Four Reporting Regimes, One Transition: What the Income-tax Act, 2025 Changes for FATCA-CRS, SFT, PAN Quoting and Form 15CC

Four Reporting Regimes, One Transition: What the Income-tax Act, 2025 Changes for FATCA-CRS, SFT, PAN Quoting and Form 15CC

Most people never see an SFT return, a FATCA-CRS report, a PAN Quoting statement or a Form 15CC. They see what those filings produce: a line in their AIS, a question from their bank about a foreign remittance, a request to quote their PAN (or sign a declaration if they don't have one), or a FATCA-CRS self-certification form they don't quite understand. Each of these comes from reporting that banks, insurers, mutual funds, registrars, fintech platforms and many businesses file with the Income Tax Department every year. The high-value transactions you see in your AIS come from SFT reporting. Account details of foreign tax residents are reported under FATCA-CRS. Transactions made without a PAN are reported under PAN Quoting. Foreign remittances handled by authorised dealer banks are reported in Form 15CC.

When the Income-tax Act, 2025 replaced the Income-tax Act, 1961 on 1 April 2026, and the Income-tax Rules, 2026 (notified on 20 March 2026) replaced the 1962 Rules, all four of these reporting streams moved at the same time. Some changes are only renumbering. Others are real changes in scope and thresholds that will decide whether a transaction gets reported at all.

The overall shape of the new law is also leaner. The old Act had 819 sections, 511 rules and 399 forms. The new one has 536 sections across 23 chapters, 333 rules and 190 forms. For anyone who files or relies on these statements, that means most of the references in your templates, checklists and system screens are now out of date.

We have gone through the notified rules, the forms and the guidance the CBDT has released since April, and set out below what has changed in each stream, where the real work lies and what individuals and businesses should keep an eye on.

Old forms, new numbers

Before looking at what changed inside each stream, it helps to have the new references in one place. Keep this table handy, because you will see both sets of numbers for a while.

One point that is easy to forget: the old numbers do not disappear on 1 April 2026. Returns, corrections and notices that relate to FY 2025-26 and earlier years still refer to the 1961 Act and its forms. The new numbers apply from Tax Year 2026-27. So for at least a year or two, both sets will sit side by side in most offices.

FATCA and CRS: e-wallets, the digital rupee and crypto are now in scope

FATCA and CRS are how India shares information about financial accounts held by foreign tax residents with other countries, and how it receives similar information about Indians' accounts abroad. The reporting is done by Reporting Financial Institutions (RFIs). Until now, most people linked this only with banks, insurers, mutual funds and depositories. That list is now wider.

From Form 61B to Form 166

FATCA-CRS reporting now sits under Section 508 of the Income-tax Act, 2025, read with Rules 238 to 240 of the Income-tax Rules, 2026. The annual statement is Form 166, which replaces Form 61B from 1 April 2026. The due date has not moved: 31 May every year.

On 24 July 2026 the CBDT released a fully revised Guidance Note on FATCA and CRS. It replaces the version last updated in November 2016, reflects the new Act and Rules, and adds the OECD's 2025 consolidated CRS text. It also carries 100 FAQs, several of which deal with wallets, prepaid instruments, the digital rupee and crypto.

Who is newly covered

The 2025 amendments to the CRS added three things, all effective from 1 January 2026 for non-US accounts:

• Specified Electronic Money Products (SEMPs). An entity that holds e-money for customers is now treated as a Depository Institution. The Guidance Note says in plain terms that mobile wallet operators and e-money issuers holding SEMPs fall in this category.
• Central Bank Digital Currency (CBDC). An account holding the digital rupee (e₹) or any other CBDC for a customer is now a Financial Account. Entities that hold CBDC for retail customers are Depository Institutions for those accounts.
• Relevant crypto-assets. For CRS, "financial assets" now reads as "financial assets or relevant crypto-assets". An entity that invests, administers or manages crypto-assets for customers can become an Investment Entity. Interests in a fund that invests in crypto-assets can also be reportable accounts.

Not every wallet balance is caught. A product counts as a SEMP only if it is a digital form of a single fiat currency, issued against funds received, accepted by people other than the issuer, and redeemable at par on demand. The Guidance Note also discusses whether every prepaid payment instrument is automatically a SEMP, and it is not. That is a product-by-product assessment.

There is also a relief for small balances. A SEMP account is excluded if its rolling 90-day average end-of-day balance never exceeded USD 10,000 during the year. For most everyday wallet users, this exclusion will apply.

New dates for the new accounts

For these new account types, the old CRS dates of 2015 and 2016 do not apply. Instead:

In practice, this means anyone opening a wallet or e₹ account from January 2026 should expect to be asked for a tax-residency self-certification at onboarding, just as they would at a bank.

Six new fields in Form 166

Form 166 asks for more than Form 61B did. The new data elements are:

• 1. Whether a valid self-certification is on file for the account holder.
• 2. Whether the account is joint, and the number of joint holders.
• 3. The role of each Controlling Person, such as settlor, trustee, protector or beneficiary.
• 4. Whether a valid self-certification is on file for each Controlling Person.
• 5. The account type, and whether it is pre-existing or new.
• 6. For trusts and similar arrangements that are Investment Entities, the role through which each person holds an equity interest.

A separate framework for crypto platforms: CARF and Form 167

On the same day, the CBDT released a separate Guidance Note on Crypto-Asset Reporting Obligations. This puts in place India's version of the OECD's Crypto-Asset Reporting Framework (CARF).

A business that holds crypto for customers and also runs a crypto-to-fiat exchange could fall under both. The Guidance Note includes a non-duplication rule so the same information is not reported twice. It is worth reading FAQ 24 and FAQ 68 of the FATCA-CRS Guidance Note together with the CARF note before deciding which form covers what.

Penalties

SFT: Form 61A becomes Form 165, and PAN now decides the threshold

The Statement of Financial Transactions (SFT) is the main source of the high-value entries you see in your AIS. Banks, post offices, registrars, mutual funds, companies, insurers and others report specified transactions every year, and the department matches them against income tax returns.

Under the new law, Rule 114E is replaced by Rule 237 and Form 61A by Form 165, filed under Section 508(1). The purpose is the same. What has changed is how the thresholds work.

One threshold for PAN holders, a lower one for everyone else

For several transactions, Rule 237 now sets two limits: one where the person has a PAN, and a lower one where they do not. The thinking is simple. If there is no PAN to match against, the department wants to see the transaction earlier.

The property threshold is the only one that has gone up. Moving from ₹30 lakh to ₹45 lakh takes a large number of smaller property deals out of SFT reporting. The same ₹45 lakh limit now also covers gifts of property and joint development agreements, which were not separately tracked before.

New transactions that are now reported

Not every SFT is annual any more

Most SFT categories are still filed once a year, by 31 May. But SFT for listed securities and mutual fund units is now reported half-yearly. That data is also used to pre-fill the capital gains schedule in the ITR. If your organisation deals in securities, runs a depository or distributes mutual funds, the reporting calendar now has two cycles, not one.

Penalty is now a capped fee

The late-filing penalty has been restructured as a fee. It is still ₹500 a day before a notice and ₹1,000 a day after it, but the total is now capped at ₹1 lakh per default. The separate ₹50,000 penalty for inaccurate information or failure to follow due diligence continues, and it is not capped. Note that this capped structure applies to SFT. It should not be assumed for Form 166, which has its own penalty provisions, set out above.

What it means for you as a taxpayer

Transactions without PAN: Rule 159, Form 97 and Form 98

The rule that tells you when you must quote your PAN was Rule 114B. It is now Rule 159, made under Section 262 of the new Act. It is not just a renumbering. The old rule was a table with provisos. The new one has a detailed table, eight sub-rules, and it names who is responsible for collecting the PAN in each case, for example the bank manager, the principal officer or the registrar.

The limits that changed

The cash deposit change will be felt most widely. Earlier, anyone depositing more than ₹50,000 in cash on a single day had to give a PAN or a Form 60. Now the test is annual. Day-to-day cash handling becomes simpler, but banks and post offices will need to track each customer's deposits and withdrawals over the whole year. Cash withdrawals appear in this rule for the first time.

What stays the same

The limits for most investment and banking transactions are broadly unchanged. These include credit card applications, opening a demat account, payments above ₹50,000 to mutual funds, for bonds or debentures and for RBI bonds, securities transactions above ₹1 lakh, time deposits above ₹50,000 each or ₹5 lakh in a year, and sale or purchase of goods or services above ₹2 lakh. On insurance, the new rule is framed around starting an account-based relationship with an insurer, so insurers should check the exact entry in Rule 159 against their own products.

What has been dropped

Some items that were in Rule 114B are not in Rule 159:

• Payments for foreign travel and for buying foreign currency
• Cash purchase of bank drafts, pay orders and banker's cheques
• Prepaid payment instruments
• The provisions added during demonetisation

Dropping these from the PAN-quoting rule does not mean they have left the reporting net altogether. Foreign exchange and cash purchase of drafts are still covered by SFT, with the PAN and no-PAN thresholds described above.

Form 60 is now Form 97, and Form 61 is now Form 98

If you do not have a PAN and enter into one of these transactions, you give a declaration. That declaration was Form 60. It is now Form 97. The entity that receives Form 97 declarations reports them in Form 98, which replaces Form 61. Form 98 is filed half-yearly on the Reporting Portal: by 31 October for April to September, and by 30 April for October to March.

Form 98 is also a much larger return than Form 61. It asks for the district, identity, address and date-of-birth proofs, joint-holder details and the cash component of the transaction. The Transaction Type codes have also been redefined, so the same number now means a different transaction. We have covered this in detail in our earlier article on Form 98.

A declaration alone is no longer the end of it

The biggest shift in Rule 159 is this. Earlier, a person without a PAN could give Form 60 and complete the transaction. Now, a person entering a specified transaction without a PAN must also apply for one. Entities that accept Form 97 have to make sure PAN is quoted correctly, keep proper records and link the PAN or Form 97 to their reporting. Rule 159 does not, however, require an institution to block the transaction until the PAN is allotted. The practical approach is to flag the transaction and obtain the PAN application acknowledgement in accordance with Rule 159.

For customers, this means you will increasingly be asked for proof that you have applied for a PAN, such as the acknowledgement number, and not just a signed declaration. Once the PAN is allotted, share it with every institution where you gave Form 97, so their records and your AIS line up.

Foreign remittances: Form 15CC is now Form 147

Anyone who has sent money abroad for a business payment knows the Form 15CA and 15CB routine. Behind it sits a third form most people never see: the quarterly statement in which the authorised dealer reports every remittance it has processed. That was Form 15CC. It is now Form 147, under Rule 220 of the Income-tax Rules, 2026 (earlier Rule 37BB), read with Sections 393, 397 and 462 of the new Act. The filing obligations, forms and exempt categories below are verified against Rule 220 of the Income-tax Rules, 2026.

The four forms, renumbered

Payments that do not need Form 145

As per Rule 220(3), no Form 145 is required for a sum not chargeable to tax in three cases:

• A remittance by an individual that does not need prior RBI approval under FEMA.
• A remittance by a unit in an International Financial Services Centre.
• A remittance falling under one of the 33 RBI purpose codes listed in the rule. These cover overseas investment, loans to non-residents, imports, travel, education, freight insurance, embassy expenses, gifts and donations, and tax refunds, among others.

The list includes five import-related purpose codes, which matter to almost every business that pays foreign suppliers:

What is new in Form 147

The filing rhythm has not changed, but the form now asks for more. Based on the CBDT's Form 147 guidance and FAQs, most of the new fields are aimed at tying each remittance to its Form 145 and to the person who received the money.

• Form 145 acknowledgement number. Each remittance must now carry the acknowledgement number of the Form 145 filed for it. This creates a one-to-one link between what the payer declared and what the authorised dealer reports.
• A code where Form 145 was not needed. If the payment falls in an exempt category, the authorised dealer enters a prescribed code explaining why no Form 145 was filed. A blank is not acceptable.
• Taxpayer Identification Number (TIN) of the recipient. Where the recipient has no PAN, their TIN from their country of residence is to be given.
• Full details of the receiving account. The form now asks for the particulars of the account to which the money was sent, not just a payment reference.
• Aadhaar fields removed. Aadhaar details of the remitter and remittee are no longer part of the form.

Due dates, filing and penalty

Form 147 is filed online on the e-filing portal, using the authorised dealer's ITDREIN, and verified with a Digital Signature Certificate. Once submitted, it cannot be edited or withdrawn. That makes checking before submission far more important than it was for filings that could be revised. The Department's FAQs state that failure to file by the due date can attract a penalty of up to ₹1 lakh under Section 462.

What it means if you send money abroad

Dates to keep in mind

Where the real work lies

Much of this transition looks like paperwork: new section numbers, new form numbers. The parts that actually take effort are fewer, but they need attention now rather than a week before the next due date.

If your organisation files these returns

1. 1

   Check whether you are now a reporting entity.

   • Wallet operators, e-money issuers, entities holding the digital rupee for customers and crypto platforms should work through the classification steps in the two Guidance Notes. Some will be Reporting Financial Institutions, some will be RCASPs, and a few will be both.
2. 2

   Rebuild the threshold checks.

   • SFT now needs a PAN and a no-PAN limit for several transactions. Rule 159 needs a full-year view of each customer's cash deposits and withdrawals. Both are structural changes, not a matter of editing a number.
3. 3

   Collect the new data at onboarding.

   • Self-certification flags, joint-holder counts, Controlling Person roles, foreign TINs and Form 145 acknowledgement numbers are far easier to capture when the account is opened or the payment is made than to chase later.
4. 4

   Replace Form 60 with Form 97 everywhere.

   • That includes account-opening kits, branch or counter checklists, and the reports that feed Form 98.
5. 5

   Add a review step before Form 147 is submitted.

   • Since it cannot be edited or withdrawn, a maker-checker check before filing is the only safety net.
6. 6

   Keep the old references alive for old periods.

   • Corrections and notices for FY 2025-26 and earlier will still come under the 1961 Act and the old form numbers.

If you are an individual or a business owner

• Check your AIS at least once a year, and give feedback on anything that is not yours or is wrong.
• If you do not have a PAN, get one. Under Rule 159 you will be asked to apply anyway, and without a PAN several SFT limits are halved.
• If a bank, wallet, insurer or crypto platform asks you for a tax-residency self-certification, fill it in carefully. It is routine, and an incomplete form can make your account reportable by default.
• If you are a tax resident of another country, expect your account information, including wallet and crypto balances above the thresholds, to be shared with that country's tax authority.
• Before sending money abroad, keep your Form 145 acknowledgement, the recipient's TIN and full account details ready.

Final thoughts

It is tempting to treat the new Act as a find-and-replace exercise: 61B becomes 166, 61A becomes 165, 15CC becomes 147. For much of the text in forms and manuals, that is all it is.

The real changes are narrower but deeper. E-wallets, the digital rupee and crypto have joined the list of reportable accounts. PAN status now decides when a transaction gets reported. Cash is watched over a whole year rather than a single day. And every foreign remittance now has to line up with its own Form 145. Those are the areas where a quiet mistake today turns into a notice two years from now.

If you file any of these returns, start with the Guidance Notes and your own data. If you are on the other side of the counter, keep your PAN, your self-certifications and your AIS in order. Either way, the information trail is getting longer, and it pays to know what is in it.

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