The Global Forum’s peer reviews deliver a level playing field for governments and business by ensuring that jurisdictions committed to exchanging information under the AEOI Standard have put in place the necessary legal and administrative frameworks to ensure its effective implementation.
Peer Review of the Automatic Exchange of Financial Account Information 2025 Update
Abstract
For the potential benefits of the AEOI Standard be fully delivered, its requirements must be implemented in a complete and effective manner. 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 results from the peer reviews completed so far, after which the results are set out in full. This is followed by an update on the Global Forum’s ongoing second round of effectiveness peer reviews in relation to the AEOI Standard, an overview of jurisdictions’ activities to ensure effective implementation of the AEOI Standard in practice, with a focus on ensuring compliance by Reporting Financial Institutions, and details of the Global Forum’s activities to support jurisdictions.
Results of the reviews of the AEOI legal frameworks
Chapter 3 of this Report contains the new and amended jurisdiction reports. It includes four new reports on the AEOI legal frameworks in the jurisdictions that committed to commence exchanges from 2024 (Georgia, Kenya, Moldova and Ukraine). It also contains revised reports for 19 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 118 jurisdictions whose legal frameworks have been assessed to date, 966 recommendations were made. A total of 88 jurisdictions have brought into force amendments to their legal frameworks to address recommendations made through the Global Forum peer reviews, with 735 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 118 jurisdictions committed to commencing exchanges by 2024, virtually all of them (116, or 98%) have an international legal framework that is fully in accordance with the AEOI Terms of Reference. The Global Forum has therefore issued 116 jurisdictions with a determination of “In Place” for Core Requirement 2. Furthermore, the majority of jurisdictions (73, or 62%) 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. 73 (or 62%) 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 (41, or 35%) 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, 41 jurisdictions received an overall determination of “In Place But Needs Improvement”. In total, 114 out of 118 (or 97%) 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, 97% 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, two have implemented a domestic legislative framework which contains many of the requirements, but that include significant deficiencies. Two jurisdictions (Jordan and Montenegro) have not yet implemented a domestic legal framework. Four jurisdictions have therefore received an overall determination of “Not In Place”.
Figure 2.1 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 unaddressed. They most commonly relate to the following areas:
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 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:
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.
Other 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.
Results of the initial reviews of effectiveness in practice
Chapter 3 of this report contains the jurisdiction-specific reports. It contains four additional initial effectiveness review reports on the implementation in practice of the AEOI Standard by jurisdictions that committed to commence exchanges from 2021: Albania, Ecuador and Kazakhstan. It also includes the initial effectiveness review report in relation to New Caledonia, which committed to commence exchanges from 2020 but for which the finalisation of the review was deferred from 2024 to 2025 due to the severe political and social issues faced by New Caledonia in 2024.
Overall, the results of the initial effectiveness reviews show that most jurisdictions were on track to deliver as expected. Moreover, significant progress continues to be made since the initial assessments were carried out (see below for some preliminary observations from the ongoing second round of AEOI effectiveness reviews). The results of the initial reviews show that, as of the time of the assessment – most of which were finalised in 2022 – almost two thirds (68, or 63%) of the 108 jurisdictions reviewed so far, were 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 had developed complete administrative compliance frameworks to ensure that Reporting Financial Institutions effectively implement the due diligence and reporting obligations, which they were also implementing in practice. Furthermore, these jurisdictions were also successfully conducting the exchanges in practice, addressing any issues as they emerged.
A further 19 (or 18%) jurisdictions were found to have credible frameworks and plans in place and were generally successfully exchanging the information in accordance with the technical requirements but needed to further implement their plans. These jurisdictions were therefore rated as “Partially Compliant”. The implementation in many of these jurisdictions is expected to be maturing significantly, provided that the plans they had in place were followed through, which is being reassessed under the second round of AEOI effectiveness reviews – see below).
Finally, 21 (or around 19%) jurisdictions were found to have fundamental deficiencies in their frameworks (i.e. they were not yet fully developed) and were therefore found to be “Non-Compliant”. Of the “Non-Compliant” jurisdictions, six addressed the significant gaps in their legal compliance and enforcement frameworks that drove the result of the initial effectiveness reviews. For the jurisdictions found to be “Non-Compliant”, while the exchanges are generally taking place each year, they did not yet have complete operational frameworks to verify and enforce compliance by Reporting Financial Institutions with the due diligence and reporting requirements.
Figure 2.2 summarises the distribution of the initial peer review results in relation to effectiveness in practice.
An indicator that highlights the advancement and increasing maturity in the implementation of the AEOI Standard over time is that a significant majority of jurisdictions have reported improvements in their ability to match the information received. This indicates an increase in the quality of the information being sent. Linked to this, 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 and therefore to be able to utilise the information exchanged for tax compliance purposes. 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 in the initial effectiveness reviews
While around two thirds of jurisdictions assessed were found to be “On Track” with their implementation, amongst the remaining jurisdictions, several common issues were identified.
The most significant issues identified related to the lack of a complete framework to enforce the requirements. In many cases some activities had been conducted to ensure Reporting Financial Institutions were reporting information as required (e.g. by cross checking relevant lists of regulated entities), but there had been limited activities to ensure that the information reported was complete and accurate. These jurisdictions generally committed to quickly work to address the deficiencies identified. Support is also 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 are being successfully addressed (which is being reassessed in the context of the second round of AEOI effectiveness reviews – see below). It will generally take longer for jurisdictions that need to address constraints in their legal frameworks to enforce the requirements as they complete the necessary legislative processes.
There is another group of jurisdictions that had credible plans in place but that had only recently started implementing them. For example, the checks to ensure that the information being reported was complete and accurate was 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.
Table 2.1 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 20221 which has been supplemented by the reports in Chapter 3 of the 2023 and 2024 reports for the assessments and reassessments completed in each of those years, and in Chapter 3 of this 2025 report for the assessments and reassessments conducted in 2025.
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 relevant public and private sector stakeholders (i.e. tax authorities, financial supervisors and representatives from Reporting Financial Institutions).
As the AEOI Standard is only effective to the extent that Reporting Financial Institutions are compliant with the due diligence and reporting obligations, the second round of AEOI effectiveness reviews involves a deeper assessment of the administrative strategies and frameworks put in place by jurisdictions to ensure compliance, as well as the actions taken and the results of those actions. There is also an annual peer input process to obtain feedback from each jurisdiction’s exchange partners to inform the review. The second round of effectiveness reviews commenced in 2023 and all 99 jurisdictions that committed to commence exchanges in 2017 or 2018 are being assessed simultaneously. The peer reviews are centred around onsite visits according to a three-year schedule, leading to internal interim reports prepared by assessment teams consisting of experts from AEOI implementing jurisdictions. The internal interim reports then act as a roadmap for the jurisdiction to make further progress in its implementation of the AEOI Standard, before the reports are updated at the end of the process (i.e. in 2026) to reflect the most up to date situation.
This section of the report provides an update on the Global Forum’s second round of AEOI effectiveness peer reviews. In advance of the publication of the peer review reports in 2026, including the jurisdictional-context, analysis and conclusions, an overview of the work undertaken by jurisdictions to ensure Reporting Financial Institutions comply with the AEOI Standard through the development and implementation of administrative compliance frameworks is provided. Furthermore, this section highlights the support offered by the Global Forum to jurisdictions in their implementation of the AEOI Standard and sets out details of the process leading to the forthcoming publication of the peer review reports in 2026.
Update on the process for the second round of effectiveness peer reviews
The Global Forum’s second round of AEOI effectiveness peer reviews have been progressing at pace. The first tranche covers the 99 jurisdictions that committed to implement the AEOI Standard in time to commence exchanges in 2017 or 2018. To date, assessment teams comprised of two expert assessors from a pool of 81 officials from 45 jurisdictions implementing the AEOI Standard, supported by a member of the Global Forum Secretariat, have conducted 91 onsite visits. During these visits, assessment teams meet with the officials involved in ensuring compliance by Reporting Financial Institutions, including policy teams, legal advisers and compliance auditors. The assessment teams also meet with the financial regulatory authorities and representatives of the financial sector, typically including the banking, insurance, custodial, trustee and investment management sectors. These in-person meetings, lasting several days, allow for the assessment teams to establish a detailed understanding of the situation on the ground, as well as highlight to senior government stakeholders and to industry the importance that the Global Forum has placed on ensuring that the AEOI Standard is effective, including ensuring that Reporting Financial Institutions are complying with their obligations. The remaining onsite visits are due to take place in the near future.
In line with the framework for these second round AEOI effectiveness reviews, the AEOI Peer Review Group (or the APRG, the body of 30 Global Forum members implementing the AEOI Standard that is charged with delivering the peer reviews) has reviewed and approved a total of 91 interim internal reports and provisional ratings. The process consists of the assessment team presenting its findings, the assessed jurisdiction representing its position and the APRG asking any questions and providing any steers, before it ultimately approves the report. This ‘interim internal report’ is a tool for assessment teams to share their immediate findings with the jurisdiction following the onsite visit and is intended to highlight at an early stage any deficiencies or areas for improvement identified in the administrative compliance frameworks. This provides jurisdictions with the opportunity to further implement and enhance their frameworks before the assessment teams update and finalise the reports in 2026.
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. This is supported by continuing to disseminate the practices observed to all jurisdictions and allowing time for their sustainable implementation and review. Support has also been available from the Global Forum throughout the process.
How jurisdictions are ensuring compliance by Reporting Financial Institutions
Since the completion of the initial reviews on effectiveness in 2022, jurisdictions have continued to develop and implement their administrative compliance frameworks. The second round AEOI effectiveness peer review reports to be published in 2026 will set out the work that each jurisdiction has undertaken to ensure the effective implementation of the AEOI Standard.
While all 99 peer reviews are ongoing, this section is intended to provide a high-level overview of what has been observed so far in relation to what jurisdictions have been doing in practice to ensure compliance by their Reporting Financial Institutions. It is not intended to evaluate the practices, set expectations, or to pre-empt the outcomes to be included in the 2026 report. Furthermore, while examples and aggregate statistics are provided from the information reported by assessed jurisdictions during the process, they represent a snapshot at a point in time and it is known that many jurisdictions have been undertaking substantial further work since the production of their draft interim report.
Development of risk-based compliance strategies that facilitate and ensure compliance
Since the initial effectiveness reviews, jurisdictions have continued to develop their compliance strategies to target the areas identified as being of highest risk. In almost all cases, this has meant carrying out compliance activities in relation to the Reporting Financial Institutions assessed as most likely to encounter challenges and posing a greater risk of non-compliance. It also means taking into account the jurisdictional context, as challenges to the implementation of the AEOI Standard vary depending on the nature of the jurisdiction’s financial sector and its legal and regulatory context. Jurisdictions have therefore been developing and updating comprehensive risk assessments to ensure that their compliance strategies effectively target the areas and sectors considered to pose the greatest risk to the effective implementation of the AEOI Standard.
Such compliance strategies continue to include a balance of activities to support and inform the financial sector of its obligations and to verify and enforce compliance. These are expanded on in the sub-sections below, which reflect the observed evolution on these strategies, including a widespread increase in the scale and depth of verification activities undertaken across many jurisdictions.
Relevant communication and outreach activities often include developing and making available a range of guidance and technical materials or tools to assist with reporting. One jurisdiction developed a chatbot where Reporting Financial Institutions can receive answers to their questions, along with links to a range of related information. The chatbot receives around 30 requests for information on a daily basis. Another jurisdiction, with a certain proportion of its population who are in possession of more than one identity card/passport or who are cross-border workers, sought to address common misunderstandings that Reporting Financial Institutions were encountering in obtaining valid self-certifications, complemented its outreach activities by raising awareness among Account Holders of the requirements to provide self-certifications and on the relevant tax residency criteria. More generally, jurisdictions continue to support industry through close engagement with representative bodies and working groups and, in several cases, have organised training events and seminars for Reporting Financial Institutions.
Ensuring Reporting Financial Institutions report as required
While the AEOI Standard and its requirements are now generally well established among the financial sector, there remains a risk that not all Reporting Financial Institutions that should be reporting information do so in practice. This can result from a lack of awareness or a misunderstanding of the obligations, or where a Reporting Financial Institution has chosen not to comply with the requirements. Great importance is therefore placed on jurisdictions understanding their financial sectors, identifying their population of Reporting Financial Institutions (including regulated Entities and non-regulated Entities that are classified as Financial Institutions for the purposes of the AEOI Standard), and ensuring that all Reporting Financial Institutions report as required. In all cases, Reporting Financial Institutions must report information in relation to Reportable Accounts that they maintain, but filing obligations for Reporting Financial Institutions with no Reportable Accounts now also exist in the majority of jurisdictions (i.e. nil returns). So far, 80% of jurisdictions have reported having some form of registration requirement for all Reporting Financial Institutions and 64% reported having an annual nil reporting requirement where a Reporting Financial Institution does not maintain any Reportable Accounts.
Most jurisdictions rely on a range of sources to identify their population of Reporting Financial Institutions. In almost all cases, this has included reviewing lists of licensed or supervised providers of financial services to identify regulated financial institutions, such as banks, custodial institutions, insurance companies and investment funds, that are within the scope of the AEOI Standard.
The identification of Reporting Financial Institutions that are not regulated – typically Entities that are Investment Entities because their assets are discretionarily managed by other Financial Institutions – can be more challenging as it requires the review of suitable sources of information available to the jurisdiction to identify Entities with the relevant characteristics. In one jurisdiction with a large number of foreign managed companies, the company registrar has amended its economic substance reports to include AEOI-related questions. In cases where the registrar identifies companies considered likely to be Investment Entities because of a relevant economic activity or purpose, the companies are proactively required to review their status and confirm whether they are Financial Institutions. In other jurisdictions, unregulated Reporting Financial Institutions are considered most likely to be managed by established fund or trust management sectors. Several of these jurisdictions conduct comprehensive reviews on each group of registered fund administrators and trustees, during which a full client list is obtained and a selection of clients is reviewed in more detail to determine whether the managed Entities have been correctly classified.
More generally, the latest figures from each jurisdiction show a 33% increase in the total number of Reporting Financial Institutions reporting Financial Account information compared to 2021, which can in part be attributed to jurisdictions’ compliance activities (including activities to raise awareness to facilitate compliance, as well as activities to verify and enforce compliance).
Even when Reporting Financial Institutions are aware of their obligations and have reported information in the past, it is important to ensure that they continue to report information in a timely manner so that exchange partners receive the expected data by 30 September annually. Jurisdictions have been active in reminding their Reporting Financial Institutions to report by the domestic filing deadline and, once the deadline has passed, in following up with those Reporting Financial Institutions that are delayed.
Ensuring the information reported is complete and accurate
Ensuring Reporting Financial Institutions report information is not the end of what is needed to ensure the AEOI Standard is effective. It must also be ensured that the information reported is complete and accurate. Reporting Financial Institutions may not have a sufficient understanding of the requirements, may not have effectively implemented them or may not seek to comply. To ensure that tax authorities can rely on the data received from their partners, it is therefore important that jurisdictions verify that their Reporting Financial Institutions are reporting complete and accurate information.
For most jurisdictions, beyond the basic validation requirements contained in the CRS XML Schema, checks to ensure that the information reported by Reporting Financial Institutions is complete and accurate begins with other pre-exchange checks on the quality of the data reported. This is to prompt any corrections in advance of sending the information to exchange partners. It can also serve as a risk assessment tool, to inform further activities. Jurisdictions then typically conduct more in-depth verification activities when they want further assurance that the information reported is complete and accurate, beyond the obvious errors or omissions that can be observed when analysing the information reported. This is to identify any underlying failures in Reporting Financial Institutions’ application of the due diligence or reporting requirements.
A range of such activities were observed, starting with activities that can help obtain comfort on compliance of a relatively large segment of the Reporting Financial Institution population, such as issuing compliance questionnaires and/or conducting ‘thematic reviews’ to address specific issues or themes. Activities designed to obtain a deeper level of assurance often come in the form of ‘comprehensive reviews’, which in most cases involve visits to the premises of Reporting Financial Institutions, where compliance is checked at a more granular level. During these reviews, jurisdictions typically analyse the Reporting Financial Institution’s policies and procedures and conduct checks on a sample of accounts, inspecting the underlying account documentation, to ensure the correct application of the procedures in practice. Jurisdictions typically adopt a mix of approaches to target their activities and maximise the overall assurance obtained.
As an example, one jurisdiction conducts comprehensive reviews on its Reporting Financial Institutions in three phases. In the first phase, auditors conduct an initial interview with relevant compliance staff from the Reporting Financial Institution and review its policies and procedures to ensure that they are sufficient and that they correctly cover all of the key areas of the AEOI Standard. An electronic master list is then obtained in relation to all of the Financial Accounts maintained by the Reporting Financial Institutions, along with several pieces of relevant information on each Account Holder. This is used by auditors to select a representative sample of Financial Accounts to review. In the second phase, auditors review the sampled Financial Accounts to test whether the Reporting Financial Institution’s policies and procedures are being followed correctly in practice. Following the completion of the reviews and during the third phase, a Compliance Report is produced that includes a Compliance Action Plan with requirements and recommendations on any actions that the Reporting Financial Institution must or should take. In reflection of the depth of the compliance actions, following the completion of several of the reviews, the tax administration identified Financial Accounts that were incorrectly not reported, and some with missing Tax Identification Numbers. Financial Accounts were also identified that were missing self-certifications that should have been collected and many more where the Reporting Financial Institutions had failed to ensure that the self-certifications were reasonable. In all cases, the Reporting Financial Institutions were required to remediate the deficiencies.
Around 79% of jurisdictions are conducting data quality checks to ensure that the data is as accurate and complete as possible before it is exchanged. Additionally, since 2022, jurisdictions have issued more than 100 000 questionnaires to their Reporting Financial Institutions as part of their compliance activities with a view to either better understanding the nature of the business or the information they reported, or to request details on their implementation of the requirements. These questionnaires typically either help jurisdictions identify Reporting Financial Institutions of highest risk or are used to test their compliance in the context of a desk-based review. Furthermore, since 2022, jurisdictions reported having reviewed the policies and procedures in respect of more than 35 000 Reporting Financial Institutions and have conducted over 2 400 comprehensive reviews covering more than 20 000 Financial Institutions, including Trustee Documented Trusts. These activities have led to the identification of around 700 Financial Institutions substantially failing to comply with the requirements and the identification of around 1.9 million incorrectly reported or unreported Financial Accounts in 2022 and 1.8 million in 2023. This has allowed jurisdictions to ensure Reporting Financial Institutions remediate any non-compliance and submit corrections to the data reported, including in many cases before the exchange has taken place.
Additionally, jurisdictions’ targeted efforts to follow up on Reporting Financial Institutions reporting ‘undocumented accounts’ have led to a substantial fall in the number of such accounts from 1 033 899 in 2020 to 310 690 in the latest year such data is available for each jurisdiction (i.e. as determined at the date of the onsite visit of the peer review). The higher number of undocumented accounts reported in earlier years was generally due to misunderstandings amongst Reporting Financial Institutions on what such accounts are, with many believing that they constitute Financial Accounts for which a self-certification is not obtained, rather than applying the strict criteria in the AEOI Standard (which essentially means that the Reporting Financial Institution does not hold any information on the Account Holder that provides an indication as to their jurisdiction of tax residence).
Overall, the efforts of jurisdictions to ensure compliance by Reporting Financial Institutions is, along with other relevant factors, contributing to an increase in the number of accounts on which information is exchanged between jurisdictions. The total number of accounts on which information was reported by Reporting Financial Institutions increased from over 139 million in 2021 to over 165 million2 for the most recent years jurisdictions have provided data. 35 jurisdictions reported significant increases of more than 20% in the number of accounts reported and in 18 of these, the number of accounts reported increased by more than 50%.
While the number of Financial Accounts reported will be impacted by various factors, such as the opening of new accounts, jurisdictions specifically reported the impacts of their compliance activities (including those to ensure all Reporting Financial Institutions report as required) contributing to the identification of around 500 000 accounts in 2022 alone that would have otherwise been unreported.
Enforcement
An effective compliance framework also requires an enforcement framework, to ensure that non-compliance is appropriately deterred and addressed. In addition to having in place the necessary legal provisions to apply penalties and sanctions (which were one of the focus areas of targeted legal assessments in 2023), jurisdictions have been implementing and refining their frameworks to apply their enforcement powers in practice.
Jurisdictions often built on the frameworks in place that were seen to work in analogous areas, such as in jurisdictions where the authorities responsible for compliance with the AEOI Standard had in place established enforcement frameworks for other areas under their supervision (e.g. compliance with tax or anti-money laundering requirements). In other jurisdictions, an AEOI-specific approach, framework and processes were developed with the AEOI due diligence and reporting obligations in mind.
In the early years of implementation, many jurisdictions had in place a ‘soft-landing’ approach when non-compliance was identified or discussed with Reporting Financial Institutions. This focused on correcting the issues and ensuring that they were not repeated. However, in more recent years, in addition to facilitating compliance, jurisdictions have been more ready to apply penalties and sanctions, recognising that Reporting Financial Institutions should now be much more familiar with their obligations and to preserve the deterrent effect of their enforcement framework. In the second round of AEOI effectiveness peer reviews so far, jurisdictions have reported applying over 4 400 penalties for failures to correctly implement the AEOI Standard, including late filing, failing to file, failing to correctly conduct the due diligence procedures and for filing incomplete or incorrect information.
Support provided by the Global Forum
Throughout the implementation of the AEOI Standard, including prior to and during the second round of AEOI effectiveness peer reviews, the Global Forum Secretariat has provided jurisdictions with guidance and support to assist them in understanding the peer review process, providing detail on the level of maturity that they need to demonstrate to show that they are in compliance with the AEOI Terms of Reference (see Annex B). The Global Forum has also made available to jurisdictions tools and examples of how to implement the requirements and it has provided bilateral technical assistance to jurisdictions, helping them to develop, refine and implement their administrative compliance frameworks.
From the peer review perspective, the Secretariat has sought to quickly share the emerging outcomes and lessons learned with all AEOI jurisdictions as the process has progressed. This included organising three coaching sessions for all assessed jurisdictions to provide them with detailed guidance on the peer review methodology, as well as on the outcomes of the analysis of the APRG in relation to common examples of implementation approaches, including the common pitfalls identified. These were supported by further, more detailed written guidance to assessment teams and assessed jurisdictions on horizontal issues and key areas of emerging focus in the peer reviews. Assessment teams complement this process by engaging extensively with the jurisdictions before, during and after the onsite visits, including to ensure that the jurisdictions fully understand the issues identified and can ask any follow-up questions.
The Capacity Building and Outreach Division in the Global Forum Secretariat has also provided extensive and dedicated support to jurisdictions in their implementation of the AEOI Standard, since the inception of the Standard itself. Since the conclusion of the initial effectiveness reviews in 2022, the Secretariat increased its activities to support jurisdictions in their development and implementation of administrative compliance frameworks, culminating in the creation of a dedicated and comprehensive technical assistance programme (the Administrative Compliance Strategy Programme). Under this programme, the Secretariat has developed ‘knowledge tools’ and resources to help jurisdictions develop, improve and/or implement their own administrative compliance strategy and which are available to jurisdictions on request. These include:3
a Model Administrative Compliance Strategy, aimed at helping jurisdiction design a compliance framework tailored to their own circumstances (provided to 79 jurisdictions)
a Methodology for the Implementation of the Risk-Based Approach to Administrative Compliance and its Risk Matrix to support jurisdictions in designing or improving their risk assessment to better inform their compliance activities (provided to 60 jurisdictions)
a Model Manual for CRS Compliance Audits to help jurisdictions develop adequate procedures to carry out CRS verification activities (provided to 88 jurisdictions)
a CRS Notifications Tracking Tool and its Glossary to ensure a smooth communication between CRS partner jurisdictions with respect of errors or non-compliance (provided to 47 jurisdictions)
These knowledge tools support the extensive, bilateral technical assistance provided to jurisdictions to assist in their implementation of the AEOI Standard and to address the recommendations made in the initial effectiveness reviews. Since 2023, the Secretariat has also proactively offered bilateral assistance on developing an administrative compliance framework to all jurisdictions that received a Non-Compliant rating in the initial effectiveness reviews. Ten other jurisdictions that received On Track or Partially Compliant ratings have also benefited from the assistance.
The Secretariat has also organised several virtual and in-person events bringing together officials from AEOI implementing jurisdictions from the tax authorities responsible for ensuring AEOI compliance in order for them to share challenges, experiences and best practices. This includes a new practical workshop format to develop the skills and knowledge of how to prepare compliance activities, how to select and review underlying documentation maintained by Reporting Financial Institutions and how to conduct in-depth/holistic and thematic reviews. Since 2024, six events were organised and all benefited from a high level of engagement, with over 620 officials from 114 jurisdictions working on practical case studies to develop their AEOI auditing skills. In addition, in 2025, a dedicated Train the Trainer series on Common Reporting Standard Administrative Compliance was delivered over six months. This programme focused on equipping local specialists with the expertise needed to effectively monitor and supervise financial institutions. The 102 participants from 50 jurisdictions developed their knowledge on the AEOI due diligence and reporting obligations.
The publication of the reports in 2026
The results of the second round AEOI effectiveness reviews for the 99 jurisdictions that committed to implement the AEOI Standard in time to commence exchanges in 2017 or 2018 are due to be published in the 2026 AEOI Peer Review Report. These will reflect any developments that have taken place in each jurisdiction since the onsite visit. To deliver this, the assessment teams will work with each jurisdiction to ensure that the analysis and conclusions accurately reflect the latest situation, before they are submitted for consideration and final approval by the ARPG. Subject to the APRG’s approval, the reports will be submitted for adoption by AEOI Peers (i.e. all jurisdictions implementing the AEOI Standard) for publication. This will be the culmination of the largest ever peer review exercise of the implementation of the AEOI Standard since its implementation and the most significant update since the publication of the initial effectiveness reports on these 99 jurisdictions in 2022.
← 1. OECD (2022), Peer Review of the Automatic Exchange of Financial Account Information 2022, OECD Publishing, Paris, https://doi.org/10.1787/36e7cded-en.
← 2. The number of accounts reported will not be an exact match with the number of accounts exchanged for a number of reasons, including the approach taken by some jurisdictions that require Reporting Financial Institutions to provide information on accounts with an Account Holder in any foreign jurisdiction and not only in those with which there is an activated exchange relationship in place. Moreover, the latest figures of accounts reported by Reporting Financial Institutions will be as early as 2022 for jurisdictions whose onsite visit took place in 2023.
← 3. OECD (2025), Tax Transparency in Action: From Global Progress to Domestic Impact – 2025 Global Forum Capacity Building Report, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD, Paris, https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/2025-global-forum-capacity-building-report.pdf.