CRS 2.0 Is Already in Force: Tax Transparency Extends Beyond Bank Accounts

From 1 July 2026, Ukraine has applied updated rules for the international automatic exchange of financial account information — CRS 2.0. The changes were approved by Ministry of Finance Order No. 316 dated 15 June 2026.

It is important to understand that the very scope of international tax transparency is changing.

Previously, when business owners referred to CRS, they primarily thought about accounts held with foreign banks.

The regulatory framework is now expanding to reflect new digital financial instruments.

CRS 2.0 introduces concepts such as electronic money, virtual assets, central bank digital currencies, and virtual-asset service providers. It also strengthens requirements for identifying account holders and controlling persons.

This directly affects Ukrainians who hold foreign accounts, have international corporate structures, or use modern digital financial instruments.

At the same time, an important clarification is needed: CRS 2.0 does not mean that, from 1 July, the State Tax Service automatically received information about every crypto wallet held by Ukrainian residents.

The changes concern expanded due-diligence and reporting requirements for specified financial products, accounts, and institutions. The State Tax Service has established separate review and reporting deadlines for new categories of accounts, and some of this information will begin appearing in reports from 2027.

Nevertheless, the trend is clear: international tax transparency is gradually moving beyond the traditional bank account.

For business owners, the question is no longer simply where an account is held. The key issue is what information tax authorities may potentially receive about foreign financial assets and structures, and whether that information matches what has been declared in Ukraine.

This is especially relevant for owners of foreign companies, controlled foreign companies, overseas accounts, and significant digital assets.

This is therefore an appropriate time to conduct a tax review of foreign assets: compare the ownership structure, tax residence, CFC reporting, tax declarations, and documents confirming the source of funds.

International tax information exchange is becoming increasingly extensive. It is better to identify a potential issue independently before the State Tax Service identifies it.

Source: State Tax Service of Ukraine, CRS 2.0.

WINNER Law Firm provides advice on international taxation, controlled foreign companies, tax residency, automatic exchange of information, and the legal structuring of transactions involving digital assets.

Would you like to review your foreign assets and structures before the information reaches the tax authorities?

Phone: 096 574 81 02
Email: info@uk-winner.com

You can seek legal support now so that you do not later need to seek criminal-defense representation.

Author: Ihor Yasko, Managing Partner at WINNER Law Firm, PhD in Law.