Expanded Account Coverage: E-Money Must Be Reported under AEOI

The Directorate General of Taxes (DGT) has announced plans to update the regulation on the Automatic Exchange of Financial Account Information (AEOI) for tax purposes.

This update was conveyed by the DGT in Announcement Number PENG-3/PJ/2025, issued on 22 October 2025. The update includes an expansion of the types of accounts subject to exchange.

In the future, accounts subject to exchange will also include certain specified electronic money (E-Money) products as well as central bank digital currency (CBDC).

CRS Rules Revised

With this update, Minister of Finance Regulation (PMK) Number 70/PMK.03/2017, as last amended by PMK Number 47 of 2024, will be adjusted accordingly.

In addition to the expanded scope of reportable accounts, the changes will also address rules to prevent duplication between the AEOI Common Reporting Standard (CRS) and the Crypto-Asset Reporting Framework (CARF).

CRS is an internationally applicable standard for the exchange of financial account information, enabling jurisdictions to automatically share information on an annual basis.

Perfecting the Previous AEOI Provisions

The existence of this new regulation will also perfect several aspects of reporting, such as the strengthening of procedures for the identification of financial accounts, the addition of types of financial accounts that are excluded, as well as the addition of several information elements to be reported.

Some of the additional information includes:

• information on whether Financial Institutions, Other Financial Institutions, and Other Entities have received a valid self-certification from the financial account holder and controlling person,
• information regarding the role of the equity interest holder in an investment entity that is a non-legal entity (legal arrangement),
• information on the procedure for identifying a financial account as a Preexisting Financial Account or a New Financial Account,
• information on the type of financial account being reported (deposit account, custodial account, insurance contract, or equity or debt interest),
• information related to joint financial accounts and the number of financial account holders in such accounts.

Controlling Person Information

In addition, this new regulation will also require the submission of information regarding the role of the controlling person of an entity.

In the announcement, the DJP also stated that the AEOI CRS reporting format will be adjusted to accommodate the additional information based on the CRS amendments, according to the CRS XML: Guide for Tax Administrations format issued by the OECD. (ASP/KEN)