more information)
Summary of actions reported	The same actions have been reported by the Cayman Islands as for Recommendation 2.
Conclusion	The Cayman Islands has taken preliminary steps to address the recommendation, but no material progress has been reported for a period of eight years. The Cayman Islands is urged to make substantive progress before its next self-assessment.
Status determined	Has not been addressed
Actions required	The Cayman Islands should submit a schedule for completion of steps to address the recommendation and an update on its progress made to address the recommendation by 31 March 2027. In particular, the Cayman Islands should – Report on the use of access powers to obtain accounting information in a timely manner, including indicating measures taken in instances where such information is held abroad or where the information holder delays or does not comply with the competent authority’s notices. Report on any EOI requests where accounting information could not be provided and the reasons for the failure.

EOIR experience

Over the monitoring period, the Cayman Islands received 230 requests and did not send any requests. The Cayman Islands reported providing full and final responses in 94.8% of all the received requests, 1.3% of requests were withdrawn by requesting jurisdictions and 3.9% of requests are pending. Information requested by peers included legal ownership information, beneficial ownership information, accounting information and banking information. The Cayman Islands reported an overall deterioration in the timeliness of their responses. Only 23% of the requests were replied to within 90 days, 53% within 180 days, and 70% within a year, which constitutes backsliding compared to the situation at the time of the 2017 Report. The Cayman Islands did not provide information on the timely provision of status updates during the monitoring period and indicated that status updates were provided on a case-by-case basis.

Ten peers provided input on the Cayman Islands. Peers have reported general satisfaction with their EOIR experience with the Cayman Islands. However, five peers have commented on issues with timeliness of responses, lack of status updates and/or lack of timely acknowledgement of EOI requests.

In light of the backsliding with regard to the timeliness of responses, a new recommendation is issued to the Cayman Islands under Element C.5 (see paragraph 0). The Cayman Islands is recommended to implement suitable measures, including securing adequate resources, so it can provide the requested information in a timely manner in all cases in line with the standard.

The Cayman Islands should submit a schedule for completion of steps to address the recommendation along with an update on the progress made by 31 March 2027.

Based on peer input on the inconsistent and delayed provision of status updates, a new recommendation is issued to the Cayman Islands under Element C.5 (see paragraph 0). The Cayman Islands is recommended to ensure effective communication with treaty partners, including systematically providing them with status updates when it is unable to provide a response to a request within 90 days.

New developments having a bearing on the EOIR standard

No recent developments that could have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by the Cayman Islands or have otherwise come to light.

Next steps

The Cayman Islands should continue taking actions towards implementing the standard effectively.

Under the first round of enhanced monitoring, two new recommendations are issued to the Cayman Islands.

4. Timeliness of exchanges

 

Recommendation (C.5, practice)

The Cayman Islands is recommended to implement suitable measures, including securing adequate resources, so it can provide the requested information in a timely manner in all cases in line with the standard.

Underlying factor

During the monitoring period 2023-2024, the Cayman Islands’ competent authority experienced staffing constraints and handing over issues during staff transition. As a result, the timeliness of the Cayman Islands responses to requests for information deteriorated over the 2023-2024 monitoring period compared to the timeliness noted for the review period at the time of the 2017 Report. Of the incoming requests, 23% were responded to within 90 days and 53% within 180 days, while 30% remained pending after a year. Issues were noted in tracking of requests and following up with treaty partners. In one case, information was not verified before exchanging resulting in further delays in providing the complete information. The Cayman Islands has taken measures to recruit and train new staff members. In addition, broader organisational changes have been introduced, which should further contribute to improvement of timeliness. Since these measures are new, their effectiveness is yet to be validated.

5. Communication and provision of status updates

 

Recommendation (C.5, practice)

The Cayman Islands is recommended to ensure effective communication with treaty partners, including systematically providing them with status updates when it is unable to provide a response to a request within 90 days.

Underlying factor

During the monitoring period, the Cayman Islands did not provide status updates to EOI partners in respect of all requests where a full response could not be provided within 90 days. Around 77% of the requests required a status update but it was provided only in some cases and sometimes only after having been specifically sought by the partner. There were also issues in communicating effectively with partners as some emails remained unanswered for extended periods.

The following next steps are expected from the Cayman Islands:

• For the two recommendations where lack of material progress has been identified for more than three years since the last review, the Cayman Islands should submit to the PRMG – i) a schedule for completion of steps to address the recommendation and ii) an update, including details on the progress on such recommendations by 31 March 2027.

  • Recommendation 2, on monitoring compliance with requirements to keep accounting records, including those kept abroad (Element A.2)

  • Recommendation 3, on use of enforcement powers to access information not maintained in the Cayman Islands (Element B.1)

• For the new Recommendation 4 on timeliness of exchanges (Element C.5), the Cayman Islands should submit to the PRMG – i) a schedule for completion of steps to address the recommendation and ii) an update, including details on the progress on such recommendation by 31 March 2027.

• Submit its next self-assessment, including on the new recommendations issued, in 2028 under the second round of enhanced monitoring.

Views/response of the monitored jurisdiction

The Cayman Islands thank the Global Forum Secretariat and the Peer Review and Monitoring Group for their work, support, and engagement throughout the enhanced monitoring process, as well as our peers for their valuable input. We reaffirm our strong commitment to the international standard on transparency and exchange of information on request (EOIR), and agree with the findings and conclusions of the report.

The Enhanced Monitoring process is as an important aspect of the work of the Peer Review and Monitoring Group and we welcome the opportunities it provides to improve our implementation of the EOIR standard to ensure its continued effectiveness.

The Cayman Islands looks forward to addressing the matters raised in the report and to our continued close collaboration with the Global Forum.”

Note

← 1.  OECD (2017), Global Forum on Transparency and Exchange of Information for Tax Purposes: Cayman Islands 2017 (Second Round): Peer Review Report on the Exchange of Information on Request, OECD Publishing, Paris, http://dx.doi.org/10.1787/9789264280168-en.