New CRS/DAC2 guidance: file 2026 data by 31 January 2027

Finnish reporting financial institutions face a rewritten CRS/DAC2 rulebook for the 2026 reporting year.Vero Skatteförvaltningen has replaced its 2024 guidance on DAC2 and sections 17 b–d of the act on assessment procedure (VH/4324/00.01.00/2024)Vero with comprehensive guidance applying the new act on the disclosure duty of reporting financial institutions (1042/2025)Vero, in force since 1 January 2026Finlex. Data for calendar year 2026 must be filed by 31 January 2027.Vero

The new act carries the DAC2 duties into a standalone statute and adds the DAC8-driven updates to the directive, the matching Common Reporting Standard updates, and national clarifications on estate accounts, the procedure for new accounts where no self-certification arrives in time, and the filing deadline itself. The guidance stresses that the material changes to earlier law are small and mostly clarifying: no major expansion of duties, but several new reportable items and tighter definitions. The statute also aligns the implementation technique with DAC6, DAC7 and DAC8: sections 17 b and d were repealed and section 17 c amended.

The duty covers depositaries, deposit institutions, investment entities and specified insurers resident in Finland, plus Finnish branches of foreign financial institutions. Each entity must test itself against the definitions, run due diligence on residence and reportable-person status, and file annually, including nil returns. Records must be kept for the statutory period, and avoidance arrangements are prohibited.

Three definition changes widen the net. The act adds electronic money, central-bank digital currencies and reportable crypto-assets: a deposit institution now includes entities holding clients' electronic money or CBDC, and investment-entity activity and gross-income tests count investment in and administration of reportable crypto-assets. Indirect crypto exposure through funds or derivatives whose underlying is a crypto-asset falls inside the act, while direct crypto investment stays under the separate act on crypto-asset service providers. A holder of an equity interest in a collective investment vehicle now counts as a customer, so funds managed by their own staff meet the investment-entity definition.

Estate accounts get their own regime: the act defines a specific estate account, held solely by a deceased person's estate with documentation of death, and a reportable estate account is now reported as a joint account — previously such accounts were reported as entity accounts. The pre-existing-account definition extends to accounts administered at 31 December 2025 holding only electronic money or CBDC, and to accounts of entities that only became reporting institutions through the new act.

The filing itself carries new flags. Institutions must report for each account whether it is a joint account including the number of holders, the account type and whether it is pre-existing or new, the role basis for each controlling person treated as reportable, and — for equity interests managed in an investment entity that is a legal arrangement — the information identifying the holder. Every account must state whether reporting rests on a valid self-certification from the holder. No new account may be opened without a reliable customer self-certification, verified against account-opening and anti-money-laundering information; where the business line makes prior certification impossible, the account must be closed without undue delay if no certification arrives in time. US-linked financial-account exchange continues under the Finland–US FATCA agreement (FördrS 25/2015) with its own guidance.

Legal basis: Lag om skyldighet för rapporteringsskyldiga finansiella institut att lämna upplysningar i fråga om beskattning (1042/2025), BFL 17 c § and 28 a §, applying Council Directive (EU) 2025/872 to the extent in force as law in Finland.