FATCA corrections & re-filings — practical workflows and evidence

Corrections are inevitable: late documents, GIIN changes, TIN/name hygiene issues, or mapping fixes. This playbook shows a repeatable workflow and the evidence to keep so corrections pass audit and reviewer checks.

1) When to correct vs re-file — quick rules

• Data errors, such as name/TIN, GIIN, residence or amounts: file a correction using the same record key the platform expects.
• Omissions, such as missed accounts or recipients: submit additional records and log the reason.
• Schema or process errors, such as bad version, invalid TCC or rejected file: re-file the batch after fixing the root cause.
• Nil returns: follow portal rules; corrections may still be required if metadata was wrong.

2) Standard workflow — 5 steps

1. Identify the issue and root cause, such as late documentation, mapping bug or onboarding hygiene issue.
2. Prepare the corrected dataset and maintain a before/after diff per record.
3. Validate against the correct schema and run a dry-run where the platform supports it.
4. Submit the correction or batch; capture submission ID, receipt and any error report.
5. Close the loop: update logs, evidence and impacted processes; communicate to stakeholders.

3) Evidence pack — what to keep

• Corrections Log with before/after values, error code or description, owner, due date, status and receipt.
• Refiling Tracker for batch submissions: counts accepted/rejected and next actions.
• Receipts and error reports, including portal confirmations, PDFs/CSVs and hashes where provided.
• Root cause memo for material issues, with remediation action and validation evidence.

4) Controls that reduce re-work

• Schema and version lock in the build pipeline; sample validation before every submission.
• Name/TIN hygiene routines and monthly GIIN matching.
• Maker-checker review for corrections; approvals captured in the log.
• Post-mortems for rejected batches; mapping fixes and validation re-runs documented.

5) Templates and tools

Related reading

• FATCA reporting — Form 8966 and local IGA portals
• FATCA sponsored structures
• FATCA for Foreign Banks: Operating Model & Reporting