Reporting Financial Institutions

AEoI reporting only applies to Reporting Financial Institutions. Most Financial Institutions will be Reporting Financial Institutions, however there are some exemptions for example for government entities and central banks which, whilst they fall within the definition of being Financial Institutions, are exempt from AEoI reporting obligations.


Financial Institutions are defined as entities which fall into one of the following four categories.

  • Depository institutions – includes banks, building societies, credit unions and any other entities which accept deposits in the ordinary course of banking or similar business.

  • Custodial institutions – which hold, as a substantial part of their business, financial assets for the account of others.

  • Investment entities - either activity based investment entities or managed investment entities.

    - Activity based investment entities - primarily conducting business on behalf of customers such as trading in money market instruments, commodities trading, portfolio management and otherwise administering funds.

    - Managed investment entities – if managed by a Financial Institution and they meet the financial assets test (broadly that it’s gross income is primarily attributable to investing, reinvesting or trading in financial assets).


  • Specified insurance companies – writing cash value life assurance contracts and annuity contracts

The broad definition of Financial Institutions, particular taking into account the investment entity category described above, means that there are many thousands of small trusts, charities, partnerships, investment companies and securitisation vehicles which are classified as Financial Institutions and potentially could have reporting requirements.