Ireland — Regulatory Framework (FATCA, CRS & QI)

Last updated: 18 Oct 2025

Ireland — Regulatory Framework

Overview of the key legal sources, competent authorities and technical standards in Ireland for FATCA (Model 1 IGA), CRS/DAC2 and the QI regime – including interfaces and practical notes for Irish financial institutions.

Key points

  • FATCA is implemented via a Model 1 IGA: reporting to Revenue (Irish Tax and Customs), which forwards data to the IRS.
  • CRS/DAC2 is implemented in Irish law and operated via Revenue’s AEOI framework.
  • QI remains a US regime (IRS) but can rely on Irish Approved KYC Rules for documentation checks.

Who is in scope?

  • Banks, custodians, brokers, MiFID firms and other Irish Reporting FIs.
  • Investment funds, management companies and other collective investment vehicles.
  • Insurance companies with relevant cash value / annuity products.

1) Legal sources (selection)

AreaSourceContent / focus
FATCA (IGA) US–Ireland FATCA Intergovernmental Agreement (Model 1) + Annex I/II Definitions, due diligence and reporting requirements; Annex II exemptions for specific Irish entities/products.
FATCA (domestic) Section 891E TCA 1997; Financial Accounts Reporting (United States of America) Regulations 2014 (S.I. 292/2014) as amended Domestic implementation of the IGA: reporting obligations, Revenue’s powers and AEOI framework.
CRS / DAC2 Sections 891F & 891G TCA 1997; CRS/DAC2 regulations and Revenue guidance Automatic exchange of information under CRS and the EU Directive on Administrative Cooperation (DAC2) for non-resident account holders.
QI IRS QI Agreement; Approved KYC Rules (Ireland) US withholding and documentation regime; recognition of Irish KYC processes for W-8/W-9 review.
AML / KYC Criminal Justice (Money Laundering and Terrorist Financing) Acts; Central Bank of Ireland guidance Customer due diligence, ongoing monitoring and governance – foundation for “reason-to-know” and documentation quality.
Data protection GDPR; Data Protection Act 2018; AEOI-related provisions in TCA 1997 Legal basis for processing and transmitting account data; information requirements, retention and security.

2) Responsibilities

  • Revenue Commissioners: competent authority for FATCA and CRS/DAC2 in Ireland; receipt, validation and onward transmission of AEOI data.
  • Central Bank of Ireland (CBI): prudential and conduct supervision, including AML/CFT frameworks, governance and outsourcing.
  • Financial institutions: customer due diligence, classification, data capture, reporting and remediation of errors.
  • IRS: primary supervisor for QI (QI Agreement, Periodic Review, certifications and potential sanctions).

3) Interfaces: FATCA ↔ CRS/DAC2 ↔ QI

  • Consistency of identifiers (US TIN, Irish TIN where applicable, GIIN), customer data and documentation status across all regimes.
  • Annex II exemptions (FATCA) vs. CRS/DAC2 obligations need to be clearly mapped for each product line and entity type.
  • KYC synergies: Irish KYC processes can support QI and CRS/FATCA due diligence, but tax-specific requirements (e.g. self-certifications, W-forms) must still be met.

4) Technical standards (high level)

  • FATCA and CRS XML prepared in line with the latest Revenue filing guidelines and schema versions.
  • Electronic submission via ROS / AEOI channels with appropriate digital certificates and encryption.
  • Change management process for schema updates, new validations and Revenue/IRS guidance; test submissions before go-live where feasible.
  • Defined process for corrections/voids/amendments with stable record keys and audit trail.
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Note: This page provides a practice-oriented summary. The binding rules are set out in the current official documents (US–Ireland FATCA IGA, Sections 891E/891F/891G TCA 1997 and related regulations, CRS/DAC2 framework, IRS QI Agreement, Revenue/CBI guidance). Always check the latest versions before taking decisions.