Rating: On track
The United Kingdom’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). The United Kingdom 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 the United Kingdom’s exchange partners did not raise any specific concerns with respect to their ability to process the information received from the United Kingdom and therefore with respect to the United Kingdom’s implementation of these requirements. More generally, one of the United Kingdom’s exchange partners reported rejecting more than 25% of the files received due to the technical requirements not being met. This is broadly in line with the general experience of other jurisdictions. It was noted that the United Kingdom has already successfully addressed the issue.
Based on these findings it was concluded that the United Kingdom is fully meeting expectations in relation to sorting, preparing and validating the information. The United Kingdom 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, the United Kingdom linked to the CTS.
Based on these findings it was concluded that the United Kingdom is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. The United Kingdom 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:
Four exchange partners highlighted delays in the sending of information by the United Kingdom (representing 5% of its partners). This represents a relatively high proportion of exchange partners. It was noted that The United Kingdom successfully addressed all of the issues and sent the information as soon as possible thereafter.
Based on these findings it was concluded that the United Kingdom is fully meeting expectations in relation to exchanging the information in a timely manner. The United Kingdom 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 the United Kingdom’s exchange partners did not raise any concerns with respect to the United Kingdom’s use of the agreed transmission methods and therefore with the United Kingdom’s implementation of this requirement.
Based on these findings it was concluded that the United Kingdom is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. The United Kingdom 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:
Ten exchange partners highlighted delays in the sending of status messages by the United Kingdom, representing 9% of its partners. This represents a relatively high proportion of partners. The United Kingdom has still not yet sent some of the status messages due to be sent in 2021.
Based on these findings it was concluded that, overall, the United Kingdom is meeting expectations in relation to the receipt of the information. It was also noted that there is room for improvement with respect to the timeliness as regards sending status messages. The United Kingdom is encouraged to continue to ensure the ongoing effectiveness of its implementation, including by addressing the recommendation made.
Recommendations:
The United Kingdom should ensure it sends status messages to all of its exchange partners in a timely manner.
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:
The United Kingdom 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 the United Kingdom’s exchange partners and therefore with respect to the United Kingdom’s implementation of these requirements.
Based on these findings it was concluded that the United Kingdom is fully meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. The United Kingdom is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.