2026 FATCA Reporting for Model 2 Funds – IRS Updates and Actions for Fund Managers

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Rudo Mugwagwa

Rudo advises on investment funds, corporate, and cross-border compliance matters, with experience across fund formation, governance, and investor-side advisory.

The U.S. Foreign Account Tax Compliance Act (“U.S. FATCA“) reporting season is fast approaching, and early preparation remains critical for investment funds. In advance of filings, fund managers and their designated FATCA Responsible Officer (“Responsible Officer“) should take note of recent Internal Revenue Services (“IRS”) updates and use the questions below to guide their preparation.

Have you updated your FATCA Portal login credentials?

The IRS has updated the FATCA Portal to streamline login credentials across the IRS reporting systems. Responsible Officers now access the FATCA Portal through Login.gov or ID.me, using a single login for all entities under their oversight. Fund managers should confirm that credentials are active and that all relevant are correctly listed under their profile.

The IRS issued a new public key for FATCA report transmission on the International Data Exchange System Portal (“IDES Portal”) in October. Filers must download and use the new key for the upcoming deadline to ensure successful report submission. 

Under the Foreign Financial Institution (“FFI”) Agreement, the Responsible Officer must recertify the FFI’s status every three years. The Responsible Officer should confirm whether the upcoming season is a recertification year and ensure before the annual reporting deadline.

Responsible Officers should confirm access to both the FATCA portal and IDES Portal early in the season. Access should be validated for internal compliance teams and thirdparty service providers that are engaged to support reporting. Given recent system changes, the Responsible Officer should verify that portal logins have transitioned to the authentication system and establish a secure process for sharing access details where appropriate.   

Fund managers should confirm that administrator, tax agents and other service providers have been informed of any material developments including, but not limited to, any restructuring, key officer changes, compliance program updates and investor changes. Early coordination ensure all relevant updates are captured for accurate reporting, particularly where classification account data may be affected.

FATCA obligations require FFs to identify all accounts to determine which are U.S. accounts under the Model IGA framework and FFI AgreementResponsible Officers should confirm that investor documentation remains complete and accurate, and that controls are in place to capture updates to investor tax resident and profile data. 

For tailored assistance with Model IGA obligations, including IDES submission and Responsible Officer certifications, Basswood can assist

New to FATCA? Our Model 2 IGA FAQ for first-time fund managers is available here.

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