An important change is coming to CRS compliance in the Cayman Islands: it will affect every fund, SPV and Reporting Financial Institution.
From the 2026 reporting cycle (with full effect by 2027), the Department for International Tax Cooperation (DITC) will require your Principal Point of Contact (PPOC) to be physically based in Cayman.
What’s changing?
The PPOC has always been the person the DITC can contact if they have questions about your FATCA/CRS filings. But until now, many managers appointed someone in another jurisdiction: often an administrator or compliance officer sitting in New York, London or Hong Kong.
Going forward, that won’t be enough. The DITC has confirmed that:
- The PPOC must be located in the Cayman Islands.
- They must be available to respond to DITC queries on your FATCA/CRS submissions, notifications and any follow-up requests.
- They will be responsible for keeping you updated as new legislation and reporting requirements come into force.
It’s a light role in terms of day-to-day effort. But it carries real accountability. And failing to appoint a compliant PPOC could result in penalties.
What ELSE is changing in this legislation?
First of all, crypto-assets, certain electronic money products and central bank digital currencies will now fall within the CRS framework.
Most crypto-asset service providers will instead fall under CARF, but crypto-asset custodians and related businesses may still be captured by CRS.
Second, Reporting Financial Institutions will face earlier annual return and compliance form deadlines: moving to 30 June each year for all filings, starting with the 2026 reporting period.
New entities forming from 2026 will also need to register with the DITC by 31 January, not 30 April.
And third, more detailed information must be collected and reported. Financial institutions will now need to capture additional data, including:
- the role of controlling persons
- whether an account is “new” or “pre-existing”
- the type of account, including joint-account indicators
Why appointing wb.group can help you
When we act as your PPOC, the process becomes simpler for one reason: we live and work in Cayman every day. Our CRS clients value three things:
- Responsiveness — the DITC reaches out, and we’re on it immediately.
- Accuracy — filings are checked, consistent and submitted correctly.
- Updates — new legislation and regulatory notices are reviewed and flagged before they affect your structure.
For financial institutions who need their CRS obligations handled with zero delay, having us in the PPOC seat removes one moving part from an already crowded compliance calendar.
If you haven’t yet appointed a Cayman-based PPOC, it’s worth addressing it early — well before the 2026/27 requirement takes effect. It’s a small adjustment that prevents unnecessary risk.
If you’d like to discuss your PPOC appointment or streamline your FATCA/CRS process, we’re happy to help.