ACD CRS: FAQ

Last Updated on July 5, 2025 by Arnaud Collignon

1. General Provisions

What documentation should be consulted?

  • Amended Law of 18 December 2015
  • Amended Grand-Ducal Regulation of 15 March 2016
  • ACD official FAQs
  • Circular ECHA No. 4
  • CRS XSD schemas and status message formats
  • OECD publications and tools (AEOI portal, guides, TIN on the Web)

Which jurisdictions are covered?

  • Reportable jurisdictions: EU member states and countries with information exchange agreements with Luxembourg
  • Partner jurisdictions: defined by law and Grand-Ducal regulation

Optional provisions for FIs

  • Outsourcing CRS obligations to service providers
  • Applying enhanced due diligence procedures
  • Accounts <250,000 USD may be excluded
  • Applying thresholds or expanded definitions as provided in CRS law

2. Financial Institutions

Who is affected?

  • UCIs, SIFs, SICARs, pension funds, RAIFs, investment firms, etc.

Investment entity status

  • An entity qualifies if it manages financial assets on behalf of clients

Luxembourg-specific rules

  • No officially recognized low-risk non-reporting FIs
  • E-money institutions are generally not considered depository institutions unless exceptions apply

3. Financial Accounts

Removal of low-risk excluded accounts

  • As of 2018, these accounts are no longer excluded from CRS

Supplementary Pension Schemes (RCP)

  • Classified as financial accounts, even during the accumulation phase

Derivatives

  • Not considered financial accounts unless held in a custodial account

4. Due Diligence

Mandatory wider approach

  • All accounts must be reviewed, even if the jurisdiction is not yet a partner

NIF / TIN collection

  • Required for all new accounts

Self-certifications

  • No specific form mandated, but must determine tax residence
  • Must be collected within 90 days of account opening

5. Reporting

Only secure transmission channels allowed

  • Only via third party providers

Zero reporting requirement

  • Mandatory even if no reportable accounts are identified

Technical identifiers (RFI_IDENTIFIER)

  • Composed of a Luxembourg registration number + extension (e.g. M00000000)

Foreign TINs

  • Must be specified for each jurisdiction
  • If not available: use code #NTA001#

Closed or dormant accounts

  • Must be reported using specific XML attributes

Validation and schemas

  • Data messages: XSD v2.0
  • Status messages: XSD v3.0
  • Automatic validation with ACK/NAK, VAL/WAR/ERR messages