Today, banks and financial institutions in the UAE report the accounts of customers who are tax resident in other countries to the Ministry of Finance under the Common Reporting Standard (`CRS`), so that the information can be exchanged with those countries. Crypto-assets such as Bitcoin were left outside this framework. The new `CARF` and the updated `CRS` close that gap. This article is based on the official news and guidance of the UAE Ministry of Finance and the commitments list of the `OECD` Global Forum on tax transparency, checked on 25 October 2026.
The official timeline
| Date | Event |
|---|---|
| April 2017 | The UAE signs the Convention on Mutual Administrative Assistance and the multilateral agreement on the automatic exchange of financial account information |
| November 2024 | The UAE becomes one of 61 jurisdictions committed to implementing `CARF` |
| 15 September to 8 November 2025 | Ministry of Finance public consultation on implementing `CARF` |
| 20 September 2025 | Signing of the multilateral competent authority agreement for `CARF` exchanges |
| 8 November 2025 | Announcement of the UAE's commitment to implement `CRS 2.0` |
| 1 January 2027 | `CRS 2.0` takes effect |
| 2027 | `CARF` goes live according to the ministry's news; data for 2027 is reported |
| 2028 | First exchanges of information under both frameworks, on 2027 data |
In the `OECD` list last updated on 14 September 2026, the UAE is among 27 jurisdictions undertaking first exchanges by 2028. 46 jurisdictions do so by 2027, and 4, including the United States, by 2029. Dominica and Vanuatu do not appear in any group of that list.
What is CARF?
According to the Ministry of Finance guidance, a crypto-asset is "a digital representation of value" that relies on a cryptographically secured distributed ledger or similar technology to validate and secure transactions. These assets can be held and transferred without traditional financial intermediaries, so current reporting may not capture them. `CARF` is an international standard that fills this gap.
| Concept | Definition in the official guidance |
|---|---|
| Relevant crypto-asset | any crypto-asset other than a central bank digital currency, a specified electronic money product, or an asset the provider has adequately determined cannot be used for payment or investment |
| Exchange transaction | an exchange between crypto-assets and fiat currency, or between two or more crypto-assets |
| Reporting provider | any individual or entity that, as a business, carries out exchange transactions for customers, as a counterparty, an intermediary or by making available a trading platform |
| Reportable user | a customer of the provider who is tax resident in a "reportable jurisdiction" |
The guidance says `CARF` requires intermediaries, for example crypto exchange platforms and wallet providers, to report certain transfers such as disposals and acquisitions.
The provider's link with the UAE
A provider in the UAE is subject to reporting if it has at least one of these links: it is tax resident in the UAE; it is incorporated in the UAE and has legal personality or tax reporting obligations there; it is managed from the UAE; it has a regular place of business in the UAE; or it carries out transactions through a branch in the UAE.
What information is reported?
| Category | Information under the Ministry of Finance guidance |
|---|---|
| User | name, address, jurisdiction(s) of residence, tax identification number and, for individuals, date and place of birth |
| Provider | name, address and identifying number |
| Each type of asset | full name, aggregate gross amount paid or received, number of units and number of transactions |
| Proposed deadline | 30 June of the following year, aligned with the `CRS` deadline |
The USD 50,000 threshold for retail payments
Under the `OECD` model described in the guidance, for retail payment transactions:
- if the value exceeds USD 50,000, the customer is identified as a user and their details are exchanged;
- if it is below, the customer is not reported and only the recipient, for example the merchant, is reported as a user.
What does CRS 2.0 change?
According to the Ministry of Finance news of 8 November 2025, `CRS 2.0` extends reporting to electronic money and central bank digital currencies. It also covers certain crypto-asset-related activities and adds new audit and reporting requirements. It builds on Federal Law No. 48 of 2018 and Cabinet Resolution No. 93 of 2021, and its timing is aligned with `CARF`.
CRS in the UAE today: points for account holders
The Ministry of Finance `CRS` questions and answers (April 2026) contain several practical points:
| Topic | Official rule |
|---|---|
| The UAE's approach | the "widest approach": reporting all accounts of persons tax resident in other jurisdictions, except the US and the UAE |
| Self-certification | at account opening, with name, address, jurisdiction of tax residence, tax number and date of birth |
| Reasonableness test | the bank compares the self-certification with its know-your-customer documents; an address in another country may create an inconsistency |
| Validation deadline | if validation follows account opening, within 90 days at most |
| Joint accounts | the full balance of a joint account is attributed to each holder |
| Institutions' reporting deadline | 30 June of the following year |
Penalties
| Violation | Penalty |
|---|---|
| False self-certification that the account holder knew or should have known was incorrect | AED 20,000 |
| Opening a new account without a valid self-certification or without validating it, by a financial institution | AED 1,000 |
| Failing to submit the report in the required form and on time, by a financial institution | AED 50,000 |
| Violation with intent to circumvent the `CRS` regulations, by a financial institution | AED 250,000 |
The `CARF` guidance cites these `CRS` penalties as examples and says the UAE will have strong measures against non-compliance with `CARF` too. The amounts of `CARF`'s own penalties were not on the pages we read.
Supervisors
According to the `CARF` guidance, supervision of virtual assets in the UAE is shared among several bodies:
| Body | Remit |
|---|---|
| Securities and Commodities Authority (`SCA`) | the main federal authority, including in free zones, except financial free zones |
| Central Bank of the UAE | virtual assets as a means of payment |
| `VARA` | virtual assets in Dubai, except `DIFC` |
| `ADGM` and `DIFC` authorities | within their own financial free zone |
Two examples
These examples are hypothetical and only apply the official rules above.
Example 1: a tax resident of another country with an account at a Dubai crypto exchange. Suppose that in 2027 they exchange Bitcoin for dirhams several times and their country of tax residence is on the UAE's list of reportable jurisdictions.
| Question | Answer under the official guidance |
|---|---|
| Is the exchange an "exchange transaction"? | Yes; an exchange between a crypto-asset and fiat currency |
| Who reports? | The exchange, if it has one of the links with the UAE above |
| What is reported? | Their identity and tax residence and, for each asset, the aggregate amount, number of units and number of transactions |
| When? | Reporting by 30 June 2028 (proposed) and exchange in 2028 |
Example 2: a joint account. Two people hold a joint account with USD 25,000 at a bank in the UAE. The first person separately has USD 30,000 and the second USD 40,000 at the same bank.
| Account holder | Calculation | Aggregate balance |
|---|---|---|
| First person | 30,000 + 25,000 | USD 55,000 |
| Second person | 40,000 + 25,000 | USD 65,000 |
This is the example given in the Ministry of Finance questions and answers. If one of the two is resident in a reportable jurisdiction, the joint account is reportable and its full balance is attributed to that person.
Practical points
- Fill in your tax self-certification correctly and completely; tax residence is not the same as citizenship. The article "Banks, the CRS and a second passport" explains the difference.
- If your address or tax residence changes, tell your bank or exchange; a change in circumstances must be reported.
- See the UAE tax residency certificate in the article "UAE tax residency certificate: the 183-day and 90-day tests, documents, fees and timing".
- See tether payments at Royal Golden in the article "Paying safely with tether (USDT) at Royal Golden".
- For the final `CARF` rules, follow the UAE Ministry of Finance pages.
Royal Golden does not give tax or legal advice. This article is general information, and decisions on any person's reporting obligations rest with the UAE Ministry of Finance and the supervisors.
Sources
- UAE Ministry of Finance, signing of the multilateral competent authority agreement on the automatic exchange of information under CARF (20 September 2025) — https://mof.gov.ae/en/news/uae-signs-multilateral-competent-authority-agreement-on-the-automatic-exchange-of-information-under-the-crypto-asset-reporting-framework/ (checked on 25 October 2026)
- UAE Ministry of Finance, The Crypto-Asset Reporting Framework: General Overview — https://mof.gov.ae/wp-content/uploads/2025/09/The-Crypto-Asset-Reporting-Framework-Guidance-document-EN.pdf (checked on 25 October 2026)
- UAE Ministry of Finance, announcement of the UAE's commitment to implement CRS 2.0 (8 November 2025) — https://mof.gov.ae/en/news/ministry-of-finance-announces-the-uaes-commitment-to-implement-the-updated-common-reporting-standard-crs-2-0/ (checked on 25 October 2026)
- UAE Ministry of Finance, CRS questions and answers — https://mof.gov.ae/wp-content/uploads/2026/04/UAE-CRS-FAQS.pdf (checked on 25 October 2026)
- OECD Global Forum on Transparency and Exchange of Information for Tax Purposes, jurisdictions committed to implement the CARF (updated 14 September 2026) — https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/commitments-carf.pdf (checked on 25 October 2026)