Starter Package: FATCA (Model 1 & Model 2)

Author: Alexander Fölsche, CPA (US), Wirtschaftsprüfer (Germany), Swiss Licensed Audit Expert

Everything you need to determine your FATCA status, register with the IRS, and set up your national Model 1 or IDES Model 2 submission channel. Country-specific pricing is listed on the Countries pages.

Scope: FATCA classification, IRS FATCA registration, GIIN issuance, national portal setup for Model 1 jurisdictions, IDES readiness for Model 2 jurisdictions, and starter documentation for counterparties, regulators and internal stakeholders.

Who this is for

  • Foreign banks, asset managers, funds/SPVs, trust companies, custodians, and specified insurance companies starting or re-starting FATCA compliance.
  • Institutions operating in Model 1 jurisdictions that report to a local competent authority, or Model 2 jurisdictions that report directly to the IRS via IDES.
  • Groups seeking a uniform, audit-ready baseline across multiple countries.

Outcomes

  • Decision-grade opinion on your FATCA status, including FI vs. NFFE, Investment Entity analysis, and Non-Reporting / Annex II options.
  • Live registrations: IRS registration with GIIN, national portal/data-sender setup for Model 1, or IDES readiness for Model 2.
  • Reviewer-ready starter documentation for regulators, counterparties, and internal audit.

What you get

1) FATCA Filing Obligation Opinion

  • Entity classification: FI vs. NFFE; Investment Entity “managed-by” test; Specified Insurance Company; exemptions.
  • Jurisdiction mapping: Model 1 local authority reporting vs. Model 2 Form 8966 / IDES reporting.
  • Non-Reporting / deemed-compliant checks, including Annex II categories where available.
  • Clear go/no-go conclusion, risks, assumptions, and next steps.

2) IRS Registration & GIIN

  • IRS FATCA portal setup.
  • Responsible Officer and Points of Contact configuration.
  • Submission of FATCA registration.
  • GIIN issuance tracking and confirmation pack for counterparties.

3) National / IDES Onboarding

  • Model 1: Local competent-authority portal and data-sender setup, including roles, certificates and test readiness where applicable.
  • Model 2: IDES technical readiness for direct IRS submissions of Form 8966.

4) Starter Docs & Guides

  • Concise onboarding guide with checklist and screenshots.
  • GIIN confirmation and first-submission readiness checklist.
  • Template language for counterparty outreach and basic FATCA status attestations.

Scope & boundaries

Included: Status opinion, IRS registration and GIIN, national/IDES technical onboarding, and starter documentation.

Not included: Full governance/process design and data mapping (Build), annual filings and back filings (Run), and independent health checks (Assurance).

How it works

  1. Kickoff & data request: entity tree, licenses, products, client profile, and existing KYC/W-forms approach.
  2. Analysis & opinion: FI/NFFE status, Investment Entity analysis, Model 1 vs. Model 2, and non-reporting options.
  3. Registrations: IRS portal and GIIN; national portal or IDES setup.
  4. Handover: starter pack with confirmations and first-submission readiness checklist.

Indicative timeline

Delivery typically fits a short project window once prerequisites are in place, including portal access, corporate approvals and responsible stakeholder availability. Country-specific SLAs and pricing are provided on the Countries pages.

Prerequisites

  • Authorized signatories for IRS portal and any national portal.
  • Nomination of a Responsible Officer.
  • Basic organizational and KYC documentation, including legal names, addresses, entity chart, activities, and regulatory permissions.
  • Contact details for operational and technical stakeholders, including Compliance, Operations and IT.

Helpful resources

Next steps

Need FATCA setup support?
Pick your jurisdiction on the Countries pages for pricing and local details. When you are ready to move from registration to operations, add the Build and Run packages.