126 jurisdictions, including developed and developing countries, have either commenced exchanges under the AEOI Standard or have committed to do so soon. Maximising the benefits of the AEOI Standard requires its widespread and effective implementation based on a level playing field. The Global Forum seeks to deliver this through its monitoring and peer review processes, as well as through capacity building.
Peer Review of the Automatic Exchange of Financial Account Information 2024 Update
Abstract
The OECD, working with G20 countries, developed the AEOI Standard in 2014. The G20 then asked the Global Forum to monitor the implementation of the AEOI Standard worldwide. As a first step, the Global Forum initiated a commitment process to ensure the widespread implementation of the AEOI Standard.
The Global Forum’s first step to deliver the widespread and effective implementation of the AEOI Standard based on a level playing field was to put in place a commitment process. As a consequence, all Global Forum members, except for developing countries that did not host a financial centre, were invited to commit to implement the AEOI Standard to specific timelines. This led to around 100 jurisdictions committing to:
implement the AEOI Standard;
exchange information with all Interested Appropriate Partners (which are all jurisdictions interested in receiving information from a jurisdiction and that meet the expected standards in relation to confidentiality and data safeguards); and
commence exchanges in 2017 or 2018.
Since then, a further 26 jurisdictions have committed to implement the AEOI Standard, with commencement dates between 2019 and 2027. This mainly consists of developing countries that do not host a financial centre but that want to benefit from AEOI in relation to Financial Accounts, although does also include jurisdictions subsequently identified through the Global Forum’s “jurisdiction of relevance” process, designed to maintain a level playing field. The continually increasing number of jurisdictions committing to, and commencing, exchanges under the AEOI Standard, demonstrates the growing significance of AEOI to enhance tax transparency and ensure the correct payment of tax.
Once commitments are made, the Global Forum monitors the timeliness of the delivery of each aspect of the implementation process. These include:
putting in place a domestic legislative framework requiring Reporting Financial Institutions to collect and report the information for exchange, in accordance with the detailed due diligence and reporting rules contained in the AEOI Standard;
putting in place an international legal framework that allows the automatic exchange of information with a jurisdiction’s exchange partners, which includes an underlying legal basis for exchange and an administrative agreement containing the detailed specificities. The overwhelming majority of exchanges are conducted under the multilateral frameworks of the multilateral Convention on Mutual Administrative Assistance in Tax Matters (the Convention) and the associated Multilateral Competent Authority Agreement (MCAA); and
establishing a technical infrastructure to receive the information from Reporting Financial Institutions and to process and transmit it to exchange partners. All jurisdictions use the Common Transmission System (CTS), procured by the OECD and managed by the Global Forum, to transmit the information.
In addition, both before and after jurisdictions receive information from their partners, their confidentiality and data safeguards frameworks are assessed to provide assurance that the information exchanged will be kept safe and only be used for the purposes set out in the international exchange agreement. Where substantive issues are identified in the confidentiality and data safeguards assessments, they must be addressed for the jurisdiction to receive, or continue to receive, information. Assistance is provided where necessary.
Delivery of the commitments
Table 1.1 presents details of the numbers of partners to which information was successfully sent by each implementing jurisdiction from 2018 to 2024. The data presented includes jurisdictions that received information as well as all instances where the necessary (domestic and international) legal frameworks were in place containing an obligation on Reporting Financial Institutions to report information with respect to tax residents of an exchange partner, but where no relevant Reportable Accounts were identified in practice (i.e. essentially a nil return).
97% of jurisdictions have delivered their commitment to exchange information under the AEOI Standard.
Note:
The United States has undertaken automatic information exchanges pursuant to FATCA from 2015 and entered into intergovernmental agreements (IGAs) with other jurisdictions to do so. The Model 1A IGAs entered into by the United States acknowledge the need for the United States to achieve equivalent levels of reciprocal automatic information exchange with partner jurisdictions. They also include a political commitment to pursue the adoption of regulations and to advocate and support relevant legislation to achieve such equivalent levels of reciprocal automatic exchange.
a Jurisdictions that are developing countries that were not asked to commit to implementing the AEOI Standard to a particular timeline but did so voluntarily.
b Developed jurisdictions that joined the Global Forum after the commitment process was conducted in 2014 and were therefore asked to commit to a particular timeline upon joining.
c Jurisdiction that were identified through the Global Forum process aimed at identifying jurisdictions of relevance for the implementation of the AEOI Standard and subsequently voluntarily committed to implement the AEOI Standard.
d As established through the peer review process, there are no Reporting Financial Institutions (RFIs) located in this jurisdiction.
e Albania voluntarily committed to commence exchanges in 2021 but did so in 2020.
f This jurisdiction is delayed in undertaking exchanges. It is expected to carry out the exchanges in the near future.
g This jurisdiction has conducted exchanges, but the figure provided is provisional and subject to changes as the exchanges are not yet fully verified.
h Note by the Republic of Türkiye: The information in this document with reference to “Cyprus” relates to the southern part of the Island. There is no single authority representing both Turkish and Greek Cypriot people on the Island. Türkiye recognises the Turkish Republic of Northern Cyprus (TRNC). Until a lasting and equitable solution is found within the context of the United Nations, Türkiye shall preserve its position concerning the “Cyprus issue”.
Note by all the European Union Member States of the OECD and the European Union: The Republic of Cyprus is recognised by all members of the United Nations with the exception of Türkiye. The information in this document relates to the area under the effective control of the Government of the Republic of Cyprus.
N/A: Not applicable since the year is prior to the commitment date.
Jurisdictions yet to commence exchanges as committed to
As set out above, the vast majority (97%) of jurisdictions that committed to commence exchanges under the AEOI Standard have fulfilled their commitment.
There are nevertheless some jurisdictions that were invited to commence exchanges from a certain date, either under the original commitment process (Trinidad and Tobago that committed to commence exchanges from 2018) or that were identified later through the Global Forum’s jurisdictions of relevance process (Jordan and Montenegro that committed to commence exchanges from 2023) that have not yet delivered on the commitments made.
A fully effective AEOI Standard requires a level playing field and the Global Forum therefore continues to work closely with these jurisdictions to facilitate the delivery of their commitments.
Commitments to commence exchanges in the future
Nine jurisdictions have committed to commencing the exchanges under the AEOI Standard in 2025 or in subsequent years. These are set out in Table 1.2 below.
Note: All jurisdictions committed to commencing AEOI exchanges from 2025 onwards are developing countries that do not host a financial centre and that were not asked to commit to a specific date to exchange information, but that have done so voluntarily.
While the timeliness of implementation is critical, all of the requirements must be implemented in a complete and effective manner for the potential benefits of the AEOI Standard be fully delivered. To ensure this, the Global Forum conducts peer reviews with respect to the quality of the implementation of all aspects of the AEOI Standard. Conclusions are drawn on the completeness of the domestic and international legal frameworks and on the effectiveness in practice of the domestic collection of the information and its international exchange.
Below is an analysis of the peer review results to date, after which the results are set out in full.
An analysis of the peer review results to date
The results of the reviews of the AEOI legal frameworks
Chapter 3 of this Report contains the new and amended jurisdiction reports. It includes five new reports on the AEOI legal frameworks in the jurisdictions that committed to commence exchanges from 2022 (Jamaica and the Maldives) and 2023 (Jordan, Montenegro and Thailand). It also contains revised reports for 46 jurisdictions that underwent a reassessment, either due to the additional checks carried out in 2023, mainly in relation to the compliance and enforcement frameworks, or at the request of the jurisdiction following amendments to their legal frameworks, including to address recommendations previously made.
In total, across all 114 jurisdictions whose legal frameworks have been assessed to date, 936 recommendations have been made, including 107 recommendations following the additional checks made in 2023. A total of 82 jurisdictions have brought into force amendments to their legal frameworks to address recommendations made through the Global Forum peer reviews, with 706 recommendations having been successfully addressed.
The peer review results show that there is a very high level of compliance in relation to the legal frameworks put in place to implement the AEOI Standard. Of the 114 jurisdictions committed to commencing exchanges by 2023, virtually all of them (111, or 97%) have an international legal framework that is fully in accordance with the AEOI Terms of Reference. The Global Forum has therefore issued 111 jurisdictions with a determination of “In Place” for Core Requirement 2. Furthermore, the majority of jurisdictions (60, or 53%) have domestic legislative frameworks that are also fully in accordance with the AEOI Terms of Reference. The Global Forum has therefore issued these jurisdictions with a determination of “In Place” for Core Requirement 1. 60 (or 53%) of jurisdictions have therefore received an overall determination of “In Place” for their legal frameworks implementing the AEOI Standard.
By far the next largest group of jurisdictions (48, or 42%) are those for which the Global Forum issued a determination of “In Place” for Core Requirement 2 and “In Place But Needs Improvement” for Core Requirement 1. Their peer review reports include one or more recommendations to amend their domestic legislative framework in order for it to be fully consistent with the AEOI Terms of Reference. Consequently, 48 jurisdictions received an overall determination of “In Place But Needs Improvement”. In total, 108 out of 114 (or 95%) of the jurisdictions assessed therefore have domestic and international legal frameworks that are fully or substantially in place. This demonstrates a high level of compliance with the AEOI Terms of Reference.
Following the actions taken, 95% of jurisdictions have been determined to have domestic and international legal frameworks that are fully or substantially in accordance with the AEOI Terms of Reference
Of the remaining jurisdictions, three have implemented a domestic legislative framework which contains many of the requirements, but that include significant deficiencies. Three jurisdictions (Jordan, Montenegro and Trinidad and Tobago) have not yet implemented a domestic legal framework. Six jurisdictions have therefore received an overall determination of “Not In Place”.
Figure 1.1 summarises the distribution of the peer review results.
Common issues identified
While compliance with the requirements is generally high, there are some common issues where recommendations remain. They most commonly relate to the following:
The largest category of remaining recommendations relates to jurisdiction-specific Non-Reporting Financial Institutions and Excluded Accounts that are not in accordance with the requirements of the AEOI Standard.
The legal frameworks for compliance and enforcement have also been found to have issues in several cases, including issues identified through the additional targeted checks in relation to the compliance and enforcement frameworks conducted in the context of the second round of AEOI reviews in relation to effectiveness in practice. These include gaps in:
the powers to address avoidance of the due diligence and reporting requirements;
the ability to impose sanctions on Reporting Financial Institutions across the full expected range of instances of failures to comply with the due diligence and reporting obligations;
the ability to sanction Account Holders and Controlling Persons for submitting false self-certifications; and
the applicable record-keeping obligations.
It is noted that all the jurisdictions with legal frameworks that have been determined to be “Not In Place” have multiple recommendations with respect to their legal frameworks for compliance and enforcement.
Several more specific recommendations have also been made in cases where jurisdictions have summarised the detailed definitions in the AEOI Standard with the omission of relevant details that are needed to ensure their full and proper operation.
The Global Forum continues to work with the jurisdictions concerned to assist them in addressing the issues where recommendations have been made.
The results of the reviews of the effectiveness in practice
Chapter 3 of this report contains the jurisdiction-specific reports. It contains three additional initial effectiveness review reports on the implementation in practice of the AEOI Standard by jurisdictions that committed to commence exchanges from 2020: Nigeria, Oman and Peru. Note that, under the usual process, the initial effectiveness review report in relation to New Caledonia would have been published this year as New Caledonia also commenced exchanges in 2020, as it committed to. However, the Global Forum has deferred the finalisation of the initial effectiveness review for New Caledonia by one year due to the severe political and social issues faced by New Caledonia in 2024, including the civil unrest and the imposition of a state of emergency.
Overall, the results of the initial effectiveness reviews show that most jurisdictions are delivering as expected. Moreover, it is understood that significant progress continues to be made since the assessments have been carried out. The results of the initial reviews show that almost two thirds (67, or 64%) of the 104 jurisdictions that have been reviewed so far, have been rated as “On Track” with respect to their frameworks and activities to ensure the effectiveness of the AEOI Standard in practice. This means that they have developed complete administrative compliance frameworks to ensure that Reporting Financial Institutions effectively implement the due diligence and reporting obligations, which they are also implementing. Furthermore, these jurisdictions are also successfully conducting the exchanges in practice, addressing any issues as they emerged.
A further 17 (or 16%) jurisdictions have been found to have credible frameworks and plans in place and were generally successfully exchanging the information in accordance with the technical requirements, but need to further implement their plans. These jurisdictions have therefore been rated as “Partially Compliant”. The implementation in many of these jurisdictions is expected to mature significantly in the near future, provided that the plans they have in place are followed through.
Finally, 20 (or around 19%) jurisdictions have been found to have fundamental deficiencies in their frameworks (i.e. they are not yet fully developed) and have therefore been found to be “Non-Compliant”. Of the “Non-Compliant” jurisdictions, four have since addressed the significant gaps in their legal compliance and enforcement frameworks that drove the result of the initial effectiveness reviews. For these jurisdictions, while the exchanges are taking place each year, they have not yet completed operational frameworks to verify and enforce the compliance by Reporting Financial Institutions with all of the due diligence and reporting requirements.
Figure 1.2 summarises the distribution of the peer review results.
In general, the rate of advancement and the increasing maturity in implementation continues at pace. In this regard, a significant majority of jurisdictions had seen improvements in their ability to match the information received, indicating an increase in the quality of the information being sent. Furthermore, in recent years, three-quarters of jurisdictions have seen improvements in the collection of Tax Identification Numbers, as well as reductions in the numbers of undocumented accounts reported. Furthermore, the rate of the collection and exchange of dates of birth is close to 100%. These are all critical aspects to the matching of the information exchanged with domestic taxpayer records. As regards the exchanges themselves, while there are sometimes delays and issues with the preparation of the files, these tend to be quickly and effectively addressed.
Common issues identified
While around two thirds of jurisdictions assessed have been found to be “On Track” with their implementation, amongst the remaining jurisdictions, several common issues were identified.
The most significant issues identified relate to the lack of a complete framework to enforce the requirements. In many cases some activities had been conducted to ensure Reporting Financial Institutions are reporting information as required (e.g. by cross checking relevant lists of regulated entities), but there has been limited activities to ensure that the information being reported is complete and accurate. These jurisdictions generally committed to quickly work to address the deficiencies identified. Furthermore, support is being given by the Global Forum Secretariat, which has developed a Model Administrative Compliance Strategy, organised knowledge sharing events and recently released additional tools to support its bilateral technical assistance programme. It is therefore expected that these issues be successfully addressed in the near term. It will generally take longer for jurisdictions that need to address constraints in their legal frameworks to enforce the requirements, in order to complete the necessary legislative processes.
There is another group of jurisdictions that have credible plans in place but that have only very recently started implementing them. For example, the checks to ensure that the information being reported is complete and accurate is not yet very mature, such as being limited to analysing the information reported but not yet including reviewing the policies, procedures and account documentation of individual Reporting Financial Institutions.
As mentioned earlier, with respect to the exchanges in practice, the level of implementation has been very high and, where issues emerge, they are generally promptly addressed.
A summary of the peer reviews to date
Table 1.3 contains an overall summary of: (i) the determinations made with respect to legal frameworks introduced by each jurisdiction to implement the AEOI Standard, and (ii) the ratings made following the initial review of the effectiveness of their implementation in practice. Further details on the analysis and reasons for the determinations for each jurisdiction can be found in Peer Review of the Automatic Exchange of Financial Account Information 2022 (https://www.oecd-ilibrary.org/taxation/peer-review-of-the-automatic-exchange-of-financial-account-information-2022_36e7cded-en) which has been supplemented by the reports in Chapter 3 of the 2023 report for the assessments and reassessments completed in 2023 and in Chapter 3 of this report for the assessments and reassessments conducted in 2024.
The second round of AEOI effectiveness reviews
With the completion of the initial peer reviews of the effectiveness of the implementation of the AEOI Standard for the first 99 jurisdictions in 2022, the Global Forum put in place a framework to carry out a second round of AEOI effectiveness reviews. These are designed to obtain a more in-depth assurance in relation to the effectiveness of the implementation of the AEOI Standard in practice and include onsite visits by Assessment Teams to meet with all relevant public and private sector stakeholders.
The second round of AEOI effectiveness reviews commenced in 2023 and involve a detailed and deeper assessment of the administrative strategies and frameworks jurisdictions have in place to ensure compliance by Reporting Financial Institutions, as well as the actions taken and the results of those actions. Onsite visits are being conducted during which assessment teams meet with the officials involved in ensuring compliance by Reporting Financial Institutions as well as with the regulatory authorities and representatives of the financial sector. There is also an annual peer input process to obtain the feedback from each jurisdiction’s exchange partners to inform the peer review process. All 99 jurisdictions that committed to commence exchanges in 2017 or 2018 are being assessed simultaneously, according to a schedule for the onsite visits, with all reports being updated at the end of the process to reflect the most up to date situation in the jurisdictions.
The second round of AEOI effectiveness reviews has been a hugely beneficial learning process, both for implementing jurisdictions and the Global Forum more generally. The collective knowledge of the practices of governmental and private sector stakeholders has expanded considerably, and the expectations of AEOI Peers as to what constitutes an effective implementation of the AEOI Standard have been developed and refined. Ultimately, the objective of the Global Forum is to have a global implementation of the AEOI Standard that is as effective as possible to provide the greatest expected benefit to the international community. This is supported by continuing to disseminate the best practices observed to all jurisdictions and allowing time for their sustainable implementation and review. With this in mind, the Global Forum has extended the period within which it will conduct the second round of AEOI effectiveness reviews of the first 99 jurisdictions to implement the AEOI Standard by one year. An update on the processes being conducted will be published in the 2025 AEOI Peer Review Report and the final results of the second round AEOI effectiveness reviews for all 99 jurisdictions will be published in the 2026 AEOI Peer Review Report.
Further details of the frameworks used for the AEOI peer reviews can be found in Chapter 2.