Based on these findings it was concluded that Spain is fully meeting expectations in relation to sorting, preparing and validating the information. Spain is 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, Spain linked to the CTS and the CCN, which is used for the exchanges within the EU.
Based on these findings it was concluded that Spain is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Spain 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:
No exchange partners highlighted delays in the sending of information by Spain.
Based on these findings it was concluded that Spain is fully meeting expectations in relation to exchanging the information in a timely manner. Spain 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 Spain’s exchange partners did not raise any concerns with respect to Spain’s use of the agreed transmission methods and therefore with Spain’s implementation of this requirement.
Based on these findings it was concluded that Spain is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Spain 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:
One exchange partner highlighted delays in the sending of status messages by Spain, relating to 2020. It was noted that Spain is in the process of addressing the issue raised.
Based on these findings it was concluded that Spain is fully meeting expectations in relation to the receipt of the information. Spain 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:
Spain 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 Spain’s exchange partners and therefore with respect to Spain’s implementation of these requirements.
Based on these findings it was concluded that Spain is fully meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Spain is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.