|
|
| Regulator |
OECD / IRD / ATO |
| Jurisdiction |
Global |
| Status |
live |
| Applicability |
Platform |
The OECD Common Reporting Standard (CRS) is the international framework for the automatic exchange
of financial account information between tax authorities. It was developed by the OECD in 2014 and
endorsed by the G20. Under CRS, financial institutions (including banks) must identify the tax
residency of account holders, collect the required information, and report annually to their domestic
tax authority, which then exchanges data with the account holder's country of tax residence.
New Zealand participates in AEOI under the Tax Administration Act 1994 (Part 11B) and the OECD/G20
Base Erosion and Profit Shifting (BEPS) project. Reporting is to Inland Revenue (IRD). Australia
participates under the Taxation Administration Act 1953 (Schedule 1, Subdivision 396-B) and reports
to the Australian Taxation Office (ATO). Both jurisdictions have signed multilateral competent
authority agreements for AEOI.
Key obligations are: (1) due diligence on all financial accounts to determine tax residency (new
accounts at opening, pre-existing accounts via self-certification or indicia search); (2) annual
report filed with IRD or ATO by the prescribed date (NZ: 30 June following the reporting period; AU:
31 July); (3) pre-existing account review — high-value individual accounts within 1 year, lower-value
and entity accounts within 2 years of go-live. FATCA (US Foreign Account Tax Compliance Act) imposes
parallel obligations for US persons and is covered by the same policy and module.
Compliance register
This register maps every material obligation under CRS/AEOI to the platform control or institutional
process that satisfies it. It is the static traceability layer for the Totara compliance report —
dynamic data (module build status, test evidence, control test dates) is overlaid at runtime.
Scope legend
| Symbol |
Meaning |
| 🤖 Automated |
Platform enforces or performs the obligation. Primary control mode is GATE, AUTO, CALC, or ALERT. Human action is not required in the normal case. |
| 📊 Evidenced |
Platform captures the evidence trail automatically. Human compliance decision sits on top. Primary control mode is LOG. |
| 🏛 Institutional |
Obligation is met by a process entirely outside the platform — regulatory registration, tax counsel review, annual certifications. Platform may generate evidence inputs but does not own the process. |
| N/A |
Obligation does not apply to this deployment configuration. |
Build legend
| Symbol |
Meaning |
| ✅ |
Module built and deployed |
| 🔨 |
Module planned — not yet built (build_status: Not started) |
| ❌ |
Uncontrolled gap — no module attributed |
Due diligence obligations
| Ref |
Obligation |
Scope |
Policy |
Platform controls |
Build |
| CRS s.1 — New accounts |
Obtain self-certification from new account holders at opening; determine tax residency before account activates |
🤖 Automated |
PRI-004 |
MOD-060 (AUTO) — FATCA and CRS due diligence workflows automated; account classification applied at onboarding from CDD profile data including tax residency and entity classification |
🔨 |
| CRS s.2 — Pre-existing individual |
Review pre-existing individual accounts for CRS indicia; obtain self-certifications for accounts meeting the threshold |
🤖 Automated |
REP-011 |
MOD-060 (AUTO) — automates CRS due diligence workflows including pre-existing account review scheduling and self-certification collection |
🔨 |
| CRS s.3 — Entity accounts |
Identify controlling persons of passive NFE entity accounts; apply CRS due diligence to controlling persons |
🤖 Automated |
PRI-004 |
MOD-060 (AUTO) — entity account classification and controlling person identification included in the CRS due diligence workflow |
🔨 |
| CRS s.4 — FATCA classification |
Apply FATCA W-9 / W-8 classification to US persons; identify US indicia for account holders |
🤖 Automated |
PRI-004 |
MOD-060 (AUTO) — FATCA due diligence workflows automated alongside CRS; classification determined from CDD profile |
🔨 |
Annual reporting obligations
| Ref |
Obligation |
Scope |
Policy |
Platform controls |
Build |
| CRS report — NZ |
File annual CRS report with IRD by 30 June following the reporting period; include name, address, TIN, account balance, income, and gross proceeds |
🤖 Automated |
REP-011 |
MOD-060 (AUTO) — annual report preparation and submission to IRD automated; account balance and interest data sourced from CDC pipeline in Snowflake |
🔨 |
| CRS report — AU |
File annual CRS report with ATO by 31 July following the reporting period |
🤖 Automated |
REP-011 |
MOD-060 (AUTO) — annual report preparation and submission to ATO automated |
🔨 |
| FATCA report |
File annual FATCA report with IRD (NZ) and ATO (AU) for US person accounts; IRD / ATO transmits to IRS |
🤖 Automated |
REP-011 |
MOD-060 (AUTO) — FATCA and CRS report preparation and submission automated together |
🔨 |
| Data disclosure logging |
Every cross-border data transmission to IRD / ATO / IRS under FATCA/CRS logged with recipient, data scope, legal basis, and transmission timestamp |
📊 Evidenced |
PRI-004 |
MOD-060 (LOG) — every cross-border data transmission recorded; provides the privacy evidence base for tax data sharing |
🔨 |
Record-keeping obligations
| Ref |
Obligation |
Scope |
Policy |
Platform controls |
Build |
| Record retention |
Retain account holder due diligence records and self-certifications for 7 years (NZ) / 5 years (AU) from end of reporting year |
🤖 Automated |
PRI-004 |
MOD-060 relies on MOD-010 (CDD profile data retained) and the immutable record store; self-certifications retained as part of the CDD record and are not deletable |
🔨 |
| Obligation |
Owner |
Platform evidence input |
| Registration as a Reporting Financial Institution with IRD / ATO |
CFO / Tax Counsel |
Institutional registration; not platform scope |
| Responsible Officer designation and certification (FATCA) |
CFO |
Institutional compliance certification; not platform scope |
| Tax counsel review of self-certification validity and borderline classifications |
CFO / Tax Counsel |
MOD-060 surfaces accounts requiring manual review |
| Appeals and dispute resolution with IRD / ATO on classification decisions |
CFO / Tax Counsel |
MOD-060 provides the classification data and audit trail |
Coverage summary
| Area |
Total obligations |
Platform automated 🤖 |
Platform evidenced 📊 |
Institutional 🏛 |
N/A |
| Due diligence |
4 |
4 |
0 |
0 |
0 |
| Annual reporting |
4 |
3 |
1 |
0 |
0 |
| Record-keeping |
1 |
1 |
0 |
0 |
0 |
| Total |
9 |
8 (89%) |
1 (11%) |
0 |
0 |
All attributed modules are currently build_status: Not started — the compliance position will
update as modules are built and deployed.
| Policy |
Title |
| PRI-004 |
FATCA & CRS Compliance Policy |
| REP-011 |
Tax & information reporting (FATCA/CRS/AEOI) |
See D10 Governance & Legal for the full risk domain.
Official documentation
Policies referencing this standard
- PRI-004 — FATCA & CRS Compliance Policy
- REP-011 — Tax & information reporting (FATCA/CRS/AEOI)
Compiled 2026-05-22 from source/entities/regulations/industry-crs-aeoi.yaml