LUXEMBOURG LEGAL UPDATE
On 19 March 2026, the Luxembourg Parliament approved Bill 8592. The resulting Law of 27 March 2026 transposes Council Directive (EU) 2023/2226 (DAC8) and amends, among other legislation, the Luxembourg law of 18 December 2015 on the Common Reporting Standard (NCD/CRS). The new provisions apply from 1 January 2026. For Reporting Crypto-Asset Service Providers, the first Luxembourg filing will cover calendar year 2026 and is due by 30 June 2027.

The international tax transparency framework continues to evolve. In Luxembourg, the implementation of DAC8 gives domestic effect to the amended Common Reporting Standard (commonly referred to as “CRS 2.0”) and introduces a dedicated reporting framework for certain crypto-asset activities.

For Luxembourg Financial Institutions – including investment funds, Investment Entities, banks, certain insurance businesses and other structures within the CRS perimeter – the changes are particularly relevant when reviewing existing FATCA and CRS compliance frameworks, investor documentation and reporting systems.

What is changing under CRS 2.0 in Luxembourg?

More detailed CRS reporting

The revised Luxembourg CRS framework requires Reporting Financial Institutions to capture and report more granular information for reportable accounts. For reporting periods beginning on or after 1 January 2026, the additional information includes, among other items:

• whether a valid self-certification has been obtained for the Account Holder;
• where a reportable person is a Controlling Person, the capacity or role through which the person exercises control and whether a valid self-certification is available for that Controlling Person;
• whether the account is a Preexisting Account or a New Account;
• whether the account is jointly held and, where applicable, the number of joint Account Holders; and
• for participation interests in certain legal arrangements that are Investment Entities, the role through which the reportable person holds the participation interest.

Expanded scope for certain digital financial products

CRS 2.0 also updates the scope of the CRS to reflect developments in financial markets. In particular, the revised rules bring certain electronic money products and central bank digital currencies within the CRS framework and ensure that certain indirect investments in crypto-assets through derivatives and investment vehicles are captured.

Enhanced due diligence and data quality

The changes reinforce the importance of robust due diligence. Financial Institutions should be able to demonstrate that self-certifications are complete, valid and reasonable when compared with the information available in their records, and that changes in circumstances are identified and followed up.

Particular attention should be given to tax residence, Tax Identification Numbers (TINs), the FATCA/CRS status of investors and Account Holders and, where relevant, the identification and documentation of Controlling Persons.

Review of existing investor and Account Holder documentation

For investment funds and other Investment Entities, the Luxembourg changes make the quality of the existing investor population increasingly important. A gap analysis should consider whether:

• valid FATCA/CRS self-certifications are available for all relevant Account Holders;
• tax residences and TINs have been properly collected and remain consistent with the information on file;
• entity classifications remain appropriate and are supported by the relevant documentation;
• Controlling Persons of Passive NFEs have been correctly identified, classified and documented;
• changes in ownership, tax residence or other investor circumstances have been reflected in the due diligence records;
• the capacity or role of reportable Controlling Persons and holders of participation interests can be captured for CRS reporting; and
• the information available is sufficient to populate the additional CRS data fields required for FY2026 reporting.

What about crypto-assets?

Digital assets form part of the broader evolution of the international tax transparency framework, but it is important to distinguish CRS 2.0 from the dedicated DAC8 crypto-asset reporting regime.

Under CRS 2.0, certain electronic money products, central bank digital currencies and certain indirect investments in crypto-assets are brought within or clarified under the CRS perimeter.

In parallel, the Luxembourg Law of 27 March 2026 introduces specific due diligence and annual reporting obligations for Reporting Crypto-Asset Service Providers. These operators must identify reportable crypto-asset users and report relevant transactions to the Luxembourg tax administration (Administration des contributions directes – ACD). The first reporting will relate to calendar year 2026 and must be filed by 30 June 2027.

Important distinction
DAC8 does not automatically create crypto-asset transaction reporting obligations for every Luxembourg Financial Institution or investment fund. The reporting obligation depends on whether the relevant entity or service provider falls within the definition of a Reporting Crypto-Asset Service Provider. Funds and investment structures should nevertheless assess whether their own activities, investments or service arrangements bring any part of the structure within the expanded rules.

What should Luxembourg Financial Institutions do now?

Financial Institutions should review their FATCA and CRS compliance framework now, because the enhanced data requirements apply to information relating to 2026. Key areas of focus include:

• FATCA and CRS entity classification;
• investor and Account Holder due diligence;
• validity, reasonableness and completeness of self-certifications;
• identification and documentation of Controlling Persons and beneficial ownership information;
• tax residence and TIN information;
• monitoring and remediation of changes in circumstances;
• completeness and consistency of investor data across AML/KYC, FATCA and CRS records;
• capture of the new CRS 2.0 reporting fields; and
• readiness of CRS reporting templates, XML processes and internal systems for the FY2026 reporting cycle.

Although the legislative amendments primarily change the CRS and DAC8 frameworks, the implementation project is also an opportunity to review the overall consistency and quality of FATCA and CRS documentation, controls and reporting processes.

How can Value Partners assist?

Value Partners Value Partners supports Luxembourg Financial Institutions throughout the FATCA and CRS compliance cycle.

In addition to its existing services covering FATCA and CRS classification, IRS registration, and annual FATCA and CRS reporting and filing, Value Partners can also support Financial Institutions with ongoing FATCA and CRS due diligence throughout the year.

Our ongoing due diligence support can include:

• review of investor and Account Holder documentation;
• review of FATCA/CRS self-certifications and assessment of their completeness and consistency with the information available;
• identification and documentation of Controlling Persons, where applicable;
• review of tax residence and Tax Identification Number (TIN) information;
• identification and follow-up of missing, incomplete or inconsistent documentation;
• monitoring and remediation of changes in circumstances;
• periodic review of the investor and Account Holder population;
• follow-up and remediation of FATCA/CRS documentation gaps; and
• preparation and review of the investor population ahead of the annual FATCA and CRS reporting cycle.

This ongoing approach allows Financial Institutions to identify and address documentation or data gaps throughout the year, rather than only at the time of the annual reporting exercise.

With the enhanced CRS requirements applying to information relating to 2026, maintaining complete, accurate and up-to-date investor and Account Holder information becomes increasingly important. By combining ongoing due diligence with its existing classification, registration, reporting and filing services, Value Partners can support Financial Institutions throughout the entire FATCA and CRS compliance process.

Any questions on CRS 2.0 in Luxembourg? Contact Marco Scappaticci, FATCA/CRS expert at Value Partners.