Slovenia’s tax administration (FURS) issued technical guidance on the implementation of CRS 2.0, DAC8 and Directive 2025/872, expanding reporting requirements to cover E-Money, CBDCs and certain crypto-asset investments. The guidance also set out updated due diligence rules, excluded accounts, reporting deadlines and XML requirements.
Slovenia’s tax administration (FURS) issued technical guidance on 10 September 2026 on the national implementation of CRS 2.0, EU Council Directive 2023/2226 (DAC8) and Directive 2025/872.
The changes were transposed into Slovenian law through amendments to the Tax Procedure Act (ZDavP-2P), which took effect on 1 January 2026.
The updated framework expanded the scope of reportable financial products and accounts to include Electronic Money (E-Money) and Central Bank Digital Currencies (CBDCs). E-Money covers digital claims denominated in a single fiat currency and redeemable at par value, including e-wallets, prepaid cards and fiat-backed stablecoins such as USDC.
CBDCs cover digital fiat currencies issued by central banks or monetary authorities.
Crypto-assets and investment entities
The guidance also expanded the definition of Financial Assets to include derivative contracts linked to reportable crypto-assets, including futures, options and forwards.
Investment Entities that invest, manage or trade in reportable crypto-assets are also brought within the CRS 2.0 reporting framework.
The guidance distinguishes between CARF/DAC8 and CRS 2.0. CARF/DAC8 covers direct crypto-asset exchanges reported by Reporting Crypto-Asset Service Providers (RCASPs), while CRS 2.0 covers financial account balances and indirect crypto-asset investments held through financial institutions.
To avoid duplicate reporting, reporting entities may opt out of reporting gross proceeds under CRS 2.0 where those proceeds have already been reported under CARF/DAC8.
New excluded accounts
Entities holding E-Money or CBDCs for customers are now classified as depository institutions holding depository accounts.
The guidance identifies several categories of Excluded Accounts, including low-value E-Money accounts where the rolling 90-day average daily balance, or maximum balance during any 90-day period in the year, does not exceed USD 10,000.
Accounts established solely for incorporation or capital increases may also qualify where the funds remain blocked until registration and the account is closed or converted within 12 months.
Other specified low-risk national accounts include Slovenian housing reserve fund accounts (rezervni sklad) and dormant accounts with balances below USD 1,000.
Slovenian Individual Investment Accounts (INR) do not qualify as excluded accounts and remain fully reportable under CRS 2.0.
The rules also update the treatment of Non-Reporting Financial Institutions, including Central Banks and Governmental Entities managing CBDCs for commercial non-exempt account holders. Broad participation pension funds are subject to a 5% beneficiary limit.
Due diligence requirements
Pre-existing Accounts are accounts that were open as of 31 December 2025, while New Accounts are those opened on or after 1 January 2026.
For relevant pre-existing accounts, financial institutions must complete reviews by 31 December 2026 for high-value accounts and by 31 December 2027 for lower-value accounts and entities.
Self-certifications must generally be obtained when an account is opened. Financial institutions may collect the certification within 90 days in exceptional operational circumstances.
From 1 January 2026, account holders with dual tax residency must disclose all tax residencies rather than relying solely on tax treaty tie-breaker rules to identify a single jurisdiction.
Financial institutions must also conduct enhanced due diligence where account holders claim tax residence in jurisdictions offering potentially high-risk Citizenship/Residence by Investment schemes.
Reporting deadlines and XML changes
Financial institutions must submit reportable account information electronically to FURS by 31 May following the relevant reporting calendar year. FURS must exchange the information internationally within nine months.
The CRS XML 3.0 Schema will become mandatory for reporting data from 1 January 2027.
The updated specifications introduce several mandatory fields, including AccountNumberType, with the new OECD606 code for E-Money accounts.
Reporting entities must also provide detailed classifications for Controlling Person Role / Equity Interest Type, report the exact total number of holders of joint accounts including non-reportable individuals, and use the SelfCert tag to indicate whether a valid self-certification was obtained.
Standard forms and FAQs
FURS has included standardised self-certification forms for individual account holders, entity account holders and controlling persons of passive NFEs.
The guidance also addresses transitional and technical issues involving crypto-assets and E-Money, including cases where crypto-assets evolve into E-Money products during the year, multi-currency e-wallets, and the distinction between regulated investment funds and crypto-asset service providers.
