Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2026 Update (June)

In respect of the additional 14 monitored jurisdictions added to Chapter 4 of this publication, actions taken in respect of a further 92 in-box recommendations have been analysed since the December 2025 report. Of these, 31 recommendations related to aspects of the jurisdictions’ legal and regulatory framework (“framework” recommendations), and 61 related to the practical implementation of the frameworks (“practice” recommendations).

The trends for the 14 monitored jurisdictions reflect consistency and continuity with the findings for the 25 jurisdictions for which the enhanced monitoring process was previously completed and there is aggregated cumulative analysis presented below.

Figure 2.1 presents the aggregated Element-wise and type-wise (framework or practice) findings focusing on the recommendations analysed in the 14 additional reports included in this publication.

Across the 14 additional reports, 33 in-box recommendations (36%) are “considered addressed in the context of the monitoring process (subject to a peer review)” or “considered provisionally addressed in the context of the monitoring process, subject to detailed validation” – together referred to as “considered (provisionally) addressed”. Both statuses convey a good degree of satisfaction that the reported actions address the recommendation. Further, 44 in-box recommendations (48%) are categorised as “in the process of being addressed” and 11 in-box recommendations (12%) are assigned the status of “has not been addressed”. In addition, four in-box recommendations (4%) are considered “no longer sufficiently material”.

For the 14 monitored jurisdictions, 31 recommendations pertain to deficiencies in the legal and regulatory frameworks of the jurisdictions. Of these, 13 recommendations have been addressed by the relevant monitored jurisdictions through amendments to their legal and regulatory frameworks. Nevertheless, to demonstrate implementation of the amended frameworks, six new recommendations have been issued. In addition to these addressed recommendations, four recommendations have been determined to be “no longer sufficiently material” permitting the monitored jurisdictions concerned to stop reporting on them in the future.

The remaining 61 recommendations pertain to identified issues in the effectiveness of the implementation of the monitored jurisdictions’ legal and regulatory frameworks in practice. Of these, 20 recommendations or 33% have been considered (provisionally) addressed. A third of these 20 recommendations (i.e. 7 recommendations) pertain to effective exchange of information. In this regard, five monitored jurisdictions have improved their communication, organisational resources and timeliness of responding to requests. For other aspects of the standard, there has been some success in demonstrating the satisfactory implementation of the legal and regulatory frameworks in practice.

Notwithstanding the encouraging progress observed, there is room for further work in some areas. For the 14 monitored jurisdictions, 11 recommendations or 12% have each been determined as “has not been addressed”. Out of these 11 recommendations, for 6 recommendations, no actions or only preliminary steps have been reported, although more than three years have passed since the adoption of the EOIR report. These monitored jurisdictions have been asked to submit a schedule for the completion of the steps necessary to address the recommendation(s), along with an update on progress made by 31 March 2027.

Two out of the 14 monitored jurisdictions have received an additional recommendation to improve an issue identified as having broader than bilateral implication for the implementation of the standard. In one case, the matters raised by peers reflected backsliding. Accordingly, the jurisdiction concerned is required to report annually on the actions taken to address the corresponding recommendation. In respect of the other jurisdiction, a fresh recommendation on a new issue that was not previously identified has been made based on the analysis of the peer input.

Altogether 217 in-box recommendations for 39 monitored jurisdictions have been analysed so far under round 1 of the enhanced monitoring process. Of these 217 recommendations, 76 are framework recommendations and 141 are practice recommendations.

Across the 39 reports, 69 in-box recommendations are “considered (provisionally) addressed”. Further, 111 in-box recommendations are categorised as “in the process of being addressed” and 29 in-box recommendations are assigned the status of “has not been addressed”. In addition, 8 in-box recommendations are considered “no longer sufficiently material” (for the meaning of these statuses, refer to the discussion on “Statuses determined and actions required” under Chapter 1, section on “Procedure followed”, “Step 5 PRMG decisions”).

Figure 2.2 below presents the findings in respect to all jurisdictions monitored so far. The results are shown in an Element-wise and a type-wise (framework or practice) breakdown of the statuses determined for in-box recommendations.

In relation to the 69 recommendations that are “considered (provisionally) addressed”, 28 are recommendations on the jurisdictions’ legal and regulatory frameworks (framework recommendations), while 41 pertain to implementation aspects. Out of the 39 jurisdictions, 28 have at least one of their recommendations considered (provisionally) addressed.1 These addressed recommendations relate to a range of issues across the standard. In respect of framework recommendations, notable progress by jurisdictions is seen through the amendments of their legal and regulatory frameworks. However, a legal change must be followed up with a demonstration of suitable implementation. In respect of the 28 framework recommendations “considered (provisionally) addressed”,2 13 corresponding new recommendations on the implementation of the amended frameworks have been issued.3

In respect of recommendations on implementation, for the 39 monitored jurisdictions, 41 recommendations for 19 jurisdictions are considered (provisionally) addressed. About a third of these recommendations pertain to effective exchange of information and another third to availability of ownership information, where jurisdictions have demonstrated sufficient improvements. The remaining such recommendations are spread over multiple Elements of the standard.4

A total of 111 recommendations (or 51%) are “in the process of being addressed”. Although this status means that the recommendations are not yet considered addressed, for almost all such recommendations, material progress has been made by the jurisdictions, even though some further work remains to be done or to be demonstrated to fully address the recommendation. For such recommendations, jurisdictions have been asked to take suitable actions and to report further progress on the implementation of these recommendations in their next self-assessments. Of the 39 monitored jurisdictions, 31 have at least one recommendation considered as being “in the process of being addressed”.5

A total of 29 recommendations are assigned the status of “has not been addressed”. Of the 39 monitored jurisdictions, 12 jurisdictions have this status for at least one of their recommendations.6 Following the methodology (point 2 of the table at paragraph 60 of the methodology for enhanced monitoring), where more than three years have elapsed since the issuance of the recommendation and material progress7 has not been demonstrated, the jurisdiction must submit a schedule for completion of actions to address the recommendation and provide an annual update to the PRMG. Out of these 12 jurisdictions, 8 have been asked to undertake such a follow-up and start reporting back from 31 March of the year following the publication of its report. In addition, one jurisdiction with a recommendation “in the process of being addressed” has been similarly asked to undertake such a follow-up.8

A total of eight recommendations have been ascertained to be “not sufficiently material” and no further reporting is required. Five of them pertain to monitoring that attorney-client privilege does not unduly affect the powers of the competent authority to access and exchange information. The jurisdictions concerned were able to demonstrate that there is no indication of any adverse consequence on EOIR in practice as a result; thus, although no specific legal or regulatory change has been made, there is no indication that this aspect has had or is likely to pose any difficulties to effective EOIR in practice. Two recommendation was for the jurisdiction to ratify all signed treaties and, since its review, the jurisdiction signed and ratified the Multilateral Convention, which addressed the substance of the recommendation, as now the jurisdiction and its partners can exchange information in accordance with the standard. Finally, one recommendation to amend the legal framework to disclose minimum information in summons notices for gathering information has been accepted with this status given the limited need in practice to issue summons to gather information, coupled with the jurisdiction’s active practice of keeping its treaty partners duly informed about this aspect and issuing such notices after informing its peers.

The defining feature of the revision of the Terms of Reference in relation to the EOIR standard in 2015 was the introduction of the requirement to ensure availability of beneficial ownership information for legal entities and arrangements, as well as for bank accounts. In the second round of reviews this new requirement has accordingly been one of the key focus areas. It has led to recommendations for most jurisdictions, as they put in place systems to comply with the revised standard; of the 217 in-box recommendations in the 39 reports, 99 (46%) pertain to the availability of beneficial ownership information.

The challenges faced by jurisdictions include both the putting in place of the necessary legal requirements for ensuring the availability of beneficial ownership information and the practical implementation and supervision of these requirements; of the 99 recommendations related to beneficial ownership information, 47 recommendations pertain to the legal and regulatory framework and 52 recommendations pertain to implementation in practice. As banks and financial institutions in most jurisdictions were already familiar with the concept of beneficial owner and had already been implementing anti-money laundering requirements related to beneficial ownership information, only a small proportion of recommendations (18) relate to availability of beneficial ownership information on bank accounts (Element A.3), and the bulk of the recommendations (81) relate to the availability of beneficial ownership information of relevant legal entities and arrangements (Element A.1).

While jurisdictions have generally been making progress on addressing these recommendations, demonstrating effectiveness in practice takes time. In this regard, addressing issues in legal and regulatory frameworks outpace demonstrated improvements in practical implementation. Out of the 99 recommendations related to beneficial ownership, 25 recommendations relating mainly to legal and regulatory frameworks are “considered (provisionally) addressed” and 61 recommendations, mostly relating to practical implementation, remain “in the process of being addressed”. Finally, 13 recommendations have been determined as “has not been addressed”.

Some common trends on beneficial ownership information recommendations are noticeable.

• Jurisdictions have progressively adopted a multi-pronged approach to ensure the availability of beneficial ownership information by putting in place more than one source of such information. For instance, obligations on entities themselves to maintain adequate, accurate and up-to-date beneficial ownership information, and/or the introduction of beneficial ownership registers to supplement the beneficial ownership requirements under the anti-money laundering framework.

• Jurisdictions are demonstrating an increased understanding of the complexities of ensuring the availability of accurate beneficial ownership information and the associated challenges. The experience of jurisdictions shows that the legal framework for beneficial ownership registers takes time to mature and challenges in practical implementation often require legislative solutions.

• The practical implementation of beneficial ownership registers follows an evolutionary trajectory – this begins with outreach and enforcement measures targeted at the persons with obligations with respect to the beneficial ownership register, followed by data cleaning, matching and verification and, finally, risk-based supervision.

Of the 39 monitored jurisdictions that received an in-box recommendation on implementing their beneficial ownership registers, some have reported high levels of success in populating the beneficial ownership registers.9 Discrepancy reporting by AML-obliged persons has emerged as an important tool to verify the information reported to beneficial ownership registers.10 For most jurisdictions, more work is still needed to ensure the quality of the information in the beneficial ownership registers. Hence, the reports of some jurisdictions acknowledge the progress on the implementation of their beneficial ownership registers and indicate that they should take further supervisory steps and report the results to demonstrate the effectiveness of their efforts to ensure the quality of information contained in the registers in due course.11

In EOIR peer review reports, inactive entities have been identified as posing specific issues in respect of the availability of ownership and accounting information, particularly where the reports noted a high volume of such entities and/or an inability of the jurisdiction to accurately estimate their numbers. Across jurisdictions and reports, inactive entities are defined and understood with some variation and no homogenous definition exists. A common definition is where entities have been assigned a status of “inactive” (or similar) by the authorities after their lack of economic activity has been verified. In such cases, there is a clear indication of the number of such entities. This usually requires coordination between tax authorities and the commercial registry, and the harmonisation of their databases. In other jurisdictions, inactive entities are not defined specifically but are understood to mean persistently non-compliant entities that fail to meet their filing requirements under tax law or commercial laws. Usually, the tax authorities and commercial registry assign their own statuses to entities they oversee based on the non-compliance they identify. This often leads to differences in the number of inactive entities between the databases of tax authorities and commercial registries.

The risk in respect of inactive entities is their continued legal personality that can allow them to carry on economic activities or to hold assets inside or outside of their jurisdiction of incorporation. Experience during peer reviews shows jurisdictions making EOI requests seeking information on entities which were or have been considered inactive by the requested jurisdiction. In such instance, requested jurisdictions have faced difficulties in providing the relevant legal and beneficial ownership information, as well as basic accounting information. For the 39 reports, recommendations on the availability of ownership and accounting information in respect of inactive entities were present in 16 recommendations made to 8 jurisdictions.12 Following the analysis, no recommendation is “considered (provisionally) addressed”. Four recommendations issued to two jurisdictions (each with a recommendation in respect of ownership and accounting information) are determined as “has not been addressed”. The remaining recommendations are “in the process of being addressed”.

Some facts noted so far are below:

• Jurisdictions are at different stages in addressing recommendations pertaining to inactive entities.

• A first step is often introducing a clear definition of inactive entities and establishing how many entities are inactive according to the definition. Jurisdictions are at different stages in this regard. Some jurisdictions have taken preliminary steps to coordinate between the relevant supervisory authorities to identify inactive entities, while others have taken steps to put in place and improve their monitoring tools. The more advanced jurisdictions have a more complete oversight over the number of inactive entities.

• Jurisdictions have often relied on their existing surveillance mechanisms to monitor domestic economic activity. While this measure is helpful, it does not by itself mitigate the concerns around economic activities that might be carried on overseas or assets held abroad.

• Some jurisdictions have adopted the approach of registry clean-up by the compulsory dissolution of inactive entities. This is usually the case where it is easy to identify that the entities do not hold assets that would require liquidation. Nevertheless, such jurisdictions should ensure the availability of information for at least five years following the dissolution of such entities.

• The continued maintenance of legal personality by inactive entities continues to pose risks. There are variations across jurisdictions in their approach to clean-up the commercial registries by compulsorily dissolving inactive entities to extinguish their legal personality. Such actions are not yet legally feasible in some jurisdictions and entail costs and time around closure audits and liquidations.

• Overall, jurisdictions continue to face challenges in demonstrating the sufficiency of actions to address recommendations pertaining to inactive entities.

Another area of further work is the overall legal, regulatory and enforcement systems that jurisdictions have in place to ensure ready availability and timely access by the Competent Authority to accounting information for all relevant entities and arrangements. These practical implementation aspects affect both Element A.2 (availability of accounting information) and Element B.1 (access to information). Out of the total 36 recommendations for these two Elements that are “in the process of being addressed” or have the status of “has not been addressed”, at least 19 pertain to availability and timely access to accounting information aspects for one or more types of relevant entities and arrangements. Four monitored jurisdictions have a recommendation in this regard that has not yet been addressed.13

Enforcement of legal and regulatory framework in respect of accounting information is particularly challenging where there are no requirements that the accounting records be located in the jurisdiction and there is no mechanism in place to ensure availability and timely access to the accounting records (for example, requiring an entity to appoint a responsible natural person in the jurisdiction who has control or possession of such information and the ability to produce the information when called upon by the Competent Authority, requiring prior authorisation before records can be stored abroad subject to conditions that guarantee timely access and establishing minimum reporting requirements or ensuring the availability of specific information within the jurisdiction). The availability of underlying documentation as part of accounting records, availability of accounting information of inactive companies maintaining their legal personality, or where entities cease to exist or redomicile to other jurisdictions present a range of inter-linked issues. The application of sanctions and taking measures to ensure compliance and to deter non-compliance requires jurisdictions to ascertain whether their legal and regulatory frameworks facilitate such actions and, if not, consider legal amendments. Finally, the aspect of ensuring the adequacy and accuracy of accounting information is premised on scrutiny and oversight by public authorities, which needs to be sufficiently demonstrated by jurisdictions seeking to address such recommendations.

The EOIR experience so far of all the monitored jurisdictions is analysed below through:

• A discussion on the overall incoming and outgoing requests observed.

• An analysis of the peer input received, including:

  • Overall trends

  • Observations specific to monitored jurisdictions.

In total, over the 2023-2024 monitoring period, the 39 jurisdictions monitored so far received 18 493 requests for information and sent 19 921 such requests. While the statistics on timeliness of responding to incoming requests vary across jurisdictions, the following observations are made:

• On average, 70% of incoming requests were responded to within 90 days and a further 14% within six months.

• Improvement in the timeliness of providing responses to incoming requests resulted in the in-box recommendations on timeliness under Element C.5 for seven jurisdictions being “considered (provisionally) addressed”.14

• If a requested jurisdiction is unable to obtain and provide the information requested within 90 days of the receipt of a request, it should immediately inform the requesting partner, explaining the reason for its inability, the nature of the obstacles, or the reasons for its refusal, i.e. provide a status update on the request. Status updates were provided in 74% of all such cases across the 39 jurisdictions, with 11 jurisdictions doing it systematically, i.e. always providing status updates where responses could not be provided within 90 days. The general trend seen is an improvement in this regard as compared to previous years, i.e. communication between authorities is improving. In-box recommendations on status updates under Element C.5 were considered (provisionally) addressed for seven jurisdictions.15

• On both these aspects of timeliness and provision of status updates, 11 recommendations issued to nine monitored jurisdictions remain in the process of being addressed.16

A key driver of progress to deliver effective EOIR in practice is the engagement of exchange partners to address issues, including through monitoring and peer review processes.

In the context of the enhanced monitoring process, a total of 803 pieces of peer input were received from 53 jurisdictions that related to all jurisdictions covered under cycle 1. This is a very significant increase in the participation of Global Forum members in the provision of peer input on their EOI relationships. This demonstrates confidence in the enhanced monitoring process to deliver effective EOIR. Since 2021, when the submission of peer input was first introduced as part of the prior annual follow-up process, the submission of peer input has increased more than five times with the submission of peer input growing from 150 peer inputs in 2021, to 803 in 2025. What is most encouraging is the very high levels of positive input.

Most of the peer input on the monitored jurisdictions was positive, reflecting general satisfaction with the EOIR relationships. The proportion of peer input that was positive rose from 62% in 2021 to 79% in 2025. This trend is a testament of the positive EOIR relationships amongst Global Forum members.

Under the 2025 enhanced monitoring process, 17 members provided peer input for the first time (i.e. these members had not provided peer input under the earlier annual follow-up process). More generally, 35 members provided peer input on at least 5 EOI partners and 19 members provided peer input on more than 10 EOI partners, with some members providing input on a very significant number of their partners. This reflects a strong interest in the enhanced monitoring process and the confidence in its ability to deliver results.

In their peer input, peers indicated the significance of the jurisdiction reported upon relative to the peers’ overall EOIR experience. A fifth of all received peer input, i.e. 157 out of the 803 peer inputs was in respect of monitored jurisdictions that were among the top five EOI partners for the peer submitting the input. A further one-third (261 peer inputs) was in respect of what the peers considered standard partners, i.e. partners which may not have been among the top five in terms of volume, but with whom the peer had either a significant volume of exchange or with whom there were more than a few simple requests (sent or received). Thus, more than 50% of all peer input pertained to monitored jurisdictions where the volume or complexity of requests made them important EOIR partners. This reflects the strong interest by members to provide feedback on their EOIR relationships in such cases.

There was a substantial volume of peer input that was received where the peer did not have a significant volume of exchanges or, in some cases, no exchanges over the monitoring period. In some instances, the reporting peer wanted to raise matters such as difficulties in communication (something that is often noted amongst new EOI partners). Where such peer input did not raise a specific issue, it often still provided a degree of reassurance that the absence of requests between the reporting peer and the monitored jurisdiction was not due to any problems that the peer had encountered in the past or anticipated with respect to the jurisdiction that might have deterred it from making its requests.

In respect of the 39 monitored jurisdictions, 405 peer inputs from 48 peers were analysed. Across these reports, 70% of the peer input was positive and reflected general satisfaction. Seventeen per cent of the input reflected that there had not been any exchange of information between the reporting peer and the monitored jurisdiction and, hence, the EOIR relationship was untested during the monitoring period.

Some peer input raised matters indicating one or more areas of improvement for the monitored jurisdictions as 53 out of the 405 peer inputs (or 13%) raised at least one matter on which the response of the monitored jurisdiction was needed.

Based on the responses received from the jurisdictions, in respect of the 39 reports so far, 36 matters were identified to be bilateral matters that were resolved bilaterally, mainly on issues of communication, generally due to technical issues. This reflects that, upon receiving the peer input, monitored jurisdictions proactively resolved such bilateral matters.

Some of the issues raised by peers were already captured by recommendations issued to the monitored jurisdictions in their peer review, and which the jurisdictions reported were “in the process of being addressed”. Typically, these matters pertained to provision of status updates and the timeliness of providing responses. In respect of the 39 reports, there were five instances where the matters raised led to the detection of a systemic issue of compliance with the standard. These matters were presented to the assessment panel for its views, which were subsequently submitted to the PRMG for consideration.

In three cases, peer input on incoming requests received by the monitored jurisdictions suggested backsliding as the jurisdiction had a much better record of effective exchange of information at the time of their EOIR peer review reports. The jurisdictions were issued recommendations in this regard.17 In other instance, peer input raised a matter in relation to outgoing requests of the monitored jurisdiction, and the matter was not resolved bilaterally. The jurisdiction was recommended to ensure the provision of clarifications in a timely manner to its treaty partners.18 Further, another monitored jurisdiction has been recommended that it exchanges information in line with the standard once the requesting jurisdiction explains that there is a reasonable possibility that the requested information will be relevant in the context of its underlying investigation or examination.19