From 1 January 2027 the UAE adopts CRS 2.0 and the Crypto-Asset Reporting Framework. For DIFC foundations, family offices and funds the work is practical: confirm each entity's classification and bring controlling person records and self-certifications up to date.
The short answer
- Both start on 1 January 2027. The UAE adopts the updated Common Reporting Standard and the Crypto-Asset Reporting Framework from that date, with first exchanges in 2028.
- CRS 2.0 widens the scope. Electronic money, central bank digital currencies and some indirect crypto holdings come into scope.
- Roles are now reported. The role of each controlling person, such as founder, council member or beneficiary of a foundation, must be reported, not just their identity.
- CARF covers crypto service providers. Families and funds holding crypto through exchanges or brokers will be asked for self-certifications and controlling person details.
- Classification is the key task. Confirm whether each entity is a Reporting Financial Institution or a Non-Financial Entity, and keep the reasoning on file.
Last reviewed 2 October 2026
From 1 January 2027, the UAE moves to a new generation of international tax reporting. The updated Common Reporting Standard, known as CRS 2.0, takes effect on that date, and so does the Crypto-Asset Reporting Framework, or CARF. The first exchanges of information under both are expected in 2028.
For most DIFC families, foundations and funds this is not a new tax. It is a change in what is reported, about whom, and in how much detail. Structures that are well documented will adapt with little effort. Structures with out-of-date classifications or incomplete ownership records will feel it first. This guide explains what changes, who is affected, and what to put in order over the next three months.
The short answer
CRS 2.0 extends the UAE's existing financial account reporting to electronic money and central bank digital currencies, brings some indirect crypto holdings into scope, and requires more detail about the people who control entities, including their exact roles. CARF adds a parallel regime for crypto-asset service providers. Both start in the UAE on 1 January 2027, with first exchanges in 2028. For a DIFC foundation, family office or fund, the practical work is to confirm each entity's classification and make sure controlling person records and self-certifications are complete and current.
What has been announced
The UAE Ministry of Finance announced its commitment to implement CRS 2.0 from 1 January 2027, with the first exchange of information under the updated standard in 2028, as reported by PwC Middle East. Separately, the UAE signed the Multilateral Competent Authority Agreement under CARF in 2025, as noted by Pinsent Masons, and has since ratified it, with go-live on 1 January 2027 and first exchanges in 2028.
Both frameworks come from the same package of standards published by the OECD in June 2023. They were designed to work together: CARF covers crypto-assets held through crypto service providers, and the amended CRS updates the existing regime for financial accounts.
What CRS 2.0 changes
The original Common Reporting Standard has applied in the UAE for years. Financial institutions identify account holders who are tax resident elsewhere and report their accounts to the Ministry of Finance, which exchanges the information with other countries. CRS 2.0 keeps that model and widens it:
| Area | What changes under CRS 2.0 |
|---|---|
| New products | Electronic money products and central bank digital currencies come into scope |
| Crypto exposure | Indirect investments in crypto-assets, for example through funds or holding entities, can fall within CRS |
| Controlling persons | The role of each controlling person must be reported, not just their identity |
| Account details | Reports show whether an account is joint, whether it is new or pre-existing, and whether a valid self-certification was obtained |
| Self-certifications | A clearer definition of what a valid self-certification must contain |
For family structures, the most important line is the third one. Reporting a person's role, such as founder, council member, beneficiary or protector of a foundation, means the information exchanged about a family structure becomes far more precise.
What CARF adds
CARF applies to Reporting Crypto-Asset Service Providers: exchanges, brokers and other businesses that carry out crypto-asset exchange transactions for customers. These providers must collect self-certifications from their users, identify where they are tax resident, and report their transactions each year.
Most DIFC families and funds are not crypto service providers themselves. Where they hold crypto-assets through an exchange or broker, they will be asked for self-certifications and information about their controlling persons, in the same way a bank asks today under CRS. A foundation or holding company that holds crypto through a provider should expect those requests during 2027.
Who is affected in the DIFC
Funds and fund managers
DIFC funds and many fund managers are already Reporting Financial Institutions under CRS. They will need to update onboarding forms, self-certification templates and reporting systems to capture the new data points, including controlling person roles and account status.
Foundations, trusts and family holding companies
How a family entity is treated depends on its classification. An entity whose assets are managed by a financial institution can itself be an Investment Entity and a Reporting Financial Institution. Otherwise it is usually a Passive Non-Financial Entity, and the banks and custodians that hold its accounts report its controlling persons. Getting that classification right is the single most useful thing a family structure can do before 2027. Our guide to DIFC Foundations explains the roles within a foundation that will now be reported.
Family offices
A single family office that manages investments for the family may meet the definition of an Investment Entity, depending on how it is structured and who manages the assets. Our overview of DIFC family office rules and licensing sets out the common structures.
A three-month checklist
Use the remaining months of 2026 to put the basics in place:
- Map every entity. List each company, foundation, fund and SPV in the structure, with its jurisdiction and purpose.
- Confirm each classification. Decide whether each entity is a Reporting Financial Institution or a Non-Financial Entity, and record the reasoning.
- Update controlling person records. For every entity, record who its controlling persons are and the role each one holds.
- Refresh self-certifications. Expect banks, custodians and crypto providers to request updated forms. Having accurate information ready makes those requests quick.
- Align your registers. Make sure your DIFC registers, beneficial ownership filings and CRS records tell the same story.
- Review crypto holdings. Note any crypto-assets held directly or through providers, and which entity holds them.
The final UAE implementing rules will set the detailed mechanics, so treat this checklist as preparation and confirm the details once the Ministry of Finance publishes them.
Why this is good news for well-run structures
Greater transparency rewards structures that are properly organised. A foundation or holding company with clear records, accurate classifications and current controlling person details will move through bank reviews and self-certification requests quickly, and will find onboarding with new institutions easier. The UAE's early adoption of both standards also strengthens its standing as a well-regulated, internationally aligned financial centre, which is part of what makes the DIFC attractive to families and fund managers in the first place.
How Atlas helps
Atlas Corporate Services is a DFSA-registered Corporate Service Provider in the DIFC. We maintain the corporate records that CRS 2.0 relies on: registers of members, directors and beneficial owners, foundation records and group structure charts, through our company secretarial and governance service. For families, we establish and administer DIFC Foundations and holding structures with this level of documentation built in. Tax classification work is delivered with GTAG, our sister company in the GTAG/Assetica group.
This article is general information and does not constitute legal, tax or regulatory advice. The UAE's implementing rules for CRS 2.0 and CARF will govern the detailed requirements. Confirm the position for your structure with a qualified adviser before acting.
Frequently Asked Questions
When does CRS 2.0 start in the UAE?
The UAE Ministry of Finance has committed to implement the updated Common Reporting Standard, CRS 2.0, from 1 January 2027, with the first exchange of information under the updated standard in 2028.
What is CARF and when does it apply in the UAE?
The Crypto-Asset Reporting Framework is the OECD standard for reporting crypto-asset transactions by crypto service providers. The UAE has signed and ratified the multilateral agreement under CARF, with go-live on 1 January 2027 and first exchanges in 2028.
What does CRS 2.0 change compared with the original CRS?
It brings electronic money products and central bank digital currencies into scope, can capture indirect crypto holdings, requires the role of each controlling person to be reported, and adds information such as whether an account is joint, whether it is new or pre-existing, and whether a valid self-certification was obtained.
Does CRS 2.0 affect a DIFC Foundation?
Yes, in how the foundation is classified and reported. A foundation whose assets are managed by a financial institution may itself be a Reporting Financial Institution. Otherwise it is usually a Passive Non-Financial Entity, and the banks and custodians holding its accounts report its controlling persons, now including their roles.
Is CRS 2.0 a new tax?
No. CRS 2.0 and CARF are reporting and information exchange standards. They change what financial institutions and crypto service providers report and to whom, not how much tax an entity pays.
What should a DIFC family structure do before 2027?
Map every entity, confirm each one's classification, update controlling person records with each person's role, prepare for refreshed self-certification requests from banks and crypto providers, align corporate registers with CRS records, and note any crypto-assets and which entity holds them.