Based on these findings it was concluded that, overall, China is meeting expectations in relation to sorting, preparing and validating the information. It was also noted that there is room for improvement with respect to validating data for standard errors before transmission. China is therefore encouraged to continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
China should review its procedures to sort, prepare and validate the information to ensure that the information exchanged is in accordance with the CRS Schema.
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, China linked to the CTS.
Based on these findings it was concluded that China is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. China 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 China’s exchange partners did not raise any concerns with respect to the timeliness of exchanges by China and therefore with respect to China’s implementation of this requirement.
Based on these findings it was concluded that China is fully meeting expectations in relation exchanging information in a timely manner. China 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 China’s exchange partners did not raise any concerns with respect to China’s use of the agreed transmission methods and therefore with China’s implementation of this requirement.
Based on these findings it was concluded that China is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. China is therefore 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 China, representing 10% of its partners. This represents a relatively high proportion of partners, although it has improved over time. China has still not sent some of the status messages for 2021 and for prior years.
Based on these findings it was concluded that China is partially meeting expectations in relation to the receipt of the information. However, significant issues have been identified with respect to processes to receive and acknowledge receipt of exchanged information. China should continue its implementation process to ensure its effectiveness, including by addressing the recommendation made.
Recommendations:
China should ensure that 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:
China is ready to respond to notifications and to provide corrected, amended or additional information in a timely manner and no such concerns were raised by China’s exchange partners with respect to China’s implementation of these requirements.
Based on these findings it was concluded that China is fully meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. China is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.