CRS, FATCA and CARF for UAE family offices: what gets reported and who reports it

Under the Common Reporting Standard (CRS) and FATCA, UAE financial institutions report accounts held by non-residents and US persons to the UAE Ministry of Finance, which exchanges the information with other tax authorities. A family office, foundation or investment holding company can itself be a reporting financial institution if it is professionally managed and earns mainly investment income. If so, it must register, collect self-certifications and report. From 1 January 2027 the UAE will apply the updated CRS (CRS 2.0) and expects to apply the Crypto-Asset Reporting Framework (CARF), with first exchanges in 2028.

Families often assume CRS and FATCA reporting is the bank’s job. Banks do report the accounts they hold for reportable account holders, including family companies and trusts and, where an entity is passive, the people who control it. But a family trust or holding company whose investments are professionally managed can be a Financial Institution in its own right, with its own reporting duties. For each family entity, the answer depends on how it is classified.

How do CRS and FATCA work in the UAE?

The UAE implemented CRS from 1 January 2017. It signed the Multilateral Competent Authority Agreement in February 2017 and the OECD Convention on Mutual Administrative Assistance in April 2017 (OECD MCAA signatories; OECD MAC status). FATCA operates under a Model 1B intergovernmental agreement with the United States. The UAE agreed the IGA in substance in June 2014, so its account rules run from 1 July 2014, although the text was formally signed on 17 June 2015 and entered into force on 19 February 2016 (US Treasury, FATCA; UAE IGA). UAE reporting financial institutions register on the Ministry of Finance’s CRS and FATCA portal, carry out due diligence on account holders and report annually. The ministry then exchanges the data with partner jurisdictions under CRS and with the US Internal Revenue Service under FATCA (Ministry of Finance).

For a family that has moved to Dubai, this means accounts held in the UAE are reported to the country where each account holder is resident for tax purposes, based on their self-certification. A family member who certifies UAE residence is not reported to their former country. The bank will ask for evidence, though, and can challenge a certification that conflicts with its records. Our guide to UAE tax residency for relocating families covers how residence is established.

Is a family office or foundation a reporting financial institution?

The CRS classifies every entity as either a financial institution or a non-financial entity (NFE). For family structures, the deciding category is usually the “investment entity”.

An entity is an investment entity if its gross income is primarily attributable to investing, reinvesting or trading in financial assets and it is managed by another financial institution (OECD CRS, s. VIII(A)(6)(b)). The Ministry of Finance’s flowchart for identifying CRS reporting financial institutions (2022) uses a threshold of 50% or more of gross income for this test (Ministry of Finance flowchart). An entity whose business is managing financial assets for customers is also an investment entity in its own right.

In practice:

• A family holding company or foundation whose portfolio is run on a discretionary basis by a bank or regulated manager is often an investment entity, and therefore a financial institution with its own reporting obligations (OECD CRS Commentary on s. VIII, para 17).
• The same entity, managed by family members without a professional discretionary manager, is often a passive NFE. It doesn’t report, but the banks where it holds accounts must identify and report its controlling persons.
• A single family office company that provides services but doesn’t hold financial assets for others is usually an active or passive NFE, depending on its income.

For a trust that is a reporting financial institution, the CRS reports each settlor, protector and beneficiary (including anyone who may receive a discretionary distribution) as an account holder, together with amounts paid or credited to them in the year (OECD CRS, s. VIII(C)(4) and s. I(A)(7)). A foundation that is a reporting financial institution should expect its founder and beneficiaries to be treated in a similar way, so check how each one is reported. Families sometimes discover that a UAE foundation set up for privacy is reporting their details to their former country.

The flowchart also notes that an entity without a UAE commercial licence or other UAE registration is not required to report in the UAE. It may still have obligations in another country.

What changes with CRS 2.0 from 2027?

On 8 November 2025 the Ministry of Finance announced that the UAE will implement the OECD’s amendments to the CRS, known as CRS 2.0, from 1 January 2027, with the first exchanges in 2028 (Ministry of Finance). The update extends the scope to electronic money products and central bank digital currencies, covers certain crypto-asset investments, and adds reporting and due diligence requirements. On 2 September 2026 the UAE Cabinet approved ratification of a multilateral competent authority agreement on the automatic exchange of information (WAM, 2 September 2026). It has been reported as the addendum to the CRS competent authority agreement that supports CRS 2.0 (Bloomberg Tax, 15 September 2026), and the UAE signed that addendum on 11 August 2025 (OECD addendum signatories).

For families, this means more data fields and closer scrutiny of self-certifications. Some entities previously outside scope, such as some holding vehicles for digital assets, may come within it.

What is CARF, and does it affect family offices?

The Crypto-Asset Reporting Framework is the OECD’s standard for exchanging information on crypto-asset transactions, which can take place outside the traditional banks that report under CRS. The UAE signed the CARF Multilateral Competent Authority Agreement on 21 July 2025, and ratified it by Federal Decree No. 60 of 2026 on 4 May 2026. The Ministry of Finance is targeting 1 January 2027 as the effective date of the implementing rules. The first annual CARF reports for 2027 are expected by 30 June 2028, ahead of the first exchange by 1 September 2028 (Ministry of Finance CARF Readiness Circular, October 2026; Ministry of Finance CARF page).

CARF obligations fall on reporting crypto-asset service providers, such as exchanges and brokers. A family office that only invests in crypto-assets for the family is unlikely to be one, but its transactions through exchanges will be reported. A family entity that provides exchange services to others should check its status.

What should a family office do now?

1. Classify every entity. List each company, foundation and trust, and record whether it is a financial institution or an NFE under CRS and FATCA, with the reasoning.
2. Check registrations. Any entity that is a UAE reporting financial institution must be registered on the Ministry of Finance portal and must file, including nil returns where required.
3. Review self-certifications. Make sure every family member’s and entity’s self-certification matches their actual residence and classification, and update them after a move.
4. Plan for 2027. Identify holdings of e-money and crypto-assets, and the providers through which they are held, ahead of CRS 2.0 and CARF.
5. Align with residence planning. Reporting follows certified residence. If the residence position is uncertain, resolve it before it appears in another country’s data.

The pillar guide explains who usually owns these records. Classification and residence sit with different advisers in most families: the bank collects the self-certification, the trustee runs the foundation and the accountant files in each country. A fractional head of tax is often the one person who checks that all of them describe the family the same way.

Within, by PBF, is fractional tax advisory: your tax team, within your business. A senior tax team works as part of your family office, alongside your accountants, trustees and banking contacts, and reviews residence declarations and cross-border reporting, including CRS and FATCA, so that those preparing the filings work from one view of your family’s affairs. See how Within works.