FATCA timeline

according to the Final Treasury Regulations*

21.05.2015

* the timeline may differ for Financial Institutions under IGA

2013
17 January 2013Final FATCA regulations issued
19 August 2013FATCA registration portal opening
10 September 2013FATCA technical corrections to the final regulations issued
2014
1 January 2014Earliest day to finalise the registration with the IRS (no information populated on the website is considered final before this day). The Global Intermediary Identification Number (GIIN) assigned to registered FFIs upon approval.
5 May 2014Deadline to register with IRS to ensure inclusion in the first web published FFI List.
2 June 2014First List of participating FFI (PFFI) and registered deemed-compliant FFI (with assigned GIIN) to be published on the web by the IRS (updated list will be published monthly from then on)
30 June 2014Expiration of the validity extension of:
- Chapter 3 Documentation: W-8 forms and other documentary evidence
- QI, WP and WT agreements
that would otherwise have expired on 31 December 2013.
Earliest effective date of an FFI Agreement.
1 July 2014Begin FATCA withholding on U.S. source FDAP for accounts identified as non-participating FFIs, non-compliant NFFEs and recalcitrant account holders (new accounts and pre-existing accounts documented as non-FATCA compliant).
Cut-off date for Grandfathered Obligations.
Enhanced account opening procedures must be in place to include FATCA due diligence for New Accounts; deadline is the later of either 1 July 2014 or the effective date of the FFI Agreement.
31 December 2014Deadline for FFIs to complete due diligence on pre-existing entity account holders that are held by Prima Facie FFIs. *
2015
1 January 2015Begin FATCA withholding on U.S. source FDAP on pre-existing entity account holders that are Prima Facie FFIs.*
15 March 2015First FATCA reporting due on Form 1042-S for U.S. source FDAP income for calendar year 2014.
31 March 2015Limited FATCA reporting due on Form 8966 for calendar year 2014 for U.S. accounts, and first FATCA aggregated reporting on Form 8966 for recalcitrant accounts.
30 June 2015Deadline for FFIs to complete due diligence on pre-existing high-value individual accounts. *
2016
1 January 2016End of transitional period for limited FFI or limited branches in Expanded Affiliated Group.
Sponsored FFIs may no longer provide the GIIN from its sponsoring entity, but must obtain its own.
15 March 2016FATCA reporting due on Form 1042-S for calendar year 2015
- for U.S. source FDAP income (annual), and
- aggregated for foreign reportable amounts paid to NPFFIs (for calendar year 2015 and 2016 only)
31 March 2016FATCA reporting due on Form 8966 for calendar year 2015, including income payments
30 June 2016Deadline for FFIs to complete due diligence on pre-existing low-value individual accounts and pre-existing entity accounts not identified as Prima Facie FFIs.*
1 July 2016Begin FATCA withholding on U.S. source FDAP on pre-existing low-value individual accounts and pre-existing entity accounts not identified as Prima Facie FFIs.*
31 December 2016Pre-FATCA Form W-8 validity expires for certain payees
2017
1 January 2017Begin FATCA withholding on non-compliant accounts for gross proceeds payments.
FATCA withholding expected to begin for foreign pass-thru (currently reserved)
15 March 2017FATCA reporting due on Form 1042-S for calendar year 2016
- for US source FDAP income (annual), and
- aggregated for foreign reportable amounts paid to NPFFIs (for calendar year 2015 and 2016 only)
31 March 2017Full FATCA reporting due on Form 8966 for calendar year 2016

* These dates assume that the PFFI's FFI Agreement is approved by the IRS and effective on 30 June 2014.