EU updates automatic exchange of information protocols with Monaco and others

In 2015 and 2016 the EU entered into protocols with Andorra, Liechtenstein, Monaco, San Marino and Switzerland to provide for the automatic exchange of information in accordance with the Common Reporting Standard (CRS).

Amendments to the protocols were adopted by the EU Commission on 10 October 2025 and come into force on 1 January 2026. The amendments are to ensure alignment with the updated CRS which itself comes into force in 2026. Some of the key changes to CRS include, in brief:

  • The inclusion of new financial products, such as e-money and central bank digital currencies.

  • Widening of the definition of an Investment Entity to include entities investing in crypto-assets.

  • Enhanced reporting requirements for Financial Institutions to include matters such as self-certification, identification of controlling persons and number of account holders liked to accounts.

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