The self-certification is the cornerstone of CARF due diligence. This guide explains how to design effective self-certification forms and implement robust collection processes.

Purpose of Self-Certification

Self-certification serves as the primary mechanism for determining a user's tax residency. While CASPs could theoretically determine residency through other means, self-certification provides a standardized, auditable approach that places appropriate responsibility on users for accurate declarations.

Required Elements

For Individual Users

  • Legal name (first name, middle name(s), last name)
  • Current residence address (street, city, country, postal code)
  • Date of birth
  • Place of birth (if TIN unavailable)
  • Country/ies of tax residence
  • TIN for each country of tax residence
  • Reason if TIN unavailable
  • Certification statement
  • Signature and date

For Entity Users

  • Legal name of entity
  • Registered address
  • Country of incorporation/organization
  • Country/ies of tax residence
  • Entity TIN
  • Entity type classification (Active NFE, Passive NFE, Financial Institution)
  • Controlling person information (for Passive NFEs)
  • Authorized signatory details
Multiple Tax Residencies

Users may be tax resident in multiple jurisdictions simultaneously. Your form must allow for multiple residency declarations with corresponding TINs for each.

Collection Methods

Digital Collection

Most CASPs implement digital self-certification:

  • Integrated into onboarding flow
  • Dynamic forms based on user type
  • Real-time TIN format validation
  • Electronic signature capture
  • Automatic storage and retrieval

Paper Forms

Some situations may require paper forms:

  • Users unable to complete digital process
  • Complex entity structures
  • Remediation of existing users

Validation Process

Completeness Check

Verify all required fields are completed before acceptance.

Format Validation

Validate TIN formats against jurisdiction-specific rules.

Reasonableness Check

Compare declared information against:

  • Address on identity documents
  • Phone number country codes
  • Payment method jurisdictions
  • IP address geolocation
Reasonableness Failures

When declared information conflicts with other data, you must resolve the inconsistency before accepting the self-certification. This may require additional documentation from the user.

Common Issues

  • Multiple residencies: Users may be tax resident in multiple jurisdictions—collect all
  • TIN unavailability: Some jurisdictions don't issue TINs—document reason
  • Refusal to certify: Cannot onboard users who refuse self-certification
  • Inconsistent information: Must resolve before accepting

Conclusion

Well-designed self-certification processes reduce compliance burden while ensuring data quality. Invest in user-friendly digital forms with robust validation to minimize remediation needs.

Automate CARF Compliance

Self-certification, TIN validation, transaction reporting, and XML generation for 76 jurisdictions.

Expert Consulting