The Latest IRS, FATCA and CRS News for September 2025
- 09/30/25
- 12 Min Read Time
Coming up in October 2025:
Digital Asset Summit
We will be attending the Digital Asset Summit 2025 in London from October 13 – October 15. This flagship event is one of the largest gatherings dedicated to digital assets, covering everything from market infrastructure and institutional adoption to regulation and technology trends. Our team will be on the ground connecting with peers, discussing upcoming regulations like CARF and DAC8, and sharing how our solutions help organizations navigate the complex tax and compliance requirements in the digital asset ecosystem.
London Blockchain Conference
We are proud to announce that Comply Exchange will be at the London Blockchain Conference being held October 22 – 23. This event brings together innovators, regulators, and industry leaders to explore the future of blockchain and its role in financial services, compliance, and beyond. As sponsors, we’ll be showcasing how our solutions are leveraging tokenization and blockchain technology to simplify tax compliance and document management in the digital asset space.
IRS: Public Key for FATCA Filing
On September 30, 2025, the IRS released FATCA News & Information Issue Number: 2025-07 regarding updated public key for FATCA filings. The public/private key pairs used for encryption for FATCA filings will expire soon. The IRS has a new key and will replace the existing key on Friday, October 17, 2025, at 9:00am EDT. After October 17, 2025, at 9:00am EDT, you will need to download the new IRS Public Key from IDES to file your FATCA Reports.
South Africa: Third-Party Data Bi-Annual Submission Period
The South African Revenue Service (SARS) announced the SARS Third-Party Data Bi-Annual Submission process, including FATCA and CRS returns, for the period 1 March 2025 to 31 August 2025 opens on 1 September 2025 and will close on 31 October 2025.
IRS & Treasury Updates September 2025:
IRS Releases Draft Form W-9 (Rev. January 2026)
On September 17, the IRS published a new draft Form W-9 (Rev. January 2026). The 2026 draft signals the IRS’s continued push to adapt documentation to evolving tax reporting requirements, especially in the digital asset space. Here is a high-level overview of the changes:
- A new checkbox certification has been added in Part II of the form.
- New exempt payee code (14) has been added: U.S. digital asset brokers (other than registered investment advisers) may now certify that they are exempt from information reporting under Reg. §1.6045-1.
- The draft form explicitly states: “Do not report the employer identification number (EIN) of a sole proprietorship or disregarded entity.” Instead, a sole proprietor must provide an SSN, and a disregarded entity must provide the owner’s TIN (EIN for entities; SSN for individuals/sole proprietors).
Visit our blog for additional information around the changes and what you need know.
IRS Publishes 2025 Updates to Publications 1220 and 1187
The IRS has released the 2025 versions of Publication 1220 (Specifications for Electronic Filing of Forms 1097, 1098, 1099, 3921, 3922, 5498, and W-2G) and Publication 1187 (Specifications for Electronic Filing of Forms 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding). Section 3 of each publication highlights what’s new for this year. Below is a summary of the key changes that filers should be aware of:
- Transition from FIRE to IRIS
- The IRS has announced that the FIRE system will be retired starting with Filing Season 2027 (Tax Year 2026 returns).
- IRIS (Information Returns Intake System) will become the exclusive system for filing information returns electronically. Filers should begin applying for an IRIS Transmitter Control Code (TCC) now to prepare.
- Golden Parachute Payment Filings
- These payments can no longer be filed through FIRE.
- They must be filed either via IRIS or on paper, and corrections must be submitted on paper.
- Form 8508 can be used to request a waiver to file by paper if required.
- Combined Federal/State Filing (CF/SF) Updates
- Oregon has been added to the program (Code 41)
- Missouri has been removed (Code 29)
- Form-Specific Reporting Changes
- Form 1099-Q: New Code 2 for reporting a QTP → Roth IRA transfer.
- Form 1099-R: New Distribution Code “Y” for Qualified Charitable Distributions (QCDs).
- Transition to IRIS
- Like Pub. 1220, Pub. 1187 confirms the planned retirement of FIRE in Filing Season 2027.
- IRIS will be the exclusive system for Form 1042-S electronic filings going forward.
- Clarified Definitions
- Updates to definitions for key terms such as withholdable payment, beneficial owner, withholding foreign partnership (WP), withholding foreign trust (WT), and withholding rate pool.
- Address / Format Updates
- Expanded guidance for state abbreviations, APO/FPO/DPO addresses, and province codes in electronic submissions.
👉 Key Takeaway: Organizations relying on FIRE must begin preparing now to move onto IRIS before the 2027 deadline. The 2025 updates highlight the IRS’s continued shift to modernize electronic filing and streamline reporting through IRIS. Now is the time to update systems, test IRIS capabilities, and adjust reporting processes to ensure compliance before FIRE is phased out.
Draft Tax Forms
The IRS released several draft tax forms in the month of September:
Form 1099-S: Proceeds From Real Estate Transactions
Form 1099-G and Form 1099-G Instructions: Certain Government Payments
Form 1099-DA: Digital Asset Proceeds From Broker Transactions
Form 1099-B: Proceeds From Broker and Barter Exchange Transactions
Form 1042-S: Foreign Person’s U.S. Source Income Subject to Withholding
Form 1042: Annual Withholding Tax Return for U.S. Source Income of Foreign Persons
👉 Key Takeaway: The IRS has publicly confirmed that for tax year 2025, existing 1099s and withholding tables will remain unchanged (despite new tax law) to avoid disruption. Because 1099-DA is new and complex, industry groups are urging the IRS to allow sufficient lead time for software vendors and brokers to build compliance systems.
September 2025 FATCA, CRS and CARF Headlines:
Switzerland: Consultation on Automatic Exchange of Information
On August 13, 2025, the Federal Council initiated the consultation on the introduction of the automatic exchange of financial account information (AEOI) with eight more partner states: Armenia, Cameroon, Mongolia, Papua New Guinea, Paraguay, Rwanda, Senegal and Tunisia.
The AEOI with these partner states is scheduled to enter into force on 1 January 2027, with the first exchange of data to take place in 2028. The consultation will run until 14 November 2025.
United Kingdom: Updates to FATCA/CRS Schemas
United Kingdom’s HMRC announced from 1 January 2027, the current Automatic Exchange of Information (AEOI) return will be changing.
HMRC’s current combined Common Reporting Standard (CRS) and Foreign Account Tax Compliance Act (FATCA) schema will no longer be in use after 31 December 2026. It will be replaced by the amended CRS XML schema published by the Organisation for Economic Co-operation and Development (OECD) in October 2024 for CRS reporting, and by the Internal Revenue Service (IRS) FATCA schema published in January 2017 for FATCA reporting.
UK Financial Institutions may submit their returns to HMRC through a portal hosted on the UK Government Gateway by uploading data using the Reportable Account submission schema. For Financial Institutions who have only a few Reportable Accounts, a form-based system is also available which allows Financial Institutions to manually enter their Reportable Accounts.
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A Message From Our CEO
As we look ahead to year-end, one thing is clear: technology doesn’t replace compliance — it makes it stronger, smarter, and more sustainable. With regulations evolving rapidly, particularly in the digital asset space, the real opportunity is in turning compliance into a business advantage rather than a burden. New innovations are helping streamline form collection and validation in ways that anticipate tomorrow’s requirements. We’re excited to bring these advancements to our clients, ensuring you’re not just keeping up with change, but staying ahead of it.