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FinlandVero

CRS/DAC2 returns and corrections switch schema on 1 January 2027

Vero says the new CRS/DAC2 schema will also cover corrections for earlier years. The option to submit a replacement annual return ends for both CRS/DAC2 and FATCA.

By Taxxa AI OyPublished 12 August 2026

Tax

Industry: Financial and insurance activities

Finnish financial institutions must use the new CRS/DAC2 schema for annual returns submitted from 1 January 2027Vero Vero, according to Vero’s announcement. The change also covers corrections to returns for earlier years.Vero Reporting teams therefore need to prepare both their annual submission process and the process used to repair historical reports for the same technical transition.

Vero has published technical instructions marked as effective from 1 January 2027. The announcement separately states that the possibility of filing a replacement annual return will end for both CRS/DAC2 and FATCA. That wider change to the correction process should be distinguished from the new schema announced specifically for CRS/DAC2.Vero

The distinction matters when dealing with old reporting years. A correction submitted after the transition cannot be prepared simply by keeping the old CRS/DAC2 schema because the information concerns an earlier year.Vero Vero expressly includes earlier-year corrections in the new-schema requirement. Institutions should use the applicable technical instructions when selecting the correction method after replacement annual returns cease to be available.

Vero’s annual-reporting guidance says Finnish financial institutions submit the preceding calendar year’s FATCA and CRS/DAC2 information in XML format through Ilmoitin.fi by the end of January. Both reporting obligations require at least a nil return. An institution with no reportable customer accounts or related transactions must still identify itself and indicate that it is making a nil report.

The change should also be kept separate from Vero’s earlier instruction concerning corrections to 2025 reports. That notice told institutions to correct those reports by 31 July 2026 using replacement annual returns. It described the correction route before the January 2027 transition; it does not preserve that route after the announced change.

For reporting teams, the practical preparation is to test the new CRS/DAC2 format and revise correction procedures together, including the handling of prior-year records and the separate FATCA replacement-return change.

The reporting basis is Vero’s FATCA, CRS and DAC2 announcement and annual-reporting guidance, including the CRS/DAC2 technical instructions designated for use from 1 January 2027.

Prepare the new CRS/DAC2 schema for 1 January 2027, including prior-year corrections, and update FATCA and CRS/DAC2 replacement-return procedures.

Sources