Collect all information required to register your Financial Institution with the IRS FATCA portal and obtain your Global Intermediary Identification Number (GIIN).
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- Single: Most common. A standalone bank, fund, or insurance company without subsidiary FIs registered under it.
- Lead: Acts as the FATCA registration hub for affiliated entities. Creates accounts for member FIs and distributes FATCA IDs.
- Member: Cannot self-register — contact your Lead FI to obtain your FATCA ID before proceeding.
- Sponsoring Entity: Used when an entity manages FATCA compliance on behalf of others. Sponsored entities cannot log in themselves.
- Model 1 IGA: Your FI reports to its local tax authority, which shares data with the IRS. Classify as “Reporting Financial Institution under a Model 1 IGA.”
- Model 2 IGA: Your FI reports directly to the IRS under its local IGA. Classify as “Participating FFI including a Reporting Financial Institution under a Model 2 IGA.”
- No IGA: Your FI enters directly into an FFI Agreement with the IRS. Most commonly classifies as “Participating FFI.”
- Dual residents: Select one country here; identify the second in Q8 (if U.S.) or Q9 (if other).
- Qualified Intermediary (QI): A foreign financial institution or other foreign entity that has entered into a QI Agreement with the IRS. A QI assumes primary withholding and reporting responsibilities for U.S.-source income paid to its account holders, acting as an intermediary between those holders and U.S. withholding agents. QI status is often sought by banks, brokers, and custodians handling U.S. securities on behalf of clients.
- Withholding Foreign Partnership (WP): A foreign partnership that has entered into a WP Agreement with the IRS. A WP assumes primary withholding responsibility for U.S.-source income allocable to its partners, rather than passing that obligation upstream to U.S. withholding agents. This status is relevant for foreign investment partnerships and fund structures that distribute U.S.-source income to their partners.
- Withholding Foreign Trust (WT): A foreign simple or grantor trust that has entered into a WT Agreement with the IRS. A WT assumes primary withholding responsibility for U.S.-source income distributed to its beneficiaries or treated as owned by its grantors. This applies to foreign trust structures that receive and distribute U.S.-source income.
The RO is the person with legal authority to establish the FI’s FATCA statuses. The RO automatically becomes a POC and will receive all IRS email notifications for this account.
- PFFI: An officer with authority to fulfill FFI Agreement duties.
- Model 1 IGA reporting FI: Any individual specified under local law to register and obtain a GIIN on behalf of the FFI.
- Sponsoring Entity: The individual responsible for ensuring the sponsored entity meets its FATCA obligations.
- Direct Reporting NFFE: The individual responsible for the NFFE’s reporting obligations to the IRS.
FATCADoNotReply@irs.gov to your safe senders list to avoid notifications going to spam.
By entering POC information and submitting, the Authorized Individual grants the IRS written authorization to release FATCA information to the listed POCs. Up to 5 POCs allowed.
By checking this box and entering your name below, you grant the IRS authorization to disclose FATCA information to the POC(s) listed above. This authorization is effective until revoked.
Frequently Asked Questions about GIIN & FATCA Registration
Everything you need to know about obtaining a Global Intermediary Identification Number (GIIN), understanding FATCA obligations, and navigating the IRS online registration process.
A Global Intermediary Identification Number (GIIN) is a 19-character identification number assigned by the IRS to financial institutions (FIs) that register under the Foreign Account Tax Compliance Act (FATCA). It is used to identify your institution on all FATCA-related reporting and withholding documentation.
Your institution needs a GIIN if it qualifies as a Foreign Financial Institution (FFI) — including banks, investment funds, custodians, insurance companies, and broker-dealers — and must comply with FATCA by reporting on U.S. account holders or be subject to 30% withholding on U.S.-source payments.
Without a valid GIIN published on the IRS FFI List, your institution risks 30% FATCA withholding on U.S.-source income received from withholdable payments.
The Foreign Account Tax Compliance Act (FATCA) is a U.S. federal law enacted in 2010 that requires foreign financial institutions to identify and report information about accounts held by U.S. persons (including U.S. citizens abroad and certain U.S.-controlled entities) to the IRS — or face 30% withholding on U.S.-source payments.
FATCA affects virtually all types of financial institutions worldwide, including:
- Banks and credit institutions — holding deposits, providing loans
- Investment funds and asset managers — mutual funds, hedge funds, private equity, ETFs
- Custodians and brokers — holding financial assets for the accounts of others
- Insurance companies — issuing investment-linked or cash-value policies
- Holding companies and treasury centers — within financial groups
These are two distinct identifiers used at different stages of the FATCA process:
- FATCA ID: A temporary alphanumeric code assigned when a FATCA account is first created. It is used solely to log into and access the IRS FATCA Registration System during the registration process. It is not published externally and is never used for reporting.
- GIIN: The 19-character number issued after the IRS approves a completed registration. This is the permanent, publicly published identifier used in all FATCA reporting, withholding certificates (W-8BEN-E), and on the IRS FFI List.
Once a FATCA registration is submitted and approved by the IRS, the GIIN is typically issued within a few business days. The Responsible Officer (RO) receives an email notification when the registration has been processed.
The GIIN then appears on the institution’s FATCA account home page. However, it is only published on the public IRS FFI List at the next monthly update — the list is refreshed on the first business day of each month.
The IRS FATCA system recognizes four FI types, each with different registration requirements:
- Single FI: The most common type. A standalone financial institution with no affiliated member FIs. Can register for PFFI or RDCFFI status for itself and its branches.
- Lead FI: A U.S. or foreign financial institution authorized to manage and initiate FATCA registrations on behalf of member FIs within an Expanded Affiliated Group (EAG). Receives its own GIIN and can manage member accounts.
- Member FI: An FFI that is part of an EAG, registered under a Lead FI. Member FIs cannot create their own FATCA accounts — their account is created by the Lead FI, which then provides the Member FATCA ID.
- Sponsoring Entity: An entity that performs FATCA due diligence, withholding, and reporting on behalf of one or more sponsored FFIs or sponsored direct reporting NFFEs. Also used by trustees of trustee-documented trusts seeking a GIIN.
These are the two main FATCA classification categories for FFIs that are not U.S. financial institutions:
- Participating FFI (PFFI): An FFI that enters into an FFI Agreement with the IRS and commits to full FATCA compliance — identifying U.S. accounts, performing due diligence, and reporting directly to the IRS (or through a Model 2 IGA). This is the standard classification for most internationally active financial institutions.
- Registered Deemed-Compliant FFI (RDCFFI): An FFI that qualifies for a specific deemed-compliant category and registers with the IRS to confirm that status — but is not required to enter into a full FFI Agreement. Sub-categories include Local FFI, Non-Reporting Member of a PFFI Group, Qualified Collective Investment Vehicle, Qualified Credit Card Issuer/Servicer, and Restricted Fund.
FFIs in Model 1 IGA jurisdictions are typically classified as Reporting Financial Institutions under a Model 1 IGA rather than PFFIs.
Yes. A Direct Reporting Non-Financial Foreign Entity (NFFE) that elects to report its substantial U.S. owners directly to the IRS must register on the FATCA portal and will receive a GIIN. Unlike FFIs, a direct reporting NFFE receives only one GIIN, regardless of how many branches it maintains.
Direct reporting NFFEs follow the same registration steps as FIs, using the questions and instructions applicable to FIs, except where the system specifically indicates otherwise.
An Intergovernmental Agreement (IGA) is a bilateral agreement between the United States and another country that creates an alternative framework for FATCA compliance — allowing FIs in that country to report through their local tax authority rather than directly to the IRS.
- Model 1 IGA: The FI reports to its local tax authority (e.g., HMRC in the UK, AMF in France), which then passes data to the IRS. The FI classifies as a Reporting Financial Institution under a Model 1 IGA. This is the most common model — over 100 jurisdictions have Model 1 IGAs.
- Model 2 IGA: The FI reports directly to the IRS, but under a framework established by the IGA between the U.S. and the FI’s home country. Examples include Switzerland, Japan, Hong Kong, Bermuda, and Austria. The FI classifies as a Participating FFI including a Reporting FI under a Model 2 IGA.
The registration form above automatically detects the IGA model for your jurisdiction when you select your country of tax residence.
Yes. Even in Model 1 IGA jurisdictions, financial institutions must register on the IRS FATCA portal to obtain a GIIN. The IGA changes how you report (through your local authority), but registration with the IRS is still required to be published on the FFI List and avoid withholding.
The majority of countries with IGAs — including France, Germany, the United Kingdom, Luxembourg, the Netherlands, and most other EU member states — operate under Model 1. Registration is mandatory for all FIs in these jurisdictions unless they qualify for a specific exemption.
If your jurisdiction does not have an IGA in force with the United States, your institution must enter into an FFI Agreement directly with the IRS. In this case, the typical classification is Participating FFI (PFFI), and the institution is fully responsible for all FATCA due diligence, withholding, and reporting obligations under U.S. Treasury regulations.
This means your institution reports directly to the IRS (rather than via a local tax authority), and must comply with the full scope of FATCA requirements as defined in the regulations — including identifying U.S. accounts, performing annual reporting, and applying 30% withholding on non-compliant accounts where applicable.
Yes. An FI can have its home office in one jurisdiction and branches in others — each branch jurisdiction is registered separately. Each branch receives its own GIIN, which is distinct from the home office GIIN.
During registration, you classify your home office operations under Q4 and then list each branch jurisdiction separately in Q9. For branches located in IGA jurisdictions, the classification of the branch follows the rules of that branch’s jurisdiction, not the home office.
Before starting the registration process, gather the following documents and information:
- Legal name of the FI as shown in official incorporation or organization documents
- Country/jurisdiction of tax residence and local tax ID (TIN) if applicable
- FATCA classification (PFFI, RDCFFI, Reporting FI under Model 1 or 2 IGA, etc.)
- Mailing address for IRS correspondence
- Branch jurisdictions (if the FI maintains branches outside its home jurisdiction)
- U.S. EIN (if the FI is a U.S. tax resident or maintains a U.S. branch)
- QI/WP/WT status and corresponding EIN, if applicable
- Responsible Officer (RO) details: title, full name, business address, phone, and email
- Points of Contact (POC) information (up to 5), if the RO wishes to designate additional contacts
The Responsible Officer (RO) is the individual authorized under applicable local law to establish the FATCA statuses of the financial institution’s home office and branches. The RO must have authority to:
- Represent the FI’s FATCA status to the IRS as part of the registration process
- Certify that the information provided is accurate and complete
- Designate additional Points of Contact (POCs)
The RO is automatically a POC for the FI and will be the only individual who receives IRS email notifications related to the FATCA account. The RO’s email address must be a personal, individual email — never a shared or team inbox.
For PFFIs, the RO is typically an officer of the FFI with authority to fulfill FFI Agreement duties. For Model 1 IGA reporting FIs, any individual specified under local law to register and obtain a GIIN may serve as RO.
A Point of Contact (POC) is an individual authorized by the RO to receive FATCA-related information from the IRS and to take FATCA-related actions on behalf of the financial institution upon IRS request.
Key points about POCs:
- The RO is automatically a POC and receives all IRS FATCA email notifications
- Up to 5 additional POCs can be designated beyond the RO
- Each POC must have a unique, individual email address — shared inboxes are not permitted
- Third-party advisers or consultants (such as compliance firms) can be listed as POCs — enter the firm name in the “Business Title” field
- POC authorization is effective until explicitly revoked by either the POC or an authorized individual
Once the registration is submitted electronically and signed by the Responsible Officer, the IRS processes it. Here is the typical sequence:
- Step 1 — Processing: The IRS reviews the submitted information. The account status changes from “Registration Submitted” to “Approved” once the registration is processed.
- Step 2 — GIIN issuance: Upon approval, a GIIN is assigned and visible on the institution’s FATCA account home page. The RO receives an email notification.
- Step 3 — FFI List publication: The GIIN appears on the public IRS FFI List at the next monthly update (first business day of each month).
- Step 4 — Ongoing obligations: Depending on classification and jurisdiction, the FI must fulfill annual FATCA reporting, periodic certifications, and (for PFFIs) FFI Agreement renewal obligations.
Yes, for Participating FFIs (PFFIs) and Reporting FIs under Model 2 IGAs, the FFI Agreement must be periodically renewed during IRS-designated renewal open periods. Failure to renew results in the FI’s status changing to “Limited FFI” and eventual removal from the FFI List.
Additionally, all registered FIs are subject to periodic certification requirements — the RO must certify that the FI has complied with its FATCA obligations over the relevant certification period. The IRS notifies the RO by email when a certification period opens.
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