This annual monitoring report presents the outcomes of the 2025 enhanced monitoring process and reflects the progress in the implementation of the EOIR standard by 25 of the 82 jurisdictions undergoing enhanced monitoring in the first cycle of the first round of enhanced monitoring (herein the “monitored jurisdictions”) – Andorra, Argentina, Aruba, Austria, Bahrain, Barbados, Belgium, Bermuda, Brazil, Dominica, Dominican Republic, France, Greece, Isle of Man, Japan, Korea, Liechtenstein, Luxembourg, New Zealand, Norway, San Marino, Saudi Arabia, Singapore, Spain, and Turks and Caicos Islands.1 Similar monitoring reports, adding the enhanced monitoring reports of further jurisdictions in the first round of enhanced monitoring, will be issued in 2026 and 2027.
This report examines the effectiveness of the actions reported by the monitored jurisdictions to address the recommendations made to them and provides conclusions on the adequacy of such actions. It also analyses the peer input received on the monitored jurisdictions and indicates situations where additional recommendations have been issued. The report indicates the next steps expected from each monitored jurisdiction.
Preliminary trends suggest progress is being made, as well as a need for further action…
Many monitored jurisdictions have made good progress to address the recommendations issued and to enhance their compliance with the EOIR standard. For example, most jurisdictions have taken actions to improve the availability of beneficial ownership information, such as by moving towards a multi-pronged approach whereby beneficial ownership information is available through more than one source under a jurisdiction’s legal and regulatory framework. Many jurisdictions have introduced centralised beneficial ownership registers, while others report taking actions to improve their existing registers. In terms of the effective exchange of information in practice, most monitored jurisdictions have reported improvements in their timeliness in responding to requests.
Nevertheless, certain areas require more work. Ensuring that beneficial ownership registers are comprehensive in coverage and contain reliable information is a work in progress for several jurisdictions. Further, risks to the availability of ownership and accounting information remain an issue, especially in relation to inactive entities. Furthermore, for the effective exchange of information, jurisdictions must continue improving their engagement and communication with treaty partners, such as by keeping them informed about the progress in processing their requests where information is yet to be provided, as well as by providing timely clarifications in relation to queries from partners on their outgoing requests.
…as the steps taken by the monitored jurisdictions show welcome progress…
Overall, all the monitored jurisdictions have made progress in implementing the majority of the 125 recommendations2 issued to them in their latest peer review reports. As a result of the steps taken by the jurisdictions, 36 or 29% of these recommendations have been considered (provisionally) addressed3 in the context of the monitoring process. In addition, another 67 or 54% of the recommendations have been determined to be “in the process of being addressed”. For almost all these recommendations, material progress has been noted.
In addition, a few jurisdictions have demonstrated sufficient progress in implementing the EOIR standard to no longer be required to report on the actions taken to address recommendations made. Two jurisdictions – Bahrain and Luxembourg have been permitted to stop reporting in future rounds of enhanced monitoring4 and the PRG (the predecessor to the PRMG for EOIR) had already permitted two jurisdictions – Denmark and Liechtenstein – to stop reporting on their recommendations under the earlier annual follow-up process.5
Overall, 45 recommendations pertain to deficiencies in the legal and regulatory frameworks of the jurisdictions. Of these, 15 recommendations have been addressed by the relevant jurisdictions through amendments to their legal and regulatory frameworks. Where the jurisdiction has not had enough experience to give comfort on the effectiveness of the implementation of the amended framework in practice, jurisdictions have been issued with new recommendations focused on the implementation aspects, which they are required to report on in the future. Seven such new recommendations have been issued, following the acceptance of the previous recommendations as (provisionally) addressed. In addition to these addressed recommendations, three recommendations have been determined to be “no longer sufficiently material” permitting the jurisdictions concerned to stop reporting on them in the future.
The remaining 80 recommendations pertain to identified issues in the effectiveness of the implementation of jurisdictions’ legal and regulatory frameworks in practice. Of these, 21 recommendations or 26% have been considered (provisionally) addressed. A significant proportion of these 21 recommendations (i.e. 9 recommendations) pertain to effective exchange of information. In this regard, seven jurisdictions have improved their communication, organisational resources and timeliness of responding to requests. For other aspects of the standard, there has been some success in demonstrating the satisfactory implementation of the legal and regulatory frameworks in practice. In addition to these addressed recommendations, one recommendation has been determined as “no longer sufficiently material” and therefore does not need to be reported on in the future.
…although there remains need for further action.
Notwithstanding the encouraging progress observed, which is also reflected in the large proportion of positive peer input received on many jurisdictions, there is room for further work in some areas. Eighteen recommendations or 14% have each been determined as “has not been addressed”. Out of these 18 recommendations, for 10 recommendations, no actions or only preliminary steps have been reported, although more than three years have passed since the adoption of the EOIR report. In addition, a lack of further material progress has been identified for one recommendation that is “in the process of being addressed”. These jurisdictions have been asked to submit a schedule for the completion of the steps necessary to address the recommendation(s), along with an update on progress made by 31 March 2026.
In terms of areas where further action is required, many jurisdictions continue to face difficulties in the implementation of the beneficial ownership requirements. While 24 of the monitored jurisdictions reported having adopted a multi-pronged approach to ensure the availability of beneficial ownership information, including the creation of centralised beneficial ownership registers, only three jurisdictions have been able to demonstrate satisfactory levels of effectiveness in the implementation of their registers. This can be expected, particularly when such registers have only recently been introduced. Further action is also required from jurisdictions to ensure the accuracy of the information contained in the registers.
There are signs of improvement in effective EOIR in practice…
The enhanced monitoring exercise provides an opportunity to monitor EOIR in practice. It shows the continued widespread and established use of EOIR as a tool for tax cooperation. Exchange of information is effective if it takes place in a timely manner. The monitored jurisdictions received 11 682 requests6 over the calendar years 2023 and 2024. Most jurisdictions provided timely responses to the EOI requests they received. On average, 76% of the requests were answered within 90 days and a further 14% were answered within 180 days. Nevertheless, there remains scope for improvement. While seven jurisdictions have seen their recommendations on effective exchange of information considered addressed, due to actions taken to improve aspects of their communication, the provision of timely updates on the status of pending requests and improved organisational resources and timeliness for exchanging information, other jurisdictions are still working on these aspects.
…although peer input flag some persisting issues…
Peers are uniquely placed to know the effectiveness of exchanges of information with a jurisdiction and 52 Global Forum members provided 802 pieces of peer input on all 82 jurisdictions monitored in cycle 1. This included 16 members that had not provided peer input under the previous follow-up process. This reflects an encouraging growth in the engagement of the Global Forum members, triggered by the enhanced monitoring process.
A total of 252 out of the 802 pieces of peer input related to the 25 monitored jurisdictions covered by this report and were therefore fully analysed when preparing this report. Most of the peer input demonstrated positive collaboration amongst jurisdictions, with 73% of the submissions showing that the peers providing input were satisfied with their overall EOIR experience with the monitored jurisdictions (for instance, with the process of making requests and receiving the information in return, to facilitate their tax inquiries, or while processing requests received from the monitored jurisdictions). Another 15% of the peer input noted the existence of an EOI relationship but indicated that it was untested in practice. Finally, 12% of the peer input raised at least one matter on which a response from the monitored jurisdiction was required.
Most of the matters raised by peers were resolved bilaterally, as the monitored jurisdictions engaged directly and proactively with the peers once they were aware of the concern(s). More generally, effective communication amongst exchange partners is noted as an important area that sometimes poses challenges with peers continuing to report difficulties in contacting competent authorities or not receiving timely status updates or clarifications. Occasionally, technical issues in the transmission of electronic mails have also resulted in some delays.
…besides raising matters requiring corrective actions.
In certain cases, the peer input received has indicated matters that could have broader than bilateral implications for the implementation of the EOIR standard. In such cases, further follow up and consultations with the monitored jurisdiction and the peer(s) providing the input was needed. Where broader issue(s) are identified, the jurisdictions are issued recommendations to correct the identified issues. So far, three jurisdictions have received an additional recommendation to improve an issue identified as having broader than bilateral implication for the implementation of the standard. In two of these cases, the matters raised by peers reflected backsliding (i.e. a reduction in the effectiveness of the implementation of the EOIR standard), and, in such cases, the relevant jurisdictions are required to report annually on the actions taken to address the corresponding recommendation(s).
Reporting of further steps expected in the next self-assessments, although some recommendations are subject to closer monitoring.
Enhanced monitoring is an ongoing process. The monitored jurisdictions should submit their next self-assessment in accordance with the expectations indicated in their individual monitoring reports. For jurisdictions in cycle 1, most of the reporting is expected in 2028, under the second round of enhanced monitoring. However, where due to delays observed in the addressing of recommendations so far, five jurisdictions have been asked to provide a schedule for the completion of specific actions to address the recommendation made and to provide an update on the progress made by 31 March 2026. Similarly, the two jurisdictions that have received a new recommendation based on the backsliding observed since their EOIR report are required to provide an update on the progress made by 31 March 2026.