Switzerland CRS in 2026: CRS 2.0, Crypto Expansion and FATCA Timing – why the TCSP role is important

16/02/2026

Switzerland has entered a new phase in its automatic exchange of information framework. In early 2026, the Swiss Federal Tax Administration issued updated guidance aligning domestic rules with the OECD’s revised Common Reporting Standard, commonly referred to as CRS 2.0

Shortly afterwards, the State Secretariat for International Finance confirmed that Switzerland’s transition from a Model 2 to a reciprocal Model 1 FATCA Intergovernmental Agreement with the United States has been deferred until 1 January 2028.

For foreign trust and corporate service providers administering client structures that maintain Swiss bank or custody accounts, these developments are operationally significant. They directly affect onboarding standards, classification analyses, reporting data points and coordination with Swiss financial institutions.

Below we summarise the practical implications and how Rosemont supports cross-border TCSPs navigating the Swiss landscape:

1. CRS 2.0 in Switzerland: More Data, More Precision
The updated Swiss CRS guidance reflects the OECD’s broader expansion of scope and granularity. Key themes include enhanced identification requirements, revised due diligence standards and a wider range of reportable assets.

Enhanced Identification and Role Disclosure
Swiss Reporting Financial Institutions must now report additional identification information, including:

Confirmation that a valid self-certification has been obtained for each Reportable Person
Whether an account is joint, and the number of joint holders
The specific roles of Controlling Persons in relation to entity account holders
The role under which a Reportable Person holds an equity interest in an investment entity structured as a legal arrangement

For multi-layered trust, foundation and holding company structures, this means that role mapping must be accurate and documented. In practice, foreign TCSPs should expect Swiss banks to revisit legacy files and request clearer articulation of settlor, trustee, protector, beneficiary and controlling person roles.

Transitional Relief – But Only Partially
For accounts maintained before 26 September 2025, Swiss institutions may rely on electronic records for certain role reporting during a transitional period. However, this does not remove the underlying expectation that structures are well documented and internally consistent. TCSPs administering Swiss-banked entities should not assume grandfathering. Where records are incomplete, banks may require refreshed self-certifications or updated organisational charts.

2. Multiple Tax Residences and CBI/RBI scrutiny
CRS 2.0 eliminates the ability for individuals with multiple tax residences to rely on tie-breaker rules to select a single jurisdiction in their self-certification. All jurisdictions of tax residence must now be declared.

In addition, where tax residence is claimed in a jurisdiction associated with high-risk citizenship or residence by investment programmes, Swiss institutions are now expected to conduct enhanced verification. Additional questions regarding physical presence, residence rights and tax filings may be raised.

For foreign TCSPs acting for internationally mobile clients, particularly those with EU, UAE, Caribbean or other residency profiles, alignment between tax advice, corporate administration and bank documentation is critical. Inconsistencies are likely to trigger account reviews.

3. Crypto-Assets, Digital Money and expanded FI definitions
The Swiss CRS framework now explicitly captures relevant crypto-assets within the definition of reportable financial assets. Custodial institutions earning income from crypto custody and exchange services fall within scope, and relevant crypto holdings may be reportable custodial accounts.
Additionally:

Income and gains from crypto-assets are treated as passive income when assessing Active versus Passive NFE status
Depository institution definitions now include entities holding specified electronic money products and central bank digital currencies
Aggregation rules apply to such digital balances

For corporate structures holding digital assets through Swiss platforms, this changes classification outcomes. An entity previously analysed as an Active NFE may now fall into Passive NFE status, requiring identification and reporting of controlling persons.

Rosemont regularly reviews NFE analyses and FATCA/CRS classifications for holding companies, SPVs and family office vehicles with Swiss accounts, ensuring alignment with evolving asset classes.

4. Capital Contribution Accounts and structuring implications
Swiss guidance introduces a formalised treatment of capital contribution accounts as excluded accounts, subject to strict conditions. Funds must remain blocked until incorporation or capital increase is confirmed, and refunds must flow only to original contributors.

For foreign promoters establishing Swiss-banked holding companies, careful sequencing of capitalisation, incorporation evidence and account conversion is required. Improper handling may convert what was expected to be an excluded account into a reportable one.

5. FATCA: Model 2 continues until 2028
Switzerland’s move to a reciprocal Model 1 FATCA IGA has been delayed, with the earliest entry into force now scheduled for 1 January 2028.
Until that date:

Swiss financial institutions remain under the Model 2 regime
Reporting to the IRS continues directly, subject to account holder consent
Withholding agents should continue to select “Reporting Model 2 FFI” status on FATCA forms

For foreign TCSPs administering entities with U.S. indicia or U.S. beneficial owners, there is no immediate procedural shift. However, forward planning is advisable. A Model 1 framework will route reporting through the Swiss Federal Tax Administration, with reciprocal exchange. Document retention, GIIN status, entity classification and consent documentation should be reviewed ahead of transition.

6. Why this matters for foreign TCSPs
Swiss banks are applying increasing scrutiny to:

Controlling person role clarity
Multi-jurisdictional tax residence claims
Crypto exposure within corporate structures
NFE classification robustness
FATCA status consistency

Foreign TCSPs that do not actively manage these issues risk delayed onboarding, account restrictions or file remediation requests.

Rosemont: Cross-Border administrative control
Rosemont International offices are routinely involved in the administration of international holding companies, trusts and foundations with Swiss banking relationships. Our TCSP teams:

Maintain detailed role and beneficial ownership information
Coordinate self-certification collection and renewal cycles
Review CRS and FATCA classifications in light of asset mix changes
Liaise directly with Swiss relationship managers and compliance teams
Align corporate administration with tax advisory input

Switzerland remains a leading financial centre. With CRS 2.0, expanded digital asset reporting and a forthcoming FATCA Model 1 framework, professional coordination between TCSPs and Swiss institutions has never been more important.

Rosemont provides a structured interface between the client and the Swiss financial institution to manage these changes, and ensure compliance.

For more information, please contact office@rosemont-mc.com

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