Jun 29, 2026
By Gabriela Páez
CRS, or Common Reporting Standard, is an international standard promoted by the OECD for the automatic exchange of information on financial accounts. Its purpose is for tax administrations to receive relevant information on accounts linked to tax residents of other jurisdictions.
In Costa Rica, the General Directorate of Taxation issued Resolution MH-DGT-RES-0021-2026, which establishes the criteria it will use during 2026 to review CRS reporting compliance.
It is important to clarify that this obligation does not apply to every taxpayer. It applies to reporting entities under CRS regulations. These entities must submit the CRS report when they have reportable financial accounts, or the Report Without Financial Accounts, also known as a Nil Report, when there are no accounts to report.
The resolution does not create a new general form for all taxpayers, nor does it expressly indicate a specific format within TRIBU-CR. What it does establish are the criteria the Ministry of Finance may use to select entities and review whether they are properly complying with their CRS obligations.
Among the aspects that may draw the Ministry of Finance’s attention are:
Aspect reviewed | What it may indicate |
Failure to submit the CRS report or Nil Report | A possible formal noncompliance that may trigger reviews or requests. |
Reporting many accounts or jurisdictions | A higher volume of information and, therefore, greater exposure to errors or inconsistencies. |
Indicating that there are no reportable accounts | The need to validate that the analysis was performed correctly and that sufficient support exists. |
Increase in undocumented accounts | Possible weaknesses in due diligence and document update processes. |
Errors in data such as TIN or date of birth | Data quality issues that may affect the exchange of information with other jurisdictions. |
Inconsistencies reported by other jurisdictions | Risk of incomplete, incorrect, or misaligned information compared with prior records. |
Previous penalties or noncompliance | A higher risk profile before the Tax Administration. |
What should the reporting entity do?
The entity should review whether it is actually subject to CRS reporting, correctly identify reportable accounts, obtain and retain self-certifications, validate the data before reporting, and maintain sufficient supporting documentation.
It should also have internal due diligence procedures. This includes reviewing account holders’ tax residence, retaining supporting documentation, and comparing the information with reports from previous years to detect relevant changes.
The risk is not only failing to submit the report. Risk may also exist when incomplete, inconsistent, outdated, or insufficiently supported information is submitted.
For this reason, CRS should be viewed as an ongoing compliance process and not as an isolated annual task. Data review, file updates, and information traceability should be part of the entity’s internal controls.
Resolution MH-DGT-RES-0021-2026 confirms that the Ministry of Finance will monitor CRS reporting compliance during 2026. Reporting entities should review their internal processes, validate data quality, and retain the documentation supporting the information submitted.
Complying with CRS is not only about submitting a file. It means demonstrating control, traceability, and due diligence over the financial information communicated to the Tax Administration.
References
General Directorate of Taxation. Resolution MH-DGT-RES-0021-2026, Objective selection criteria and risk criteria for the execution of CRS report supervision, verification, and monitoring actions for 2026.
General Directorate of Taxation. Resolution MH-DGT-RES-0012-2025, General Resolution on Due Diligence for the provision of information by financial and non-financial entities for the automatic exchange of information on financial accounts: Common Reporting Standard.
Organisation for Economic Co-operation and Development. Common Reporting Standard.
Costa Rican Tax Code, article 106 quater.