Singapore — Reporting mechanisms (FATCA & CRS)

Q: Who is the reporting authority in Singapore for FATCA and CRS?

The Inland Revenue Authority of Singapore (IRAS) is the competent authority for FATCA and CRS in Singapore. Reporting Singaporean Financial Institutions (SGFIs) submit their FATCA and CRS returns to IRAS via myTax Portal AEOI e-services, and IRAS then exchanges the information with the IRS and other reportable jurisdictions under the Model 1 IGA and CRS framework.

Q: Do Singaporean financial institutions report FATCA data directly to the IRS?

No. Under the Model 1 intergovernmental agreement between Singapore and the United States, Singapore-based financial institutions report FATCA information to IRAS, not directly to the IRS. IRAS subsequently transmits the FATCA data to the IRS. Institutions must still register with the IRS and obtain a GIIN if they are Reporting SGFIs for FATCA purposes.

Q: What is the filing deadline for FATCA and CRS returns in Singapore?

For both FATCA and CRS, Reporting SGFIs must generally submit their returns, including nil returns where applicable, by 31 May of the year following the calendar year to which the return relates.

Q: How are FATCA and CRS reporting errors corrected after filing?

If errors are discovered after filing with IRAS, the Reporting SGFI must correct them by submitting updated FATCA or CRS data via myTax Portal. For CRS, corrections typically involve replacement or void/deletion records referencing the original DocRefIDs; for FATCA, corrected XML files are submitted in line with the IRAS supplementary XML user guide. Institutions should maintain an internal audit trail documenting the error, the correction and management approvals.

How Singaporean financial institutions report FATCA and CRS data in practice: roles and responsibilities, electronic filing via IRAS myTax Portal (AEOI), report contents, the annual filing cycle, error corrections, data quality and governance – and key touchpoints with the U.S. QI regime.

At a glance

Competent authority: Inland Revenue Authority of Singapore (IRAS) as the AEOI hub for FATCA and CRS.
FATCA model: Model 1 IGA – Reporting Singaporean Financial Institutions (SGFIs) report to IRAS, which exchanges with the IRS.
Channels: Electronic-only filing via myTax Portal > AEOI > Submit CRS or FATCA Return and IRAS AEOI services.
Scope: Account holder and controlling person data, tax residencies and TINs, account balances and income / gross proceeds.
Frequency & due date: Annual returns (FATCA and CRS) due by 31 May of the year following the calendar year; nil returns required if no reportable accounts.

Who should care?

Singapore-based banks, merchant banks and other deposit-taking institutions
Custodial institutions, capital markets intermediaries, fund managers and investment funds
Life insurers with cash value / annuity-type products
Trust companies and other entities that qualify as Reporting SGFIs under FATCA and/or CRS regulations

1) Roles & responsibilities

IRAS – AEOI hub (FATCA & CRS). IRAS administers FATCA and CRS in Singapore: it registers Reporting SGFIs, issues guidance and XML specifications, receives FATCA and CRS returns electronically (including nil returns) and exchanges information with partner jurisdictions – the IRS for FATCA and reportable jurisdictions for CRS.
Reporting SGFI (financial institution). Performs FATCA/CRS due diligence, classifies account holders and controlling persons, collects self-certifications, maintains KYC and tax records, prepares data in IRAS-compliant XML / PDF formats and submits annual FATCA and CRS returns to IRAS by the 31 May deadline, including corrections and follow-up submissions where needed.
Policy & regulation (MOF, MAS). The Ministry of Finance (MOF) and Monetary Authority of Singapore (MAS) provide legislative and regulatory frameworks for FATCA and CRS, including subsidiary regulations and MAS notices that shape financial institutions’ governance, risk management and AML/CFT requirements.
IRS (United States). Receives FATCA data from IRAS under the Model 1 IGA and separately supervises FATCA registration (GIINs), the QI regime and QI periodic certifications for Singapore-based intermediaries.

2) Reporting channels & technology

Path	Description	Key points
myTax Portal – AEOI e-services	Reporting SGFIs log in to myTax Portal and use the “Submit CRS or FATCA Return” e-service to upload CRS or FATCA returns in XML or (for certain use cases) fillable PDF format.	Since 1 April 2020, all FATCA returns (including nil returns) must be filed electronically via this e-service. CRS returns are also filed electronically, and there is no requirement for separate encryption/compression beyond IRAS technical specifications.
File formats & tools	For CRS, SGFIs prepare XML files in line with the IRAS XML Schema User Guide for CRS Return. For FATCA, SGFIs apply the US IRS FATCA XML Schema v2.0 together with the IRAS Supplementary XML User Guide for Preparing the FATCA Reporting Data File.	IRAS publishes detailed schema documentation and lists of CRS file and record-level errors that institutions should use to design validations and map data from source systems before submission.
Access & registration	Institutions must first register as Reporting SGFIs for CRS and/or FATCA with IRAS, then obtain appropriate myTax Portal access (e.g. Corppass) and AEOI e-service authorisations.	CRS registration is generally due by 31 March of the year following the year an entity becomes a Reporting SGFI. User access and Corppass roles should be controlled under internal governance and removed promptly for leavers.
Message & record identifiers	FATCA and CRS XML files use `MessageRefID` and `DocRefID`-type fields to uniquely identify messages and records for reporting and correction.	IRAS strongly encourages structured MessageRefID formats (e.g. incorporating GIIN and timestamp) to support reconciliation and correction logic; SGFIs should adopt and document a consistent convention.

3) Reported data (content)

Account holder and controlling person identifiers: full name, address, date of birth (individuals), entity name, registered office address, tax residency (jurisdiction(s)), tax identification numbers (U.S. TIN, foreign TINs, and Singapore TIN where applicable) and, for CRS, details of controlling persons of certain entities.
Account details: account number or functional equivalent, account type, currency, and the account balance or value as at 31 December of the reporting year (or immediately before closure).
Income and gross proceeds: depending on product type and regime, interest, dividends and other income credited to the account, and where required, gross proceeds from the sale or redemption of financial assets.
FI identifiers: Reporting SGFI name, GIIN (for FATCA), local tax reference number and other institutional identifiers required by IRAS schemas.
Internal due-diligence status (not always transmitted): documentation status (self-certification on file, documentary evidence), U.S. indicia flags, undocumented or recalcitrant status, reasonable explanations for missing TINs and TIN follow-up history should be tracked internally, even where not all elements are explicitly included in the XML return.

4) Reporting period & filing deadlines

For both FATCA and CRS, Singapore uses a calendar-year reporting period (1 January to 31 December). All Reporting SGFIs must submit their FATCA and CRS returns – including nil returns, where applicable – by 31 May of the year following the calendar year to which the return relates.

If 31 May falls on a weekend or public holiday, institutions should follow IRAS guidance for that year, but in practice lodgments made on the next business day are generally treated as on time. IRAS routinely issues reminders and publishes lists of reportable and participating jurisdictions for each CRS reporting year.

Practical timeline example: many SGFIs structure their internal process as year-end extraction → FATCA/CRS classification & cleansing → XML generation & pre-validation → management sign-off → IRAS filing (by 31 May) → monitoring acknowledgements & error reports.

5) Data quality & error corrections

IRAS validations: FATCA and CRS returns submitted via myTax Portal are subject to file-level and record-level validations against IRAS schemas and business rules. Invalid files or records are rejected with error codes that must be investigated and fixed.
Corrections and deletions: IRAS allows multiple submissions for the same reporting year. Corrections typically use replacement or void/deletion records referencing the original DocRefIDs for CRS, and corrected FATCA XML files for FATCA. All submissions for a given reporting year must be made by the 31 May due date.
TIN management: IRAS and the IRS expect SGFIs to obtain, validate and report U.S. and foreign TINs. Recent guidance allows limited use of specific TIN codes for certain pre-existing U.S. reportable accounts where TINs cannot be obtained, provided additional conditions and ongoing outreach are met – this should be reflected in policies and system logic.
Schema & version control: SGFIs must monitor IRAS updates to CRS XML Schema User Guides and FATCA supplementary XML guides, as well as OECD CRS XML schema upgrades (e.g. adoption of CRS v3.0 from 1 January 2027) and implement changes ahead of the applicable reporting years.
Reconciliations and analytics: reconcile aggregate balances and income reported in FATCA/CRS returns to core banking, custody and investment systems; perform year-on-year trend and outlier analysis on reportable populations (by jurisdiction, product, business line) to detect potential gaps or anomalies before and after filing.

6) Governance & controls

Key controls

Appointment of a named FATCA/CRS reporting owner with a clearly documented deputy
Documented four-eyes review (preparer / reviewer) and senior management sign-off before IRAS filing
Formal change and release management for IRAS schema updates, OECD CRS changes and related system changes
End-to-end audit trail covering data sourcing, mapping rules, validation outcomes, XML files, IRAS receipts and corrections
Regular training for Front Office / onboarding teams, KYC, tax operations, compliance, risk and IT

Policies & interfaces

Integrated FATCA/CRS policy that sets out classification logic, indicia workflows, self-certification standards and TIN escalation
Alignment with AML/CFT and data protection frameworks (PDPA, MAS guidelines) on purpose limitation, data minimisation and retention
Interface with QI: ensure FATCA/CRS data is consistent with QI documentation (W-8/W-9 forms, GIINs, Chapter 3/4 statuses) and apply a coherent reason-to-know framework across IRAS reporting and IRS withholding tax regimes.

FAQ

Who is the reporting authority in Singapore for FATCA and CRS?

The Inland Revenue Authority of Singapore (IRAS) is the competent authority for FATCA and CRS in Singapore. Reporting SGFIs submit their FATCA and CRS returns to IRAS via myTax Portal AEOI e-services, and IRAS then exchanges the information with the IRS and other reportable jurisdictions under the Model 1 IGA and CRS framework.

Do Singaporean financial institutions report FATCA data directly to the IRS?

No. Under the Model 1 intergovernmental agreement between Singapore and the United States, Singapore-based financial institutions report FATCA information to IRAS, not directly to the IRS. IRAS subsequently transmits the FATCA data to the IRS. Institutions must, however, still register with the IRS and obtain a GIIN if they are Reporting SGFIs for FATCA purposes.

What is the filing deadline for FATCA and CRS returns in Singapore?

FATCA and CRS returns must generally be filed by 31 May of the year following the calendar year to which the return relates. This applies to both substantive and nil returns. IRAS occasionally publishes reminders and examples confirming the 31 May deadline for specific reporting years.

How are errors corrected after filing with IRAS?

If errors are identified after filing, institutions must submit corrected FATCA or CRS data via myTax Portal. For CRS, this usually involves replacement or void/deletion records referencing the original DocRefIDs; for FATCA, corrected XML files are submitted. All corrections for a given reporting year should be made by the 31 May filing due date where possible, and internal audit trails should document the error, root cause and approvals.

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Note: This page is a practice-oriented overview. Binding details on formats, schemas, channels and timelines are set out in the most recent IRAS publications (FATCA and CRS filing pages, AEOI e-service user guides, XML schema guides and FAQs), the Singapore–U.S. FATCA Model 1 IGA and related domestic legislation, plus OECD CRS materials. Always check the latest IRAS guidance before filing.