The Inland Revenue Authority of Singapore (IRAS) has published revised lists of Reportable Jurisdictions and Participating Jurisdictions for Common Reporting Standard (CRS) purposes, introducing new compliance obligations for Singaporean Financial Institutions (SGFIs) with immediate and retrospective effect.
Key jurisdictional changes
With effect for the 2025 reporting calendar year, 3 African Nations: Rwanda, Senegal and Uganda have been added to the List of Reportable Jurisdictions. Concurrently, Curaçao has been removed. SGFIs must now include financial account information pertaining to tax residents of the three African jurisdictions in their CRS submissions to IRAS, due by 31 May 2026 for accounts maintained during calendar year 2025.
Separately, effective 2 February 2026, Rwanda, Senegal and Uganda have also been designated as Participating Jurisdictions under the Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) Regulations 2016.
Practical implications for SGFIs
The dual listing carries significant operational consequences. For SGFIs maintaining accounts held by Investment Entities structured as professionally managed vehicles, the Participating Jurisdiction status of these three jurisdictions modifies the due diligence treatment applicable.
Where an account is held by an Investment Entity described in sub-paragraph A(6)(b) of Section VIII of the CRS, and that entity is resident in a jurisdiction that is not a Participating Jurisdiction, the SGFI is required under Regulation 8 to treat such entity as a Passive Non-Financial Entity (NFE). This triggers mandatory “look-through” requirements to identify and report the Controlling Persons of that entity.
The designation of Rwanda, Senegal and Uganda as Participating Jurisdictions means that Investment Entities tax resident in these jurisdictions will now be recognised as Financial Institutions for CRS purposes. Consequently, the look-through treatment described above will no longer apply to such entities from the effective date.
Compliance challenges identified
Several practical issues arise from this update:
First, retrospective application. The addition of Rwanda, Senegal and Uganda to the Reportable Jurisdictions list applies to the 2025 calendar year, yet the Participating Jurisdiction designation took effect only on 2 February 2026. SGFIs face an asymmetry: accounts held by residents of these jurisdictions are reportable for 2025, but the Participating Jurisdiction status—which would have exempted certain Investment Entities from look-through treatment—was not available during that reporting period.
SGFIs with Investment Entity clients that are professionally managed and tax resident in Rwanda, Senegal or Uganda must therefore conduct look-through analysis for 2025 reporting, notwithstanding that the same entities will qualify as Participating Jurisdiction Financial Institutions for 2026 onwards. This creates inconsistent treatment across consecutive reporting cycles and imposes compliance costs for a one-off obligation.
Second, remediation and data capture. Many SGFIs may not have coded Rwanda, Senegal and Uganda as reportable jurisdictions for 2025, given the absence of these countries from prior lists and their relatively recent adoption of CRS standards. Self-certification forms obtained during 2025 may not have anticipated tax residency in these jurisdictions. SGFIs must now undertake retrospective account reviews to identify affected accounts, and where indicia of residency exist, pursue remedial self-certifications.
Third, system configuration updates. The removal of Curaçao and simultaneous addition of three African jurisdictions require updates to CRS classification taxonomies within SGFI systems. Given that the 2025 reporting cycle is currently underway, institutions must ensure that account opening and maintenance systems accurately reflect the revised jurisdictional status for both existing and new accounts.
Fourth, Participating Jurisdiction verification. SGFIs should verify that their CRS due diligence procedures correctly distinguish between the Reportable Jurisdictions list (which determines whose accounts are reported) and the Participating Jurisdictions list (which determines the classification of Investment Entities). The two lists now diverge: not all Reportable Jurisdictions are Participating Jurisdictions, and vice versa.
Compliance timeframe
SGFIs are reminded that CRS returns for calendar year 2025 are due 31 May 2026. Remedial due diligence and system updates should be prioritised to ensure complete and accurate reporting. IRAS has not indicated transitional relief for the retrospective application of the three new Reportable Jurisdictions; SGFIs should assume full compliance is required.
Source: IRAS website, 2 February 2026