Automatic Exchange of Information

Financial Institutions in the United Kingdom are required to submit an AEOI report online via the HMRC portal. This can be done either by uploading an XML file created using the UK schema, or via manual input by following the on-screen instructions.

Full details of the UK reporting requirements can be found in the AEOI section of the HMRC International Exchange of Information Manual

Registering for AEOI

In order to submit AEOI reports to HMRC, Financial Institutions must be registered with the AEOI service. Third parties may register Financial Institutions and report on their behalf. The Financial Institution, or third party reporting on their behalf, must register with the AEOI service at least 24 hours before filing an AEOI return. In order to register for AEOI reporting, a Government Gateway user ID is required. Full details can be found on the Gov.uk website Register for Automatic Exchange of Information.

After registering, HMRC issue a 10 digit AEOI ID, together with a 13 character identification number for each Financial Institution. These IDs are used for reporting and are required to be included in the XML file (where the option to upload an XML file is used for reporting).

AEOI Schema

The current version of the UK AEOI schema is version 2.0 (uk_aeoi_submission_v2.0.xsd). The schema files, together with the user guide and sample XML files can be downloaded from the Gov.uk website AEOI schema and supporting documents

Features of the UK schema

The UK schema differs from the standard FATCA and CRS schemas in the following key areas:

• Account holder tax info - as a single report for AEOI is submitted, individuals and entities which are both US resident (FATCA) and resident in other reportable jurisdictions (CRS purposes) can be included once in the report, with separate Holder tax info sections included to report details of each reportable jurisdiction for that account holder.
• Address fields - the UK schema does not support the concept of a 'free format' address. Addresses should be reported using the 'fixed' fields of Building identifier, Street, District, City, Postcode and Country.
• Account identifier - where the accounts held by a Financial Institution do not have recognised account numbers, the alternative Account identifier field may be used to provide a reference which can be used to identify the account. Where this field is used, the Account number field should not be used.
• Account Ref and Action fields - a unique Account Ref is required for each account reported. This reference is required if a subsequent amendment is required to be reported, together with the appropriate Action (Void, Amendment, Replacement)

Financial Institution elections

Each Financial Institution is required to state either Yes, No or N/A for each of the following elections when reporting:

• Insurance election - if the FI has elected not to report cash value insurance contracts or annuity contracts described in section III A of the CRS to non-EU jurisdictions
• Dormant accounts election - if the FI has elected NOT to report dormant accounts
• Due diligence - if reporting US persons, the FI has elected to use alternative due-diligence procedures taken from US Treasury regulations
• Thresholds - the FI has elected to use thresholds in the due-diligence process

Nil returns

Nil returns are not usually required, however they can be filed voluntarily. A nil return is required to be filed where a Financial Institution has potentially reportable accounts but has elected to apply thresholds in determining if those accounts are reportable and the account balances fall below the relevant thresholds. In this case it is necessary to submit a nil return in order to make the election to apply the thresholds.

Reportable jurisdictions

The most recent list of reportable jurisdictions is published in the International Exchange of Information Manual (updated 13 January 2022).