Date: 2025-10-17Category: Not ApplicableState: Union GovernmentCountry: Europe
Council Decision (EU) 2025/2125 of 10 October 2025 on the signing, on behalf of the Union, of the Amending Protocol to the Agreement between the European Union and the Principality of Monaco on the exchange of financial account information to improve international tax compliance in accordance with the Standard for Automatic Exchange of Financial Account Information in Tax Matters developed by the Organisation for Economic Cooperation and Development (OECD)
**Executive Summary**
The Council Decision (EU) 2025/2125, dated 10 October 2025, authorises the signing, on behalf of the Union, of the Amending Protocol to the Agreement between the European Union and the Principality of Monaco regarding the exchange of financial account information for improved international tax compliance, as developed by the OECD. The Amending Protocol aims to incorporate changes to the Common Reporting Standard (CRS) and should be signed on behalf of the Union and approved. This decision enters into force on the date of its adoption.
**Key Points / Main Content**
* **Background and Purpose:**
* The existing agreement between the EU and Monaco has enhanced mutual assistance in tax matters.
* The Amending Protocol reflects changes to the Common Reporting Standard (CRS) approved at the international level on 26 August 2022.
* The Protocol's text reflects negotiating directives issued by the Council.
* **Scope and Changes:**
* The Amending Protocol expands the scope of reporting for CRS to include new digital financial products like Specified Electronic Money Products and Central Bank Digital Currencies.
* It introduces more detailed reporting requirements and strengthens due-diligence procedures.
* Updates references to data protection legislation and applicable data protection safeguards.
* **Authorization and Approval:**
* The signing of the Amending Protocol on behalf of the Union is authorized, contingent upon its conclusion.
* Joint Declarations attached to the Amending Protocol are approved on behalf of the Union.
* **Entry into Force:**
* The Decision enters into force on the date of its adoption.
**Impact Analysis**
**European Union**
* **Impact:** Ensures that the Union complies with updated international standards for automatic exchange of financial account information, combating tax evasion and promoting fair taxation.
* **Action Required:** Proceed with signing the Amending Protocol and publishing the text along with the decision on its conclusion.
**Principality of Monaco**
* **Impact:** Aligns Monaco's financial reporting practices with updated international standards, enhancing its cooperation with the EU on tax matters.
* **Action Required:** Implement the changes outlined in the Amending Protocol, including expanding the scope of reporting and strengthening due-diligence procedures.
**Taxpayers and Financial Institutions**
* **Impact:** Subject to more detailed reporting requirements and stricter due-diligence procedures related to digital financial products and financial accounts.
* **Action Required:** Understand and comply with the new reporting obligations and provide necessary information to financial institutions as required.
Key Entities Referenced
Organisation for Economic Cooperation and Development (OECD): Developer of the Standard for Automatic Exchange of Financial Account Information in Tax Matters referenced in the agreement.
Amending Protocol to the Agreement between the European Union and the Principality of Monaco: Modifies an existing agreement on exchange of financial account information to improve international tax compliance, incorporating changes to the Common Reporting Standard (CRS).
Common Reporting Standard (CRS): The global standard for automatic exchange of financial account information, which is being updated and incorporated into the agreement.
Principality of Monaco: One of the parties involved in the agreement.
European Union: One of the parties involved in the agreement.
Official Journal EN
of the European Union L series
2025/2125 17.10.2025
COUNCIL DECISION (EU) 2025/2125
of 10 October 2025
on the signing, on behalf of the Union, of the Amending Protocol to the Agreement between the
European Union and the Principality of Monaco on the exchange of financial account information to
improve international tax compliance in accordance with the Standard for Automatic Exchange of
Financial Account Information in Tax Matters developed by the Organisation for Economic
Cooperation and Development (OECD)
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union, and in particular Article 115, in conjunction with
Article 218(5) and Article 218(8), second subparagraph, thereof,
Having regard to the proposal from the European Commission,
Whereas:
(1) The Agreement between the European Union and the Principality of Monaco on the exchange of financial account
information to improve international tax compliance in accordance with the Standard for Automatic Exchange of
Financial Account Information in Tax Matters developed by the Organisation for Economic Cooperation and
Development (OECD)(1) (‘the Agreement’) has enhanced mutual assistance in tax matters between the Contracting
Parties and improved international tax compliance.
(2) Important changes to the Common Reporting Standard (CRS) of the Organisation for Economic Cooperation and
Development were approved at international level on 26 August 2022 and were incorporated into Union law by
means of Council Directive (EU) 2023/2226(2), which amended Council Directive 2011/16/EU(3).
(3) On 21 May 2024, the Council authorised the Commission to open negotiations with the Principality of Monaco for
an amendment of the Agreement to reflect the changes to the CRS approved at the international level. The
negotiations were successfully concluded with the initialling of the Amending Protocol to the Agreement between
the European Union and the Principality of Monaco on the exchange of financial account information to improve
international tax compliance in accordance with the Standard for the Automatic Exchange of Financial Account
Information in Tax Matters developed by the Organisation for Economic Cooperation and Development (OECD)
(‘the Amending Protocol’).
(4) The Amending Protocol expands the scope of reporting for the CRS to include new digital financial products, such
as Specified Electronic Money Products and Central Bank Digital Currencies, while simultaneously introducing
more-detailed reporting requirements and strengthened due-diligence procedures. It also updates the references to
the data protection legislation of the Contracting Parties and the applicable data protection safeguards.
(5) The text of the Amending Protocol, which is the result of the negotiations, duly reflects the negotiating directives
issued by the Council.
(6) Therefore, the Amending Protocol should be signed on behalf of the Union and the Joint Declarations attached to the
Amending Protocol should be approved.
(1) OJ L 19, 21.1.2005, p. 55, ELI: http://data.europa.eu/eli/agree_internation/2005/44(1)/oj.
(2) Council Directive (EU) 2023/2226 of 17 October 2023 amending Directive 2011/16/EU on administrative cooperation in the field
of taxation (OJ L, 2023/2226, 24.10.2023, ELI: http://data.europa.eu/eli/dir/2023/2226/oj).
(3) Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation and repealing Directive
77/799/EEC (OJ L 64, 11.3.2011, p. 1, ELI: http://data.europa.eu/eli/dir/2011/16/oj).
ELI: http://data.europa.eu/eli/dec/2025/2125/oj 1/2EN
OJ L, 17.10.2025
(7) The European Data Protection Supervisor was consulted in accordance with Article 42(1) of Regulation (EU)
2018/1725 of the European Parliament and of the Council(4),
HAS ADOPTED THIS DECISION:
Article 1
The signing of the Amending Protocol to the Agreement between the European Union and the Principality of Monaco on
the exchange of financial account information to improve international tax compliance in accordance with the Standard for
Automatic Exchange of Financial Account Information in Tax Matters developed by the Organisation for Economic
Cooperation and Development is hereby authorised on behalf of the Union, subject to the conclusion of the said Amending
Protocol(5).
Article 2
The Joint Declaration of the Contracting Parties on the Agreement and the Annexes, the Joint Declaration of the
Contracting Parties on Article 5 of the Agreement and the Joint Declaration of the Contracting Parties on the entry into
force and implementation of the Amending Protocol are hereby approved on behalf of the Union.
Article 3
This Decision shall enter into force on the date of its adoption.
Done at Luxembourg, 10 October 2025.
For the Council
The President
S. LOSE
(4) Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural
persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free
movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39,
ELI: http://data.europa.eu/eli/reg/2018/1725/oj).
(5) The text of the Amending Protocol will be published together with the decision on its conclusion.
2/2 ELI: http://data.europa.eu/eli/dec/2025/2125/oj