The Central Bank of Bahrain (CBB) has amended Directive OG/33/2026 on the automatic exchange of information (AEOI) for tax purposes, requiring all reportable financial institutions (RFIs) to implement the updated OECD common reporting standard (CRS v2.0). RFIs regulated by the CBB were required to adopt these changes by 1 January 2026, with the first reports due in 2027. The updates expand the scope of the CRS to include digital assets, strengthen due diligence and introduce new reporting fields.

Key amendments:

Financial assets

The definition of financial assets has been broadened to include specified electronic money products (e-money), central bank digital currencies (CBDCs), crypto-assets derivatives and other crypto-assets in line with the crypto-asset reporting framework (CARF). All crypto-asset service providers in Bahrain – primarily regulated through Volume 6 – fall within the scope of this expanded framework.

Strengthened due diligence

RFIs now face additional due diligence requirements and greater scrutiny of self-certifications by customers and controllers. Declaration forms may need to be updated to elicit new information. Multi-resident/multi-account holders should be treated as tax resident in all identified jurisdictions and all tax residences must be self-certified. With account holders or controlling persons being urged to provide documentation to prove tax residency under residence-by-investment (RBI) and citizenship-by-investment (CBI) schemes, the OECD has begun publishing information on CBI/RBI schemes on its website. RFIs can also use government verification services (GVSes) to ascertain identity and tax residence.

For new entity accounts, RFIs must follow AML/KYC procedures set out in the 2012 FATF recommendations.

Exclusions

• Genuine non-profit entities can now be categorised as non-reporting financial institutions where they meet specific conditions and have been adequately verified by a jurisdiction’s tax authority.
• Capital contribution accounts used for company incorporation or a pending capital increase can be excluded for a maximum period of 12 months, provided adequate safeguards are in place to prevent misuse.

Reporting requirements

The OECD released a new CRS XML schema (v4.0) in October 2024 with additional data fields to support the implementation of CRS 2.0. RFIs must now collect and report:

• The role of the controlling person in relation to the entity account/interest holders in an investment entity
• Whether an account is new or pre-existing
• Whether valid self-certifications have been obtained from the account holder
• Whether an account is a joint account and – if it is – the number of account holders
• The type of financial account, such as depository/custodial, equity/debt/interest or cash value insurance contract

How can Keypoint help?

To ensure compliance with CRS v2.0, CBB-regulated RFIs may be required to analyse gaps, update onboarding processes and train staff. With our dedicated CRS team already supporting RFIs across Bahrain, we can:

• Help RFIs assess CRS v2.0’s impact
• Advise on how to update self-certification forms
• Support updates to CRS procedures
• Review/update data from reportable account holders

By combining regulatory expertise, technical support and practical implementation guidance, our CRS v2.0 team helps compliance functions adapt seamlessly to the evolving CRS framework while minimising risk and supporting compliance.