If you get paid from abroad, have a digital wallet or invest in crypto assets, you've probably heard about CRS 2.0. It's the new version of the international standard for the automatic exchange of financial information, which has been in force since January 1, 2026 and changes the rules of the game for freelancers, entrepreneurs and investors who handle money abroad.
In this guide you'll find what CRS 2.0 is, how it works, which countries participate, how it differs from FATCA and what it means in practice if you have a bank account abroad, a digital wallet or an LLC in the United States. The idea is that by the time you finish reading you'll have a clear picture of the landscape, without unnecessary jargon or promises of invisibility that are no longer real today.
Let's start with the basics.
What is CRS 2.0?
CRS 2.0 (Common Reporting Standard 2.0) is the updated version of the international standard developed by the OECD (Organisation for Economic Co-operation and Development) for the automatic exchange of financial information between countries.
It is the mechanism through which the tax authorities of more than 100 jurisdictions share information with each other about financial accounts their tax residents hold abroad. The stated goal is to strengthen transparency and detect undeclared income.
The original CRS had been in operation since 2017. Version 2.0 doesn't replace it: it expands it. And that expansion is what changes the picture for those who now operate with digital wallets, electronic money or crypto assets.
Key dates to keep in mind:
January 1, 2026: CRS 2.0 comes into force.
2026 tax year: first year reported under the new standard.
2027: first actual exchanges of information on the 2026 tax year.
In other words, CRS 2.0 is already running. What is being recorded during 2026 is what will be exchanged between tax authorities next year.
What changed compared to the original CRS?
The classic CRS was designed with a traditional banking world in mind: accounts, deposits, securities custody. The problem is that in recent years a large share of money moved to digital platforms that were off the radar. That's why the main goal of CRS 2.0 is to close those gaps.
The main changes are these:
New products covered
CRS 2.0 adds the following to automatic reporting:
Digital wallets and electronic money providers (Wise, Payoneer, Revolut and similar) based in participating jurisdictions.
Crypto assets traded on centralized exchanges in participating countries.
Central bank digital currencies (CBDC).
Tokenized instruments and other forms of electronic money.
More data per account
It's not just the year-end balance that is reported. Income flows, dividends, returns and asset sales are now added. This allows tax authorities to cross-check what they see abroad with what was declared locally and detect discrepancies.
The CARF framework, in parallel
Alongside CRS 2.0, the CARF (Crypto-Asset Reporting Framework) is being implemented, a specific framework for reporting crypto-asset transactions. It runs in parallel with CRS 2.0 and complements it: it doesn't replace it. If you trade crypto on exchanges in participating countries, it's worth keeping both frameworks in mind.
Stronger TIN requirements
CRS 2.0 tightens the requirement that every reported account be associated with a valid Tax Identification Number of the account holder. Without a TIN, the information is incomplete and platforms are exposed to penalties.
How does the automatic exchange of information work?
It's worth understanding the mechanics, because that's where the practical consequences come from.
The process, step by step
Identification of the account holder. Financial institutions (banks, wallets, exchanges) identify their clients: name, address, country of tax residence and TIN.
Data collection. They record balances, income, returns and relevant transactions during the calendar year.
Reporting to the local tax authority. Each institution sends the information to the tax authority of its own country.
Automatic exchange. That authority, in turn, shares it with the tax authorities of the countries where the account holders reside.
The process is massive and blind: it doesn't depend on a suspicion or a specific request. If you have an account in a participating country, the information travels automatically, typically in September of each year.
The technical infrastructure
The OECD manages a Common Transmission System (CTS) that interconnects more than 120 jurisdictions. Information is transmitted in standardized, encrypted XML schemas. For CRS 2.0, those schemas were updated to include specific fields for crypto assets and CBDCs.
What data is reported?
Although it may vary by jurisdiction, in general terms the report includes:
Name, address, country of tax residence and TIN of the account holder.
Account number and type.
Year-end balances.
Gross income, dividends, interest and gains from sales.
For wallets and exchanges, transactions and holdings depending on the type of platform.
Which countries participate in CRS 2.0?
The original CRS already has more than 100 participating jurisdictions. For CRS 2.0, in November 2023, a group of 48 additional jurisdictions signed the commitment to incorporate the standard into their national legislation. They include almost the entire European Union, the United Kingdom, Canada, Brazil and Chile.
Likewise, Argentina signed the Addendum to the CRS 2.0 Multilateral Agreement on July 1, 2025, which places it within the exchange schedule starting in 2027.
Now, there's a point worth stressing that is often left unclear in most explanations of CRS 2.0: the United States does not participate in CRS or CRS 2.0. It uses its own framework, called FATCA. And this is no minor detail: it defines which financial products are inside and which are outside the automatic exchange.
CRS 2.0 vs. FATCA: how do they differ?
FATCA (Foreign Account Tax Compliance Act) is a U.S. law enacted in 2010. It requires foreign financial institutions to report to the IRS (the U.S. tax agency) the accounts held abroad by U.S. taxpayers.
The central difference from CRS 2.0 lies in reciprocity.
CRS 2.0 | FATCA | |
|---|---|---|
Driven by | OECD | U.S. |
Scope | Multilateral, 100+ countries | Bilateral, country by country |
Reciprocity | Symmetrical among participating countries | Asymmetrical: the U.S. receives more than it sends |
Accounts covered | Bank accounts, wallets, electronic money, crypto assets | Accounts abroad held by U.S. tax residents |
U.S. participation | No | Yes (its own framework) |
For example, Argentina signed its IGA agreement with the United States in 2022, effective since 2023. But that agreement is governed by FATCA, not CRS. U.S. banks do not automatically report accounts held by foreign account holders to their countries of tax residence under CRS 2.0.
This doesn't mean the U.S. system is opaque. The United States maintains information exchange mechanisms on request, not automatic, and responds to formal requests from other tax administrations. The difference from CRS 2.0 is the mechanics: one works through blind, massive reciprocity, the other through specific requests.
What does CRS 2.0 mean if you get paid from abroad?
This is where the consequences vary case by case. Depending on how you get paid and where you keep your funds, your situation changes quite a bit.
If you use digital wallets in participating jurisdictions
If you get paid through Wise, Payoneer, Revolut or other platforms based in countries participating in CRS 2.0, those transactions fall under automatic reporting. Your local tax authority will receive information about balances and income. This applies both to international wallets and to local platforms that qualify as Reporting Financial Institutions under the regulations.
If you hold crypto on centralized exchanges
Centralized exchanges based in countries participating in CRS 2.0 or CARF must report holdings and transactions. If you trade on Binance, Coinbase or other global exchanges with a presence in participating jurisdictions, that data travels too.
If you have a U.S. LLC with a U.S. bank account
A business bank account in the United States in the name of an LLC is not covered by the automatic exchange under CRS 2.0, because the U.S. does not participate in that standard. What the new version expanded are digital wallets and platforms based in participating jurisdictions, not bank accounts at U.S. banks.
However, this does not equal invisibility, and it's worth being precise about it:
A foreign-owned single-member LLC is required to report its owner to the IRS using Form 5472, which reports the beneficial owner and transactions with related parties.
The United States maintains information exchange mechanisms on request with other jurisdictions.
Income generated by your activity, received in any account and in any country, is still subject to your obligation to report it in your country of tax residence.
Put another way: the mechanics of CRS 2.0 explain why a given account doesn't travel automatically, but they don't eliminate pre-existing tax obligations.
What should you do about CRS 2.0?
There's no universal answer. It depends on your profile, your tax residence, how you get paid and what kind of assets you handle. But there are some criteria that apply in most cases.
Report where you have to report
CRS 2.0 doesn't create the obligation to report. That obligation already existed. What the new standard does is strengthen the tax authority's ability to detect discrepancies between what was declared and what actually goes through your accounts. The first step in dealing with CRS 2.0 is to get your local tax returns in order.
Organize your structure
Separating personal and business operations is usually the first step. For digital service exporters, freelancers and entrepreneurs who get paid from abroad, evaluating a corporate structure suited to their operating profile can simplify management and clarify taxation. A U.S. LLC is one of the most widely used options for these profiles, but it's not the only one, nor is it right for every case.
Get professional advice
Every situation has its nuances. A freelancer earning USD 3,000 a month is not in the same position as a crypto investor with holdings on several exchanges, or an agency with clients in the European Union. Before setting up any structure, it's worth sitting down with an accountant and a structuring advisor who know the international framework.
How can Start Companies help you?
CRS 2.0 brings order to part of the landscape, but it doesn't simplify it. Each profile has different decisions to make about where to get paid, how to structure the business and how to meet its tax obligations.
At Start Companies we support entrepreneurs, freelancers and agencies with the formation and maintenance of LLCs in the United States, including handling Form 5472 (tax return), the annual report and opening business bank accounts. You can do it on your own or delegate the entire process with support at every step.
If you want to assess whether an LLC fits your current operation, contact us and together we'll map out the right path for your case.
Written by
Ignacio Navarro
Ignacio Navarro is a Certified Public Accountant, founder of Start Companies and a specialist in U.S. companies for entrepreneurs, freelancers and digital businesses in Latin America. With training in international taxation and studies at UCEMA, he advises non-resident clients on forming and maintaining LLCs, opening bank accounts, invoicing, accounting and taxes. His experience combines tax strategy, compliance and practical vision for operating in the U.S. in a simple, organized and professional way.
