On June 2, 2026, the Directorate General of Taxation published Resolution MH-DGT-RES-0021-2026, defining the objective selection criteria and the risk criteria it will apply during 2026 to carry out its supervision, verification and monitoring of reporting under the Common Reporting Standard (CRS). The resolution will be updated annually and is grounded in Article 106 quáter of the Code of Tax Rules and Procedures and in the OECD Convention on Mutual Administrative Assistance in Tax Matters.
The resolution does not create or modify any procedures for taxpayers; it is an internal operational measure that guides the Tax Authority’s control activities. Through it, the Administration may select reporting entities based on at least one of fourteen objective criteria, the most notable of which include: being within the 20% of entities with the highest number of reported accounts or reporting to the greatest number of jurisdictions; failing to file the CRS report or the nil return (Nil Report); reducing the number of reported accounts by 20% or more; an increase in undocumented accounts; or having been sanctioned in the previous supervision period.
The scope of the audits is broad. In addition to entities regulated by SUGEF, SUGEVAL, SUGESE and SUPEN or affiliated with INFOCOOP, the resolution expressly covers foundations, civil associations, solidarista associations, cooperatives and trusts —regardless of their nature— as well as the Designated Non-Financial Businesses and Professions (DNFBPs) provided for in Law No. 7786. Integral and community development associations registered with DINADECO, and the water and sewerage management associations (ASADAS) registered with the ICAA, are excluded.
With respect to the risk criteria, the Tax Authority will assess, among others, failure to submit information by the established deadline, the provision of erroneous or incomplete information, the omission or incorrect application of due diligence procedures and of the CRS standard, shortcomings in obtaining self-certifications, failure to retain supporting records for five years, and information from third parties suggesting a possible breach.
We recommend that reporting financial and non-financial entities review their internal due diligence processes, validate the quality and consistency of the information reported, and retain supporting documentation, in order to manage their exposure to control activities in a timely manner. ICS continues to monitor the implementation of these criteria and supports entities in meeting their CRS reporting obligations.