CRS 2.0: From 1 July 2026, information exchange will cover electronic money, digital currencies and virtual assets

Why CRS 2.0 was introduced

The original version of the CRS primarily covered bank accounts, deposit accounts and investment accounts.

However, in recent years, a significant share of financial transactions has shifted to:

• electronic wallets;
• electronic money accounts;
• digital payment services;
• fintech platforms;
• new types of digital financial assets.

These instruments have made it possible to conduct international transactions without relying on traditional bank accounts, creating challenges for effective international tax control. This is why the CRS standard was revised and its scope significantly expanded.

What is now covered by CRS 2.0

Electronic money

Electronic money, or another product, falls within the scope of CRS 2.0 if it meets all of the following criteria:

• it is a digital representation of a single fiat currency;
• it is issued by the issuer in an amount not exceeding the funds received from the user for the purpose of carrying out payment transactions;
• it constitutes a monetary obligation of the issuer denominated in the same fiat currency;
• it is accepted as a means of payment by persons other than the issuer;
• the issuer undertakes to redeem the electronic money or product at the user’s request at its nominal value and in the same fiat currency.

Central bank digital currency

A central bank digital currency is any digital form of fiat currency issued by the National Bank of Ukraine or another central bank.

Virtual assets

A virtual asset is a digital representation of value whose existence and transferability are ensured through cryptographically secured distributed ledger technology or similar technology used to verify and secure transactions.

Case law

Despite the relatively recent introduction of the CRS mechanism in Ukraine, administrative courts have already begun developing their first legal approaches in disputes between taxpayers and tax authorities.

The main reasons for litigation include differing interpretations of information obtained through the automatic exchange of information, as well as procedural violations during the initiation and conduct of tax audits.

An analysis of the available case law indicates that there is currently no uniform approach. Two illustrative court decisions demonstrate the criteria courts may apply when deciding in favour of either the taxpayer or the tax authority.

Taxpayer’s victory (Case No. 160/2695/26): the courts found that the audit report contained no references to primary documents that could establish the volume of business transactions, the dates on which they were carried out or the substance of those transactions. The court of first instance therefore reasonably established that the supervisory authority had violated the requirements of Procedure No. 727 and Methodology No. 244.

Tax authority’s victory (Case No. 420/19574/25): the courts concluded that the claimant had received income originating from outside Ukraine but had failed to declare that income or pay the mandatory taxes and charges. Therefore, there were no grounds for cancelling the contested tax assessment notices.

Conclusions

The introduction of CRS 2.0 is a logical step in the development of the international system of tax transparency.

While automatic exchange of information previously focused primarily on traditional bank accounts, from 1 July 2026 its scope has expanded to include electronic money, central bank digital currencies and virtual assets.

For financial institutions, this means broader obligations regarding customer identification and reporting. For users of electronic payment services, it means a higher level of international tax transparency.

The overall trend is clear: regardless of the form in which funds are held — whether in a bank account, an electronic wallet or another digital financial instrument — the opportunities to conceal assets from tax authorities in different countries are gradually narrowing.