The 2026 FATCA reporting season brings important IRS system updates that Model 2 fund managers and Responsible Officers cannot afford to overlook. This guide outlines key actions to take now – from portal access and encryption keys to recertification and investor documentation – to ensure timely and accurate reporting.

Fund managers entering Model 2 jurisdictions face complex FATCA obligations—from due diligence and onboarding to IRS reporting and re-certification. This guide breaks down key requirements, responsibilities, and deadlines to help funds establish a compliant and efficient FATCA program.