Rating: On Track
Denmark’s implementation of the AEOI Standard is on track with respect to exchanging the information effectively in practice, including in relation to sorting, preparing and validating the information (SR 2.4), correctly transmitting the information in a timely manner (SRs 2.5 – 2.8) and providing corrections, amendments or additions to the information (SR 2.9). Denmark is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.
SR 2.4 Jurisdictions should sort, prepare and validate the information in accordance with the CRS XML Schema and the associated requirements in the CRS XML Schema User Guide and the File Error and Correction-related validations in the Status Message User Guide (i.e. the 50000 and 80000 range).
Findings:
Feedback from Denmark’s exchange partners did not raise any specific concerns with respect to their ability to process the information received from Denmark and therefore with respect to Denmark’s implementation of these requirements. More generally, one of Denmark’s exchange partners reported rejecting more than 25%, although not more than 50%, of the files received, due to the technical requirements not being met. This is a relatively low amount when compared with other jurisdictions. It was noted that Denmark has already successfully addressed the issue.
Based on these findings it was concluded that Denmark is fully meeting expectations in relation to sorting, preparing and validating the information. Denmark is therefore encouraged to continue its implementation process accordingly to ensure its ongoing effectiveness.
Recommendations:
No recommendations made.
SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.
Findings:
In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Denmark linked to the CTS and the CCN, which is used for exchanges within the EU.
Based on these findings it was concluded that Denmark is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Denmark is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.
Findings:
Feedback from Denmark’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Denmark and therefore with respect to Denmark’s implementation of this requirement.
Based on these findings it was concluded that Denmark is fully meeting expectations in relation to exchanging the information in a timely manner. Denmark is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Denmark’s exchange partners did not raise any concerns with respect to Denmark’s use of the agreed transmission methods and therefore with Denmark’s implementation of this requirement.
Based on these findings it was concluded that Denmark is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Denmark is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.
Findings:
Feedback from Denmark’s exchange partners did not raise any concerns with respect to Denmark receipt of the information and therefore with Denmark’s implementation of these requirements.
Based on these findings it was concluded that Denmark is fully meeting expectations in relation to the receipt of the information. Denmark is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.
Findings:
Denmark appears ready to respond to notifications and to provide corrected, amended or additional information in a timely manner and no such concerns were raised by Denmark’s exchange partners and therefore with respect to Denmark’s implementation of these requirements.
Based on these findings it was concluded that Denmark appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Denmark is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.