CRS Nil Return Filings Now Required In Bermuda

The Government of Bermuda has amended the Bermuda Common Reporting Standard (CRS) Regulations to make nil return filings mandatory for Reporting Financial Institutions that maintained no Reportable Accounts during the applicable calendar year.

The amendment was made on 11 May 2018 by the Minister of Finance.

As a practical matter, a Reporting Financial Institution that only maintains accounts that are Excluded Accounts does not otherwise have any reporting obligations; however, it will now have the obligation to file a nil return in the absence of Reportable Accounts. Reporting Financial Institutions will need to ensure they have carried out the appropriate checks of client data in determining whether there is no data to report and whether a nil return filing is required.