Peer Review of the Automatic Exchange of Financial Account Information 2025 Update

1. Ensuring the effective implementation of the AEOI Standard: The monitoring process and results

Abstract

127 jurisdictions have either commenced exchanges under the AEOI Standard or have committed to do so soon. The monitoring process is to provide assurance that the key implementation milestones are being delivered in a timely manner.

The OECD, working with G20 countries, developed the AEOI Standard in 2014. The Global Forum then took up the call of the G20 to monitor its implementation 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 AEOI commitment process

In order to deliver the widespread and effective implementation of the AEOI Standard based on a level playing field, the Global Forum started by putting in place a commitment process. Consequently, all Global Forum members, except for developing countries that did not host a financial centre, were invited to commit to implement the AEOI Standard according to specific timelines.1 This led to around 100 jurisdictions committing, in 2014, 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 27 jurisdictions have committed to implement the AEOI Standard by a specific date, 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 help ensure the taxes due are paid.

Monitoring the timeliness of delivery

Once commitments are made, the Global Forum monitors the timeliness of the delivery of each aspect of the implementation process. This includes:

• 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 for 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 MAAC) and the associated Multilateral Competent Authority Agreement (CRS-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), which is 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 2025. 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.

Table 1.1. Jurisdictions that exchanged information from 2018 to 2025

Jurisdiction	Year of commitment to first AEOI exchanges	Number of partners to which data was sent (Year Data Exchanged (EY) / Underlying Reportable Year (RY))
		EY: 2018 RY: 2017	EY: 2019 RY: 2018	EY: 2020 RY: 2019	EY: 2021 RY: 2020	EY: 2022 RY: 2021	EY: 2023 RY: 2022	EY: 2024 RY: 2023	EY: 2025 RY: 2024
1. Albania1,5	2021	N/A	N/A	59	69	75	74	79	85
2. Andorra	2018	39	59	69	62	67	79	79	77
3. Anguilla	2017	4	52	52	55	57	67	70	71
4. Antigua and Barbuda	2018	36	35	30	33	23	40	40	57
5. Argentina	2017	56	67	71	76	78	82	82	85
6. Armenia1	2025	N/A	N/A	N/A	N/A	N/A	N/A	N/A	21
7. Aruba	2018	50	58	66	64	65	62	73	81
8. Australia	2018	57	64	70	72	76	76	81	86
9. Austria	2018	46	61	68	71	77	79	84	88
10. Azerbaijan1	2018	33	53	52	70	74	79	83	86
11. Bahamas	2018	36	48	56	60	66	66	67	66
12. Bahrain	2018	38	50	59	63	65	70	72	73
13. Barbados	2018	57	53	61	64	62	68	71	74
14. Belgium	2017	66	69	72	77	80	83	87	89
15. Belize	2018	47	59	64	63	67	69	70	69
16. Bermuda	2017	52	61	60	64	70	73	79	80
17. Brazil	2018	56	67	69	76	76	77	77	89
18. British Virgin Islands	2017	50	64	67	65	61	73	76	76
19. Brunei Darussalam	2018	27	27	33	41	61	62	67	57
20. Bulgaria	2017	60	65	71	73	77	80	86	88
21. Canada	2018	56	59	57	66	65	68	73	73
22. Cayman Islands	2017	57	64	70	73	73	79	83	84
23. Chile	2018	48	63	69	72	71	78	86	82
24. China (People’s Republic of)	2018	52	64	69	75	76	77	80	81
25. Colombia	2017	60	65	70	77	77	83	85	89
26. Cook Islands	2018	45	62	68	68	72	79	80	83
27. Costa Rica	2018	49	67	69	71	74	61	79	83
28. Croatia	2017	60	65	70	76	77	79	83	89
29. Curaçao	2018	57	57	66	51	71	71	78	-8
30. Cyprus	2017	59	67	72	74	77	80	84	89
31. Czechia	2017	60	60	66	74	80	83	81	86
32. Denmark	2017	66	69	73	76	78	83	86	89
33. Dominica	2018	0	0	0	56	65	70	77	74
34. Ecuador1	2021	N/A	N/A	N/A	46	65	72	79	84
35. Estonia	2017	62	66	69	73	74	78	85	81
36. Faroe Islands	2017	57	67	67	73	72	77	80	84
37. Finland	2017	66	69	70	77	81	82	83	87
38. France	2017	62	66	68	71	75	80	83	87
39. Including New Caledonia	2020	N/A	N/A	29	33	36	59	67	70
40. Georgia1	2024	N/A	N/A	N/A	N/A	N/A	N/A	34	44
41. Germany	2017	63	68	68	74	77	80	83	89
42. Ghana1	2019	N/A	56	64	62	68	72	73	71
43. Gibraltar	2017	51	59	69	72	75	77	77	84
44. Greece	2017	67	68	69	74	76	82	85	89
45. Greenland	2018	57	67	69	77	76	82	79	78
46. Grenada	2018	55	54	65	61	59	57	43	73
47. Guernsey	2017	61	64	70	73	78	82	85	87
48. Hong Kong, China	2018	40	45	50	67	71	75	80	84
49. Hungary	2017	57	66	72	72	73	82	82	86
50. Iceland	2017	59	64	67	70	73	76	83	84
51. India	2017	60	67	68	74	77	84	86	87
52. Indonesia	2018	59	66	69	72	77	76	83	86
53. Ireland	2017	66	69	73	78	80	81	84	90
54. Isle of Man	2017	57	64	68	75	78	82	84	86
55. Israel	2018	41	55	61	67	71	65	70	72
56. Italy	2017	64	67	71	76	75	79	83	87
57. Jamaica1	2022	N/A	N/A	N/A	N/A	13	44	51	267
58. Japan	2018	55	67	70	75	77	82	83	87
59. Jersey	2017	58	65	69	73	76	79	80	84
60. Jordan3	2023	N/A	N/A	N/A	N/A	N/A	-	-	-
61. Kazakhstan3	2021	N/A	N/A	N/A	44	58	53	56	- 6
62. Kenya1	2024	N/A	N/A	N/A	N/A	N/A	N/A	64	64
63. Korea	2017	59	67	70	74	76	81	86	89
64. Kuwait2	2019	34	52	67	62	72	07	81	337
65. Latvia	2017	56	66	69	75	78	81	80	80
66. Lebanon	2018	27	59	50	60	- 6	- 6	- 6	- 6
67. Liechtenstein	2017	50	60	68	75	74	79	82	86
68. Lithuania	2017	63	66	70	70	75	79	80	88
69. Luxembourg	2017	66	69	72	77	79	83	86	90
70. Macau, China	2018	36	48	60	67	70	73	78	81
71. Malaysia	2018	42	64	65	69	73	76	82	87
72. Maldives1	2022	N/A	N/A	N/A	N/A	35	56	73	78
73. Malta	2017	61	67	73	73	73	83	80	85
74. Marshall Islands	2018	1	57	59	60	58	62	66	68
75. Mauritius	2018	58	65	69	74	75	77	80	87
76. Mexico	2017	60	67	67	73	75	79	79	80
77. Moldova1	2024	N/A	N/A	N/A	N/A	N/A	N/A	38	63
78. Monaco	2018	34	58	63	65	66	70	80	83
79. Montenegro3	2023	N/A	N/A	N/A	N/A	N/A	-	-	-
80. Montserrat	2017	12	16	60	0	57	60	65	65
81. Nauru4	2018	No RFIs	No RFIs	No RFIs	No RFIs	No RFIs	No RFIs	No RFIs	No RFIs
82. Netherlands	2017	61	65	68	70	77	82	82	89
83. New Zealand	2018	55	65	66	73	77	82	83	88
84. Nigeria1	2020	N/A	N/A	25	63	73	74	76	81
85. Niue4	2018	No RFIs	No RFIs	No RFIs	No RFIs	No RFIs	No RFIs	No RFIs	No RFIs
86. Norway	2017	64	68	71	75	77	82	86	89
87. Oman2	2020	N/A	N/A	28	28	39	58	61	61
88. Pakistan1	2018	40	55	57	61	66	69	73	74
89. Panama	2018	32	62	63	67	69	68	74	87
90. Peru1	2020	N/A	N/A	15	45	61	73	81	77
91. Poland	2017	66	69	71	74	76	78	86	88
92. Portugal	2017	66	69	71	76	75	80	84	90
93. Qatar	2018	9	49	49	58	59	65	64	67
94. Romania	2017	59	65	67	71	77	78	82	85
95. Russia	2018	50	58	63	69	No data	No data	No data	No data
96. Rwanda1	2025	N/A	N/A	N/A	N/A	N/A	N/A	N/A	49
97. Saint Kitts and Nevis	2018	25	62	57	59	61	80	84	84
98. Saint Lucia	2018	40	61	65	68	69	75	75	81
99. Saint Vincent and the Grenadines	2018	65	56	0	0	21	76	75	- 6
100. Samoa	2018	45	59	64	66	63	69	71	70
101. San Marino	2017	57	63	68	71	74	82	85	89
102. Saudi Arabia	2018	56	65	68	74	72	78	84	85
103. Senegal1	2025	N/A	N/A	N/A	N/A	N/A	N/A	N/A	- 6
104. Seychelles	2017	55	66	63	25	69	72	74	77
105. Singapore	2018	50	63	66	70	75	77	82	86
106. Sint Maarten	2018	0	0	0	0	49	69	70	65
107. Slovak Republic	2017	62	67	68	77	77	81	85	88
108. Slovenia	2017	64	69	72	78	80	83	87	86
109. South Africa	2017	57	63	68	76	77	82	85	89
110. Spain	2017	66	71	72	78	80	83	86	90
111. Sweden	2017	61	66	70	73	78	81	82	86
112. Switzerland	2018	36	62	66	72	73	81	81	83
113. Thailand3	2023	N/A	N/A	N/A	N/A	N/A	33	56	67
114. Trinidad and Tobago3	2018	-	-	-	-	-	-	-	-
115. Türkiye	2018	1	1	52	68	73	78	81	86
116. Turks and Caicos Islands	2017	44	0	63	67	68	75	74	80
117. Uganda1	2025	N/A	N/A	N/A	N/A	N/A	N/A	N/A	39
118. Ukraine1	2024	N/A	N/A	N/A	N/A	N/A	N/A	53	65
119. United Arab Emirates	2018	43	53	68	70	75	79	79	81
120. United Kingdom	2017	62	68	70	72	76	81	85	88
121. Uruguay	2018	59	67	70	74	77	83	81	88
122. Vanuatu	2018	20	42	53	53	61	67	70	67

Notes:

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.

1. Jurisdictions that are developing countries that were not asked to commit to implementing the AEOI Standard to a particular timeline but did so voluntarily.

2. 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.

3. Jurisdictions 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 it by a specific date.

4. As established through the peer review process, there are no Reporting Financial Institutions (RFIs) located in this jurisdiction.

5. Albania voluntarily committed to commence exchanges in 2021 but did so in 2020.

6. This jurisdiction is delayed in undertaking exchanges. It is expected to carry out the exchanges in the near future.

7. This jurisdiction has conducted exchanges, but the figure provided is provisional and subject to changes as the exchanges are not yet fully verified.

8. Curacao has temporarily suspended exchanges while it reviews its confidentiality and data safeguard arrangements.

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 a few 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.

In addition, Morocco voluntarily committed to commence exchanges in 2025 although it has not yet put in place the necessary legal and technical frameworks to implement the AEOI Standard and therefore has not yet begun exchanges. It should also be noted that in 2025, the Global Forum identified Morocco as a relevant jurisdiction, meaning that it is expected to commence exchanges under the AEOI Standard by 2028 at the latest.

Commitments to commence exchanges in the future

Five jurisdictions have committed to commencing the exchanges under the AEOI Standard in 2026 or in subsequent years. These are set out in Table 1.2.

Table 1.2. Jurisdictions committed to commencing exchanges in the near future

Year of commitment to first exchanges	Jurisdiction
2026	Cameroon, Tunisia
2027	Mongolia, Papua New Guinea, Paraguay

Note: All jurisdictions committed to commencing AEOI exchanges from 2026 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.

Monitoring the implementation of the 2023 updates to the Common Reporting Standard (the amended CRS)

The amended CRS and the expectations

In 2023, after a first comprehensive review of the AEOI Standard, the OECD worked with G20 countries to finalise the 2023 updates to the Common Reporting Standard (the amended CRS), which involved extensive consultations with implementing jurisdictions and the financial sector. The amendments to the CRS cover three main topics: (i) the explicit inclusion of digital money products, (ii) enhanced reporting requirements, and (iii) clarifications on some of the terminology and due diligence obligations. The explicit inclusion of electronic money products is an important step as it was previously open to interpretation and electronic money products can constitute a credible alternative to holding money or Financial Assets in accounts that were already in scope. Furthermore, the additional reporting requirements are expected to provide important additional insights to Competent Authorities enabling them to better utilise the data received to ensure compliance by their taxpayers with their tax obligations and to more effectively ensure compliance by Reporting Financial Institutions with the due diligence and reporting procedures.

In recognition of the benefits the amended CRS has to offer, it received broad political support. At the invitation of G20 Finance Ministers, Global Forum Plenary welcomed the opportunity to build on its commitment and monitoring process to ensure the widespread implementation of the amended CRS, and to identify an appropriate and coordinated timeline to commence exchanges under the amended CRS.

After consultation with all concerned jurisdictions, and by carefully balancing the core principle of reciprocity with the need for flexibility amongst the more than 100 jurisdictions exchanging information under the AEOI Standard, the Global Forum adopted the following timeline for the implementation of the amended CRS, following which all jurisdictions that have implemented the AEOI Standard should have implemented the amended CRS:

• The commonly expected first exchange year under the amended CRS is 2027, with additional time of up to a maximum of three years for the implementation of the legal framework, if necessary.

• The common introduction of the new CRS XML Schema 3.0 as of 2027, to ensure the additional information under the amended CRS can be exchanged at a technical level.

• New jurisdictions that commit to start exchanging under the AEOI Standard as of 2027 are expected to implement it together with the amended CRS.

Similar to the implementation of the original CRS, the implementation of the amended CRS requires updates to three key elements:

• Updates to the domestic legal framework to implement the amended due diligence and reporting procedures for Reporting Financial Institutions, contained in the amended CRS and its Commentary.

• An update to the international legal framework, by implementing the Addendum to the CRS MCAA (as guided by its Commentary), providing the basis for the international exchange of the information.

• Updates to the domestic AEOI solution (the domestic IT system for preparing, sending, and receiving information under the AEOI Standard) to implement the technical requirements of the CRS XML Schema 3.0 and the respective User Guides.

The Global Forum is monitoring the implementation of the amended CRS by all jurisdictions to ensure that it is implemented in line with the agreed expectations. Furthermore, to support jurisdictions in implementing the amended CRS, the Global Forum has developed further guidance documents (in particular, an update to the model legislation to incorporate the amended CRS) and is providing bilateral technical assistance to Global Forum members upon request.

The first monitoring results

The Global Forum started its monitoring process to ensure the widespread implementation of the amended CRS in early 2025.

In order to start exchanging in 2027, the domestic legislative framework should be updated by the end of 2025 to ensure that it is in effect and applicable for Reporting Financial Institutions as of the beginning of 2026 (the year to which the information exchanged in 2027 relates). Overall, 68% of the jurisdictions (84 out of 1242) are planning to start exchanging under the amended CRS in 2027 and an increasing number reported that their domestic legislation is either in place or in the final stages of the required approval process. The remaining 32% (40 out of 124) are planning to make use of the transitional period of between one and three years as they require more time to update their domestic legislative framework. In some cases, this is because jurisdictions decided to start exchanging under the amended CRS in 2028, to align the legislative process in relation to the amended CRS with the legislative process to implement the Crypto Asset Reporting Framework (CARF). In other cases, jurisdictions require the time to complete the legislative drafting and approval processes. These include jurisdictions that only recently started exchanging under the original CRS, as well as jurisdictions that started exchanging in 2017 and 2018.

Furthermore, more than 60 jurisdictions have already signed the Addendum to the CRS MCAA to establish the international legal basis to exchange information under the amended CRS.3 The remaining jurisdictions are expected to sign the Addendum in 2026 or soon after.

Finally, the implementation of the technical updates to start exchanging using the new CRS XML Schema 3.0 in 2027 is still in an early stage and most jurisdictions are in the process of analysing the required updates to their technical systems, as well as communicating the new reporting requirements to Reporting Financial Institutions. Such activity is expected to be accelerated as we get closer to the agreed deadline of the beginning of 2027.

The Global Forum will continue to monitor the implementation of the amended CRS and continue to support jurisdictions in their implementation.

Notes

← 1.  While all Global Forum members are committed to implement the AEOI Standard, developing countries that do not host a financial centre may implement the AEOI Standard to a timeline of their choosing.

← 2.  Note that this this total does not include Nauru and Niue, reflecting the fact that there have not been any Reporting Financial Institutions identified there, so, unless and until that changes, they are not expected to implement the amended CRS.

← 3.  Signatories of the Addendum to the CRS Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information, https://www.oecd.org/content/dam/oecd/en/topics/policy-issues/tax-transparency-and-international-co-operation/addendum-crs-mcaa-signatories.pdf.