Extension of the QI Responsible Officer Certification Deadlines

As per the IRS QI FAQ, the IRS just extended the deadline for QIs certifying the full three-year certification period 2018-2020.

Responsible Officers of QIs with the certification period 2018-2020 which request a waiver or have a QI periodic review performed for years 2018 or 2019 will now have to perform the certification until December 1, 2021, (previously July 1, 2021). Equally, QIs with that certification period which have a QI periodic review performed for the year 2020 will now have to certify until March 1, 2022, (previously December 31, 2021). The extensions are automatic and require no further action by the QI.

Please note that these extensions only apply to QIs performing a certification for a full three-year period (and e.g. not to QIs performing a final certification after terminating the QI Agreement). We would also like to point out that the IRS has not updated Question 9 of the FAQ where they still reference the July 1, 2021, deadline, but we think that the answers given to that question also imply that the extended deadlines apply.

Until now, we have not heard of any extension of the FATCA certification deadline for Reporting Model 2 FFIs and Participating FFIs certifying the period 2018-2020. Should the IRS decide to extend that deadline as well, we will inform you again via this channel.

We have updated our QI Responsible Officer Certification FAQ accordingly.