IEIM400925 | Non-Reporting Financial Institutions: Introduction

Non-Reporting Financial Institutions (NRFI)

Both of the automatic exchange of information regimes exclude certain Financial Institutions from being Reporting Financial Institutions. Such Financial Institutions are not required to identify, collect or report information about Reportable Persons.

These institutions are identified in Annex II of the IGA with the USA for FATCA purposes.

For the CRS the only Non-Reporting Financial Institutions are those specifically defined in Section VIII Paragraph B of the Standard and, from 1 January 2026, Qualified Non-Profit Entities. For guidance on Qualified Non-Profit Entities see IEIM400995.

The UK has not defined in domestic law any Financial Institutions excluded by reference to Sub-paragraph B (1)(c) of Section VIII of the CRS (Low-risk Non-Reporting Financial Institutions).

There are a number of differences between the regimes in this respect. The guidance that follows shows which Non-Reporting Financial Institutions are common to both regimes and which are specific to one regime.