Second citizenship and CRS: what the OECD rules say

Information, not tax advice. This post summarises what the OECD publishes. How the rules apply to you depends on the tax laws of every country you are connected to; speak to a qualified tax adviser before acting.

A common belief is that a second passport changes where your bank accounts get reported. Under the international standard for automatically exchanging bank information, it does not, at least not in the way people hope. This post explains what the OECD's Common Reporting Standard, known as the CRS, actually keys on, and what the OECD says specifically about citizenship and residence bought through investment.

What the CRS reports, and to whom

Under the CRS, banks and other financial institutions identify which of their account holders are reportable, and report those accounts to the jurisdiction or jurisdictions where the holder is resident for tax purposes. The definition of a reportable person turns on residence under a jurisdiction's tax laws, and the report carries the holder's jurisdictions of residence and tax identification numbers. Citizenship is not the test.

That is the first thing to understand. A new passport, on its own, does not move your accounts from one reporting destination to another. What matters is where you are tax resident, which each country decides under its own law.

Why the OECD looks at investment citizenship at all

If citizenship is not the test, why does the OECD mention citizenship-by-investment schemes? Because of how account holders tell their banks where they are resident. Banks rely on a self-certification, and in the OECD's framing the concern is that a certificate of residence or citizenship from a scheme with low tax and no real presence can be used to claim a residence the person does not really have, so that the account is reported to the wrong place, or nowhere useful.

The CRS Commentary says exactly that: certain high-risk citizenship and residence by investment schemes may be misused to get around CRS reporting.

What makes a scheme “high-risk”

The OECD treats a scheme as potentially high-risk for the CRS when two things are true together: it gives access to a personal income tax rate below 10% on offshore financial assets, and it does not require at least 90 days of physical presence in the jurisdiction offering it. The OECD says it has analysed more than 100 schemes offered by jurisdictions committed to the CRS.

Which programmes are on the OECD's list

The OECD publishes a table of schemes it considers potentially high-risk to the integrity of the CRS. On the current version, the citizenship-by-investment programmes of all five Eastern Caribbean countries, Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis and Saint Lucia, are listed, as is Vanuatu's Development Support Programme. Türkiye, Nauru and São Tomé and Príncipe are not on it. The table is marked version 2, published on 22 May 2025 and last modified on 8 August 2025.

ProgrammeOn the OECD high-risk list?
Antigua and BarbudaYes
DominicaYes
GrenadaYes
St Kitts and NevisYes
Saint LuciaYes
Vanuatu (Development Support Programme)Yes
TürkiyeNo
NauruNo
São Tomé and PríncipeNo

Being on the list does not make a programme illegal, and it says nothing about the passport's travel value. It is a signal to financial institutions that a residence claim linked to that scheme deserves a closer look.

What banks are told to ask

The CRS Commentary expects financial institutions to use the OECD's published information when deciding whether a self-certification can be relied on. If an account holder claims residence in a jurisdiction with a potentially high-risk scheme and the bank has doubts, it should not rely on the self-certification until it has checked further. The Commentary gives example questions:

  • Did you obtain residence rights through a citizenship or residence by investment scheme?
  • Do you hold residence rights in any other jurisdiction?
  • Did you spend more than 90 days in any other jurisdiction during the previous year?
  • In which jurisdictions did you file personal income tax returns during the previous year?

In practice, then, a new citizen of a listed programme who gives that country as their residence should expect questions like these.

The disclosure rules for advisers

The OECD has also targeted the people who design avoidance. Its 2018 Model Mandatory Disclosure Rules require intermediaries, and in some cases users, of CRS avoidance arrangements and opaque offshore structures to disclose them to their tax administration, which shares the information with the countries where the users are resident. The covered arrangements include those that exploit weaknesses in how financial institutions identify all of an account holder's tax residences.

Our reading: any adviser selling a second passport as a way to keep accounts away from CRS reporting is describing exactly the kind of arrangement these rules exist to expose.

The Caribbean is building tax checks in, too

The region's new regulator points the same way. The agreement creating the Eastern Caribbean Citizenship by Investment Regulatory Authority requires its uniform applicant standards to include a declaration of tax residence, tax status and compliance. Our post on ECCIRA explains the wider changes.

What this means for a UAE resident

In our view, for most people who live in the UAE and want a second passport for travel, family security or a plan B, nothing here is an obstacle. The CRS is about where you are tax resident, and a passport bought for those reasons does not change that. What the OECD rules do mean is that a second citizenship is not a tool for hiding accounts, and that banks may ask questions if you claim residence in a listed jurisdiction. Answer them accurately.

If tax is part of your thinking, involve a tax adviser before choosing a programme. For everything else, the programme overview and the comparison tool set out what each passport offers, and our guide for UAE residents covers the questions specific to living here.

Start with a private consultation

Tell us about your family, nationality and goals. You receive a shortlist of the programmes that fit, and apply through a licensed partner agent we name before sharing your details.

Sources and last checked5 government and official sources · checked 5 October 2026
  1. OECD, Consolidated text of the Common Reporting Standard (2025), Section VIII(D) definitions and Section I(A) reporting requirements, checked 5 October 2026
  2. OECD topic page 'Residence/Citizenship by investment schemes' (FAQ: Which CBI/RBI schemes present a potentially high risk?), checked 5 October 2026
  3. OECD table of potentially high-risk CBI/RBI schemes: the dataset of the Datawrapper chart 'Residence/Citizenship by investment schemes' (source: OECD) embedded on the OECD topic page https://www.oecd.org/en/topics/sub-issues/international-standards-on-tax-transparency/residence-citizenship-by-investment.html, checked 5 October 2026
  4. OECD (2018), Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures, Introduction para 2 and Rule 1.1 (CRS Avoidance Arrangement), checked 5 October 2026
  5. Antigua and Barbuda Act No. 18 of 2025, Schedule (ECCIRA Agreement), Art. 45 'Uniform standards and timelines', laws.gov.ag, checked 5 October 2026
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