At a glance. CRS 2.0 is the upgraded version of the OECD’s Common Reporting Standard, the global system for the automatic exchange of financial account information. It took effect on 1 January 2026, with the first reports due in 2027. It does not raise anyone’s tax rate. Instead, it widens what is reported and tightens how it is checked. It now reaches e-money and central bank digital currencies (CBDCs), while its sister framework, CARF, captures crypto-assets. In Portugal, both arrive through Law 26/2026. The rate stays the same. The visibility does not.
Quick read: The OECD adopted the CRS 2.0 amendments and the Crypto-Asset Reporting Framework (CARF) in November 2023. In the EU, they are implemented through DAC8 — Directive (EU) 2023/2226. Portugal transposed that directive with Lei n.º 26/2026, de 3 de junho. First reporting under CRS 2.0 covers 2026 data and is exchanged in 2027.
What CRS 2.0 actually is
The Common Reporting Standard is the OECD’s framework for the automatic exchange of financial account information. Under it, banks and other financial institutions report account-holder data to their tax authority. That authority then shares it with the tax authorities of other participating countries.
CRS 2.0 is the first major overhaul of that standard. The OECD adopted it in November 2023, and it applies from 1 January 2026. It is not a new tax. It is a transparency upgrade. In short, it modernises the rules so that newer financial products no longer fall outside the net.
Why the OECD upgraded the CRS
The original CRS dates from 2014. Since then, the way people hold and move money has changed. Digital wallets, e-money and crypto-assets did not fit neatly into the old definitions. As a result, gaps appeared.
Therefore, the OECD acted on two fronts at once. It revised the CRS to capture certain digital money, and it built a separate framework, CARF, for crypto-assets. Together, they close the gaps. The aim is simple: bring the digital economy inside the same reporting perimeter as traditional bank accounts.
What is now in scope: e-money and CBDCs
The headline change in CRS 2.0 is the wider scope. The definitions of financial accounts and reporting institutions now stretch to cover digital money.
Specifically, the standard now reaches specified electronic money (e-money) products and central bank digital currencies (CBDCs). In practice, the definition of a depository account is widened to include these instruments. So a balance held in a qualifying e-money product can now be reportable, much like a bank balance.
That is a meaningful shift. Products that many users treated as informal or invisible are now part of the same automatic-exchange system.
CRS 2.0 versus CARF: who reports what
It helps to keep the two frameworks apart. They are designed to dovetail, not overlap.
CARF covers crypto-assets. That includes cryptocurrencies, stablecoins, and certain non-fungible tokens (NFTs). Crypto-asset service providers report user and transaction data under it. CRS 2.0, by contrast, covers the more “bank-like” digital money — specified e-money and CBDCs — alongside traditional accounts.
In other words, crypto goes through CARF, while e-money and CBDCs go through CRS 2.0. Between them, very little digital value is left unreported.
More granular data and tighter due diligence
The upgrade is not only about scope. It also deepens the detail.
Under CRS 2.0, financial institutions must report more granular information. That includes the role of controlling persons, joint-account details, whether an account is new or pre-existing, and the type of account held. Due-diligence procedures are also tightened, and a new list of excluded and non-reporting categories is introduced.
Finally, the OECD updated the technical XML schema used to exchange the data. The effect is cleaner, more interoperable reporting between tax authorities. For account holders, the practical message is that the data trail is richer and easier to match.
How CRS 2.0 reaches Portugal: DAC8 and Law 26/2026
CRS 2.0 and CARF do not apply in Portugal on their own. They arrive through EU law.
The EU vehicle is DAC8, formally Directive (EU) 2023/2226. It brings both CARF and the CRS amendments into the automatic-exchange machinery of the Member States. Portugal transposed it through Lei n.º 26/2026, de 3 de junho, which we cover in detail in our guide to Portugal crypto tax reporting under Law 26/2026.
That law is, above all, a transparency and reporting instrument. It does not change IRS or IRC rates. It overhauls what must be reported to the Autoridade Tributária e Aduaneira (AT – the Portuguese Tax and Customs Authority), and from how many directions.
What this means if you live in Portugal
For individuals, the change is about visibility, not rates. If you are tax resident in Portugal and hold crypto, e-money or similar products, the AT will increasingly receive data about them automatically.
So the right response is alignment, not alarm. Make sure your IRS declarations match the data that platforms and institutions will report. Where past years were filed loosely, review them before the information catches up. For how the gains themselves are taxed, see our guide to Portugal crypto tax in 2026.
What this means for companies and platforms
For businesses, the impact lands on two groups. The first is reporting institutions (banks, e-money issuers, and similar providers) that must now apply the wider CRS 2.0 scope and the richer data fields. The second is crypto-asset service providers, which fall under the CARF side of Law 26/2026 and must report user and transaction data each year.
In both cases, the compliance burden rises. Due diligence must be tighter, data must be more complete, and deadlines must be met. The penalties for getting it wrong have also increased under the revised regime.
What you should do now
The action list is short. Identify which of your accounts, wallets or products now fall within CRS 2.0 or CARF. Check that your Portuguese tax filings reflect the same reality those systems will report. If you operate a reporting institution or a crypto platform, map your new obligations and deadlines before the first exchange.
In both cases, the system rewards consistency and punishes drift. Our tax compliance and accounting team helps clients line up their filings with the new standard.
How MCS can help
MCS – Madeira Corporate Services is a corporate services and accounting firm based in Funchal, Madeira. We help individuals bring their personal income tax declarations into line with the new transparency standard. We work in English and Portuguese, and we deal with the AT every day.
FAQ
What is CRS 2.0? CRS 2.0 is the upgraded OECD Common Reporting Standard for the automatic exchange of financial account information. It applies from 1 January 2026 and widens the scope of reporting to include specified e-money and central bank digital currencies, alongside tighter due diligence and more detailed data.
When does CRS 2.0 take effect? It applies from 1 January 2026. The first reports, covering 2026 data, are exchanged between tax authorities during 2027.
What is the difference between CRS 2.0 and CARF? CARF covers crypto-assets, such as cryptocurrencies, stablecoins and certain NFTs. CRS 2.0 covers more bank-like digital money, specified e-money and CBDCs, together with traditional financial accounts. They are designed to work together.
How does CRS 2.0 apply in Portugal? Through EU law. DAC8 (Directive (EU) 2023/2226) brings CRS 2.0 and CARF into the Member States, and Portugal transposed it with Lei n.º 26/2026, de 3 de junho. It is a reporting law and does not change IRS or IRC rates.
Does CRS 2.0 increase my taxes? No. CRS 2.0 does not change tax rates or how income is calculated. It increases the information that tax authorities receive automatically, which makes undeclared income far easier to detect.
This article was prepared by MCS – Madeira Corporate Services for general information purposes only. It describes the OECD Common Reporting Standard amendments (CRS 2.0), the Crypto-Asset Reporting Framework (CARF) and their implementation in Portugal through DAC8 (Directive (EU) 2023/2226) and Lei n.º 26/2026, de 3 de junho, as in force at the date of publication (8 June 2026). These frameworks, their scope, the related due-diligence and reporting obligations, and the implementing legislation and administrative guidance are subject to change, and may be amended, supplemented or reinterpreted after that date.
Nothing in this article constitutes legal, tax, accounting or financial advice, nor an offer to provide such services, and it should not be relied upon as a substitute for professional advice on your specific circumstances. Whether a particular account, wallet, product or institution falls within CRS 2.0 or CARF, and the precise obligations that follow, depend on the facts of each case, and outcomes may differ accordingly. Reading this article does not create any client, advisory or other professional relationship between you and MCS.
The references to OECD frameworks, EU directives and Portuguese legislation are provided for general guidance only; the official published texts prevail. To the fullest extent permitted by law, MCS accepts no liability for any loss arising from action taken, or not taken, in reliance on this article.
Before filing, reporting, or making or amending any arrangement, you should obtain advice tailored to your situation. Please book a consultation with our team.
Miguel Pinto-Correia holds a Master Degree in International Economics and European Studies from ISEG – Lisbon School of Economics & Management and a Bachelor Degree in Economics from Nova School of Business and Economics. He is a permanent member of the Order of the Economists (Ordem dos Economistas)… Read more
