This final lesson examines how tax administrations ensure compliance with AEOI obligations, the enforcement mechanisms available, and the key developments on the horizon, including the amended CRS and CARF.

 

  • Legal Frameworks for AEOI: The AEOI Standard requires jurisdictions to put in place domestic legislation requiring Reporting Financial Institutions to conduct the detailed due diligence and reporting rules to ensure Financial Account information is reported . International exchange agreements must also be implemented, and technical and operational solutions delivered to exchange the information in practice .

  • Compliance by Financial Institutions: To ensure the effectiveness of the AEOI Standard in practice, tax administrations must develop and effectively implement administrative compliance frameworks to ensure compliance by Reporting Financial Institutions . The peer review process assesses the effectiveness of these frameworks. As of 2025, among 108 jurisdictions assessed, 63% are rated as “On Track” with their implementation .

  • The Second Round of Peer Reviews: The Global Forum has commenced a second round of peer reviews designed to obtain a deeper level of comfort that jurisdictions are implementing the AEOI Standard effectively . These include onsite visits by Assessment Teams of experts from AEOI jurisdictions, which meet all key stakeholders from the public and private sectors . The reports and results of the second round are due to be completed and published in 2026 .

  • The Amended CRS: With the AEOI Standard having been operationalised by a vast number of jurisdictions, the OECD worked with G20 countries to review its operation, leading to amendments to the Common Reporting Standard in 2023 . The G20 called on the Global Forum to ensure the widespread adoption of the amended CRS and to monitor its implementation .

  • The Future of EOI: The framework for automatic exchange continues to expand. The peer review of effectiveness in practice remains a key focus, with jurisdictions needing to continuously improve their administrative compliance frameworks . The integration of CARF and the amended CRS will extend transparency to crypto-assets and new financial products . International cooperation to provide tax authorities with transparency over their taxpayers’ financial activities abroad is now the established norm and has equipped jurisdictions with the necessary tools to ensure that their taxpayers meet their domestic tax obligations

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