Background: OECD CRS and the New CARF
The Common Reporting Standard (CRS) is an OECD initiative launched in 2014 that requires financial institutions to report foreign account holders’ information to their local tax authority, which then shares it with the account holders’ home jurisdictions. Over 100 jurisdictions have implemented CRS, leading to a global network of Automatic Exchange of Information on financial accounts. In 2023, the OECD conducted a comprehensive review of CRS to address digital assets and other gaps, resulting in two major developments: an updated CRS standard and a new Crypto-Asset Reporting Framework (CARF). CARF is a parallel regime providing for the automatic exchange of tax-relevant information on crypto-asset transactions in a standardized manner. It was developed to prevent crypto-assets from being used to obscure taxable assets or erode gains in tax transparency. At the same time, the CRS itself was amended to include electronic money products and Central Bank Digital Currencies, cover indirect crypto investments via derivatives or investment vehicles, and strengthen due diligence and reporting requirements. Together, the CARF and amended CRS form a coordinated effort to expand transparency to new asset classes and intermediaries that previously fell outside the scope of traditional AEOI regimes.Implementing these standards internationally involves countries signing onto multilateral agreements. CARF’s implementation is facilitated by a new MCAA (similar to how CRS is implemented via the CRS MCAA). Dozens of jurisdictions have quickly signaled support. By late 2024, 61 jurisdictions had committed to adopt CARF by 2027/28, with 48 already signing the CARF MCAA and 51 signing the CRS addendum. Mauritius’s recent commitment places it firmly in this first wave of CARF adopters.
Mauritius as an Early Adopter of Crypto AEOI
Mauritius has long participated in global tax transparency initiatives – it was an early implementer of CRS for banking and investment accounts. Embracing CARF is a natural extension of this policy. By signing the CARF MCAA and CRS MCAA addendum, Mauritius signals that it will require domestic crypto-asset service providers (such as exchanges, wallet providers, and certain fintech firms) to conduct due diligence on their users and report relevant data to the Mauritius Revenue Authority (MRA) for international exchange. This early adopter stance aligns Mauritius with other forward-looking financial centers (for example, Jersey, Singapore, and UAE) that are proactively integrating crypto reporting into their regulatory frameworks. Aligning with CARF is expected to strengthen Mauritius’s appeal as a transparent and compliant offshore hub for digital asset businessescomsuregroup.com. It also underscores Mauritius’s commitment to curbing tax evasion through crypto-assets, complementing its existing CRS commitments for traditional assetscomsuregroup.com.Being ahead of the curve does come with challenges. Participation in CARF means Mauritian authorities and institutions must invest in new reporting infrastructure and safeguards. Notably, Mauritius has emphasized data protection and robust IT systems in its CARF implementation planscomsuregroup.comcomsuregroup.com. Ensuring confidentiality and security of sensitive financial data is critical, given that detailed information on crypto transactions and holdings will be collected and exchanged. Overall, Mauritius’s proactive move sends a message that it intends to meet the highest international standards in tax transparency, even in emerging sectors like crypto.
Implications for Private Clients and Fiduciary Structures
The adoption of CARF and the updated CRS regime carries significant implications for private clients using Mauritius-based structures and for the fiduciary and financial services industry:
- Private Clients: Individuals who hold crypto-assets in Mauritius, whether through local exchanges, custodians, or entities, will lose any expectation of “hidden” assets. Crypto holdings and transactions will be reported to the MRA and subsequently exchanged with the clients’ home tax jurisdictions (just as foreign bank accounts are under CRS). This enhanced transparency means private clients must ensure they are fully compliant with tax reporting in their home countries. Those who utilized Mauritius trusts or companies to hold digital assets should be prepared for their holdings to be disclosed to foreign authorities. The upside is an environment of greater legitimacy, compliant investors may benefit from Mauritius’s stable regulatory oversight, while tax evaders will find it harder to hide in crypto.
- Trusts and Fiduciary Structures: Trust companies, foundations, family offices, and corporate service providers in Mauritius will need to incorporate CARF requirements into their operations. Many such fiduciary structures could fall under the definition of Reporting Crypto-Asset Service Providers if they custody or manage crypto-assets on behalf of clients. They will therefore have to perform due diligence to identify the tax residencies and TINs of beneficial owners and settlors with crypto interests, keep records of crypto transactions, and file annual CARF reports to the MRA.
Timeline and Implementation Steps
Mauritius’s roadmap for rolling out CARF and the CRS amendments is expected to align with the OECD’s global timeline:- Late 2025: Legal Framework Readiness. Following the Cabinet’s approval, Mauritius will finalize domestic legislative and regulatory measures to implement CARF and the CRS addendum. This includes updating laws or regulations to define which entities are Reporting Crypto-Asset Service Providers, and to empower the MRA to collect and exchange crypto-account information. The Mauritius Revenue Authority is already preparing updates to its AEOI reporting portal and guidance materials to accommodate the new data requirements. Read Rosemont’s article here: OECD CRS 2026: What financial institutions need to know about the new reporting rules
- By 1 January 2026: Effective Date for Data Collection. The target date for Mauritius to begin applying the CARF and revised CRS rules. From this date, financial institutions and crypto-asset service providers in Mauritius will need to start collecting the expanded data points on account holders’ crypto transactions and new CRS data fields (e.g. account type, self-certification status, digital asset holdings). Due diligence procedures must be in place to identify customers’ tax residencies and gather any missing Tax Identification Numbers. Institutions will use 2025 to update onboarding forms, IT systems (including adopting the new OECD XML schemas), and internal policies in preparation for this deadline.
- 2026 Calendar Year: Ongoing Compliance Build-Out. Throughout 2026, reporting entities will continue to adapt to the CARF/CRS 2.0 requirements. This transitional period may include industry training and possibly further guidance from the OECD or MRA. Some flexibility or phased implementation may be allowed on certain data elements not readily available for pre-existing accounts, in line with OECD recommendations. Mauritius is likely to follow the OECD’s norms in granting transitional relief where needed (for example, allowing omission of new data fields for older accounts until systems catch up).
- By 2027: First Exchanges of Information. The first automatic exchanges under the CARF and amended CRS are expected to occur in 2027, exchanging information collected for the 2026 reporting yearcomsuregroup.com. This mirrors the timeline for the EU’s DAC8 directive and other early-adopting jurisdictions. In 2027, Mauritius will both send out crypto asset and financial account data of foreign taxpayers to their respective jurisdictions and receive data about Mauritian tax residents’ crypto activities from other CARF participantscomsuregroup.com. These exchanges will mark the full integration of Mauritius into the global network of tax transparency for digital assets.
- Beyond 2027: Continued Compliance and Monitoring. After initial exchanges, Mauritius will be subject to ongoing peer reviews and Global Forum monitoring to ensure effective implementation (as is the case with CRS). The MRA will likely enforce compliance through audits or penalties for non-reporting institutions. The international standards may evolve further, and Mauritius will need to keep pace with any future updates to CARF or CRS. By being an early adopter, Mauritius gains experience early, but also commits to continuously maintaining a high level of compliance infrastructure.
Conclusion and Rosemont’s Expertise
Mauritius’s adoption of the OECD’s crypto-asset reporting and updated CRS regime is a significant milestone in the evolving landscape of international tax compliance. It enhances transparency and aligns the jurisdiction with emerging global standards, albeit with added responsibilities for local institutions and investors. Navigating these complex reporting obligations requires deep expertise in cross-border tax rules and careful structuring.Rosemont’s international tax compliance and structuring team stands ready to assist financial institutions, trust companies, and private clients in Mauritius and worldwide in adapting to the CARF and CRS changes. With extensive experience in OECD transparency standards, Rosemont can help review compliance frameworks, update reporting systems, and structure asset holdings in full conformity with the new requirements, ensuring that clients remain both compliant and strategically positioned as Mauritius enters this new era of crypto-AEOI.
For guidance on how CARF may affect your structures or crypto holdings, feel free to contact our Mauritius team: office@rosemont.mu