Singapore VCC insights

CRS 2.0 Hong Kong vs Singapore: One Year Apart on Amended CRS, Side by Side on CARF

By VCC Editorial Team · Published 8 November 2026

Short answer: Both hubs start the Crypto-Asset Reporting Framework on 1 January 2027 and exchange from 2028. They split on the amended Common Reporting Standard: Singapore applies it from 1 January 2027 and exchanges in 2028, while Hong Kong applies it from 2028 and exchanges from 2029. A dual-hub family faces one year of mismatched data.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

CRS 2.0 Hong Kong moved a decisive step forward on 4 November 2026, when the Legislative Council (LegCo) passed the bill that brings the Organisation for Economic Co-operation and Development (OECD) Crypto-Asset Reporting Framework and the 2023 amendments to the Common Reporting Standard into the Inland Revenue Ordinance. Singapore made its equivalent regulations on 11 August 2026. The two hubs now share a CARF start date but not an amended CRS start date, and that gap is what matters for a family with a single family office (SFO) and fund in Singapore and a bank account, investment holding vehicle or trust in Hong Kong. All Hong Kong and Singapore sources cited were checked on 8 November 2026. For the Singapore rules alone, see our earlier analysis of CRS 2.0 Singapore and CARF from 1 January 2027, which this piece does not repeat.

Where does CRS 2.0 Hong Kong stand after the 4 November 2026 vote?

The bill has passed but, as at 8 November 2026, the Inland Revenue Department (IRD) still lists it as a bill rather than a numbered ordinance, so gazettal of the amending ordinance is the next step. The commencement dates the Government has announced are 1 January 2027 for CARF and 1 January 2028 for the amended CRS.

In its press release of 4 November 2026, the Government said that CARF will be implemented next year, with relevant service providers collecting the specified information “for the Inland Revenue Department (IRD) to exchange with partner jurisdictions starting from 2028”. It added that the amended CRS “will also take effect in 2028”, with exchanges under the new standard “starting from 2029”.

The IRD’s page on the amended CRS summarises the main changes to Part 8A of, and Schedules 17C and 17D to, the Inland Revenue Ordinance:

• New products in scope: central bank digital currencies, specified electronic money products, derivatives referencing relevant crypto-assets, and investment entities investing in relevant crypto-assets.
• New reporting fields: whether a valid self-certification was obtained, the role of each controlling person or equity interest holder, whether the account is pre-existing or new, joint account status and the number of joint holders, and the account type.
• Refined due diligence: standards for anti-money laundering and know-your-customer (AML/KYC) procedures on new entity accounts, capital contribution accounts added to excluded accounts, and self-certification of every jurisdiction of tax residence.
• No double reporting: where an institution is also a crypto-asset service provider, gross proceeds on relevant crypto-assets reported under CARF need not be reported again under the amended CRS, although it may elect to do so.

Separately, the Inland Revenue (Amendment) (Automatic Exchange of Information) Ordinance 2026, gazetted on 26 June 2026, comes into operation on 1 January 2027. It tightens administration of the existing CRS: mandatory registration on the automatic exchange of information (AEOI) Portal for every reporting financial institution, six-year record keeping that survives dissolution, penalties scaled to the number of accounts for some offences, and an administrative penalty as an alternative to prosecution.

How do the Singapore and Hong Kong timelines compare, milestone by milestone?

CARF runs on the same calendar in both hubs; the amended CRS runs a year earlier in Singapore.

Milestone	Singapore	Hong Kong
Original CRS exchanges began	September 2018	2018
Legal instrument for CARF and amended CRS	S 551/2026 and S 552/2026, made under section 105P of the Income Tax Act 1947 and published 11 August 2026	Inland Revenue (Amendment) (CARF and Amended CRS) Bill 2026, passed 4 November 2026; ordinance not yet listed by IRD at 8 November 2026
CARF data collection starts	1 January 2027	1 January 2027
CARF registration	By 31 March following the calendar year the obligation arises	By 31 January of the year after first meeting the nexus rules (as proposed in the bill)
First CARF exchange	From September 2028	From 2028
Amended CRS takes effect	1 January 2027	1 January 2028
First amended CRS exchange	2028	From 2029
CRS administration changes	Trustee duties for trusts, nil return for certain trusts, CRS XML Schema Version 3.0 from 1 January 2027	Mandatory registration, record keeping and penalties under the AEOI Ordinance 2026 from 1 January 2027

In Singapore, regulation 1(2) of S 552/2026 gives effect “from (and including) 1 January 2027”, and the IRAS CRS overview page states that Singapore “is expected to commence exchanges under the Amended CRS in 2028”. Regulation 1 of S 551/2026 states that the CARF Regulations “come into operation on 1 January 2027”.

Why does the one-year gap on the amended CRS matter for a dual-hub family?

For calendar year 2027, the same family will be reported on two different standards: amended CRS data from Singapore institutions and original CRS data from Hong Kong institutions. The richer Singapore data will reach partner tax authorities in 2028; the matching Hong Kong data follows in 2029.

Three practical effects follow:

• Onboarding forms diverge. A Singapore private bank or fund administrator will ask from 1 January 2027 for every tax residence and for each controlling person’s role. A Hong Kong institution may still use its existing forms until it prepares for 1 January 2028.
• Newly in-scope products start at different times. E-money balances, crypto-linked derivatives and investment entities investing in crypto-assets become reportable in Singapore for 2027 and in Hong Kong for 2028.
• Pre-existing account review runs on different clocks. Under S 552/2026, a Singapore reporting financial institution must review newly in-scope pre-existing individual accounts by 31 December 2027 (high value, over US$1,000,000) and 31 December 2028 (lower value), and newly in-scope pre-existing entity accounts above US$250,000 by 31 December 2028. The IRD pages we reviewed do not yet set out Hong Kong’s corresponding review dates.

Who reports what, and where, for a family booked in both hubs?

Reporting follows the institution, not the family: each reporting financial institution reports to its own tax authority, which then exchanges with the account holder’s or controlling person’s residence jurisdictions. A typical dual-hub structure therefore produces several parallel reports.

Booking	Who reports	To whom	Standard for calendar year 2027
Singapore variable capital company (VCC) managed by the SFO or a licensed manager	The VCC as a reporting Singaporean financial institution, usually through its administrator	IRAS	Amended CRS
VCC’s or SFO’s account at a Singapore bank	The bank	IRAS	Amended CRS
Family trust’s or holding company’s account with a Hong Kong private bank	The bank	IRD	Original CRS (amended CRS from 2028)
Hong Kong family investment holding vehicle (FIHV)	Depends on whether the vehicle is itself a reporting financial institution; otherwise its banks report it and, where passive, its controlling persons	IRD	Original CRS (amended CRS from 2028)
Crypto-assets held at a Singapore or Hong Kong exchange or custodian	The crypto-asset service provider	IRAS or IRD under the nexus rules	CARF in both hubs

An FIHV’s CRS status turns on the investment entity tests, not its profits tax treatment; our comparison of the Hong Kong FIHV with Singapore’s 13O and 13U schemes deals with the tax side. For a family running one office across both cities, the operational picture is in our note on Singapore and Hong Kong family office set-ups, and the bank-side documentation in private bank onboarding in Singapore and Hong Kong.

How are trusts treated as reporting financial institutions in each hub?

Both hubs put the trustee at the centre, differently. Singapore’s amended regulations make the trustee legally responsible for the trust’s obligations; Hong Kong’s 2026 ordinance allows a trust to be registered and reported under its trustee’s account.

In Singapore, S 552/2026 inserts new regulations 13(5A), 14(7A) and 16(7AA) into the 2016 CRS Regulations. Each provides that, where a reporting Singaporean financial institution is a trust, the registration, due diligence or return requirement “must be complied with by the trustee”. A new regulation 16A requires the trustee of a trust that is a non-reporting financial institution under sub-paragraph B(1)(e) of the CRS definition of that term, and that maintains no reportable account in a year, to file a return stating that fact by 31 May of the following year. Failure without reasonable excuse is an offence under section 105M(1) of the Income Tax Act 1947.

In Hong Kong, the IRD explains that, under the AEOI Ordinance 2026, a trust or a sub-fund registered under the account of its trustee or umbrella fund, whose CRS data (including nil reporting) is reported by that trustee or umbrella fund, need not register separately.

Singapore also adds a “Qualified Non-Profit Entity” category for financial institutions that are charities registered under section 7 of the Charities Act 1994, or exempt charities, and that hold the Comptroller’s written confirmation; family philanthropic vehicles should check whether it applies.

What happens to controlling persons and crypto-assets held indirectly?

Controlling-person roles are reported from 2027 data in Singapore and 2028 data in Hong Kong. Direct crypto dealings through a service provider fall under CARF in both hubs from 2027; exposure through a fund or holding vehicle follows each hub’s amended CRS date.

On roles, Singapore gives transitional relief. New regulation 16(7B) provides that, for reportable accounts maintained as of 31 December 2026, the new information under sub-paragraphs A(1)(b) and A(6)bis of Section I of the CRS (which include controlling-person and equity interest holder details) is required for calendar years 2027 and 2028 “only if it is available in the electronically searchable data maintained by the institution”. A Singapore bank that already holds a trust’s settlor, protector and beneficiary roles electronically should therefore be expected to report them from 2027 data.

On indirect crypto, the Hong Kong bill brings “investment entities investing in relevant crypto-assets” within the CRS. A Singapore VCC sub-fund that trades tokens through a crypto-asset service provider will be reported by that provider under CARF from 2027, while the VCC reports its own investors under the amended CRS from 2027. A Hong Kong holding company that does the same will see CARF reporting from 2027 but amended CRS treatment only from 2028. Where a Hong Kong institution is also a reporting crypto-asset service provider, gross proceeds already reported under CARF need not be reported again under the amended CRS.

Under the CARF rules described by the IRD, controlling persons of entity users are reportable, and service providers must obtain self-certifications from pre-existing users within 12 months of the rules taking effect. Expect exchanges in both cities to request entity and controlling-person self-certifications during 2027.

What should a family office booked in both hubs do before 1 January 2027?

Treat 1 January 2027 as the working deadline for the whole group, and use 2027 to bring Hong Kong documentation to the same standard.

1. Map every account, fund, trust and crypto-asset relationship by booking centre, with the reporting institution and authority.
2. Confirm whether each Singapore and Hong Kong trust is a reporting financial institution, and who as trustee will register, conduct due diligence and file for it.
3. For any unregistered Hong Kong reporting financial institution in the group, diarise the 31 March 2027 AEOI Portal deadline, or confirm it is registered and reported under its trustee’s or umbrella fund’s account.
4. Refresh self-certifications for principals, trustees, protectors and beneficiaries to the amended CRS standard now: every tax residence, each role held, and taxpayer identification numbers.
5. List direct and indirect crypto-asset exposure, and prepare entity and controlling-person self-certifications for exchanges and custodians in both cities.
6. Check that the VCC’s administrator will file in CRS XML Schema Version 3.0 from 1 January 2027, as IRAS requires.
7. Recheck planned changes of residence against the exchange years: 2028 for CARF in both hubs and Singapore amended CRS data, 2029 for Hong Kong amended CRS data.

Common errors in existing CRS returns, which become more costly in Hong Kong once some penalties scale with the number of accounts, are covered in our note on VCC FATCA and CRS reporting mistakes and rejection reasons. For the corporate secretarial side of a Singapore holding or SFO company, our sister firm Singapore Secretary Services maintains registers and statutory filings.

Frequently asked questions

Is CRS 2.0 Hong Kong already law?

LegCo passed the bill on 4 November 2026. As at 8 November 2026 the IRD’s legislation page still lists it as a bill, so the ordinance number and gazettal date should be confirmed once published. The Government’s stated start dates are 1 January 2027 for CARF and 1 January 2028 for the amended CRS.

Why is Hong Kong a year behind Singapore on the amended CRS?

Hong Kong applies the amended CRS from 1 January 2028, with exchanges from 2029. The official sources we reviewed state the dates without giving a reason.

Does a Hong Kong trust need its own CRS registration from 2027?

Not if it is registered under its trustee’s account and the trustee reports its CRS data, including nil returns, according to the IRD’s explanation of the AEOI Ordinance 2026. Otherwise every reporting financial institution must register, and existing unregistered ones have until 31 March 2027.

Will a Singapore family trust’s roles be reported for 2027?

For a new account opened from 1 January 2027, yes. For an account maintained as of 31 December 2026, the new role information is required for 2027 and 2028 only if it is held in the institution’s electronically searchable data.

Sources

• Hong Kong Government press release: passage of the Inland Revenue (Amendment) (CARF and Amended CRS) Bill 2026, 4 November 2026
• IRD: Inland Revenue (Amendment) (Crypto-Asset Reporting Framework and Amended Common Reporting Standard) Bill 2026
• IRD: Inland Revenue (Amendment) (Automatic Exchange of Information) Ordinance 2026
• Singapore Statutes Online: Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) (Amendment) Regulations 2026
• Singapore Statutes Online: Income Tax (International Tax Compliance Agreements) (Crypto-Asset Reporting Framework) Regulations 2026

Raffles Corporate Services helps families running offices, funds and trusts across Singapore and Hong Kong with VCC incorporation, family office set-up and ongoing compliance, working alongside their CRS reporting agents and tax advisers. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 8 November 2026. The Editorial Team, Variable Capital Companies Act.