New Information about the QI and FATCA Responsible Officer Certifications

As we notified in our newsletter "Extension of the QI Responsible Officer Certification Deadlines", the IRS extended the certification deadline for QIs with the certification period 2018-2020 which apply for a waiver or have a QI periodic review performed for years 2018 or 2019 until December 1, 2021 (previously July 1, 2021). Equally, QIs with the same 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 IRS informed that the extensions are automatic and require no further action by the QI.

However, several QIs nevertheless received notifications from the QI/WP/WT system stating that their QI certification was due or overdue. We assume this to be a technical error. We nevertheless recommend, before the initial deadline of July 1, 2021, to start the periodic certification, select the periodic review year in the QI/WP/WT system and then close the certification without submitting it. The system should at that point show an updated "Extended Certification Due Date" for those QIs for which it previously did not. For additional information, please see our QI Responsible Officer Certification FAQ.

As the IRS did not announce any extension of the FATCA certification deadline for certain registered FFIs (such as Reporting Model 2 FFIs, Participating FFIs or Sponsoring FFIs) with the certification period 2018-2020, we would like to remind Responsible Officers of these FFIs that they will be required to perform a Periodic Certification by July 1, 2021.

For more information regarding the FATCA Certification, please refer to our FATCA Responsible Officer Certification FAQ.