FinlandVero
CRS/DAC2 cutover: old schema until 30 Oct 2026, test environment opens 3 Nov
Old-schema CRS/DAC2 reports only until 30 Oct 2026; Ilmoitin.fi test environment opens 3 Nov 2026, new schema mandatory 1 Jan 2027, and the replacement annual report ends with the 2026 reports.
By Taxxa AI OyPublished 30 September 2026
Finnish financial institutions filing FATCA, CRS and DAC2 annual reports face a hard cutover: CRS/DAC2 reports on the current (old) schema can be filed only until 30 October 2026Vero, after which the Ilmoitin.fi service is temporarily unavailable for CRS/DAC2 annual reports
Vero. A new schema applies from 1 January 2027, including corrections and reports for earlier years
Vero, and the replacement annual report (korvaava vuosi-ilmoitus) is abolished for both CRS/DAC2 and FATCA from the 2026 reports onwards
Vero.
Vero has published a new CRS/DAC2 technical application guide (tekninen soveltamisohje) taking effect on 1 January 2027Vero, reflecting the new CRS schema. The structures, elements and Ilmoitin checks under that guide are live in the Ilmoitin.fi test environment, with submission, from 3 November 2026
Vero, and in production from 1 January 2027
Vero. The schema change affects reports for 2026 onwards: during calendar year 2026 CRS/DAC2 reports are still filed on the old schema
Vero, and from 1 January 2027 everything, including corrections for earlier years, uses the new schema
Vero. Financial institutions should therefore plan filing and correction traffic around the service pause after 30 October 2026 and validate their files in the test environment from 3 November. The most material element changes concern Self-Certification, AccountTreatment and AccountType, including a new report on whether the institution holds an explicitly valid self-certification, and reporting of a decedent's estate moving from entity account to joint account.
The correction procedure changes with the schema: the replacement annual report is no longer usedVero, and errors are corrected under the correction procedure defined by the OECD and the IRS
Vero. A separate CRS/DAC2 act (1042/2025) entered into force at the start of 2026
Vero, with an updated in-depth CRS/DAC2 guide still to come.
Separately, Vero holds its annual FATCA, CRS and DAC2 information session on 4 November 2026Vero, with a pre-event survey open until 18 October 2026
Vero.
Legal basis: CRS/DAC2 act (1042/2025); new CRS/DAC2 technical application guide effective 1 January 2027; OECD/IRS correction procedure for errors from the 2026 reports.
File any remaining old-schema CRS/DAC2 reports before 30 October 2026, validate new-schema files in the Ilmoitin.fi test environment from 3 November, and switch corrections to the OECD/IRS procedure instead of the replacement annual report.