AEOI Under Pressure: Why Automation is Now a Governance Imperative
The new reality of AEOI
Automatic Exchange of Information (AEOI) reporting has entered a new era.
As CRS 2.0 and the Crypto-Asset Reporting Framework (CARF) come into force, fiduciary businesses face exponentially higher expectations around data quality, traceability, and Board-level oversight.
Jersey’s Comptroller of Revenue has made it clear: AEOI failures are no longer treated as administrative slip-ups, but as governance weaknesses. The regulator now expects firms to demonstrate, on demand, how classifications were derived, who approved them, and when controls were last tested.
For many trust companies and fund administrators, this creates a familiar pain point:
manual spreadsheets, opaque data flows, and inconsistent reporting across service providers.
The eight recurring failures
A recent industry audit highlighted the same issues repeating across firms:
Lack of visibility between operational teams and Boards, no evidence of AEOI oversight on statutory records.
Misclassification or reliance on outdated CRS categories with vague rationales.
Missed FI registrations causing knock-on reporting errors.
Over-reliance on administrators without clear SLAs or monitoring evidence.
Out-of-date documentation and uncontrolled procedural drift.
Missing internal control sign-off for reporting outputs.
No monitoring or escalation policy when data is modified post-submission.
Loss of data access following administrator changes.
These are not esoteric compliance failures, they are data management failures. And that means the solution is technological, not bureaucratic.
From compliance burden to data assurance
Continuum has developed an AEOI Assurance Platform, built on Alteryx, to give fiduciary Boards exactly what regulators are demanding: visibility, validation, and verifiable governance.
Using a low-code data automation engine, the platform connects to existing trust and fund systems (NavOne, ViewPoint, TrustQuay, or in-house SQL databases) and performs continuous, rules-based testing of every AEOI dataset before submission.
Key capabilities include:
Entity Classification Engine
Automatically validates each entity against current OECD and local CRS definitions, flagging conflicts or missing rationales.
Audit-Ready Lineage Dashboards
Every transformation, from raw data to submission file, is timestamped and traceable, giving Boards and auditors a full digital paper trail.
Registration & Submission Tracker
Ensures no FI is missed; integrates with regulatory portals and internal registers.
Digital Sign-Off Workflow
Embeds mandatory “Responsible Officer” approval checkpoints directly within the data pipeline, producing immutable evidence of review.
Continuous Monitoring & Alerts
Scheduled testing and exception reporting maintain compliance even when administrators or systems change.
Why CTOs should care
This is not just a compliance problem, it’s an information architecture problem.
Most fiduciary firms are sitting on multiple generations of client-data systems, stitched together through manual exports and Excel-based macros. Each additional layer of manual intervention increases the probability of classification error and data loss.
By re-platforming AEOI into an automated workflow, CTOs can finally integrate data quality assurance into their broader digital transformation programmes using the same tools already proven in financial reporting, AML remediation, and fund accounting.
Why CEOs and Boards should care
Regulatory penalties are only part of the risk. The greater danger lies in reputational damage.
A single failed AEOI submission, or a missing audit trail of how data was approved, can expose a fiduciary firm to scrutiny that far outweighs any monetary fine.
Automation provides something human processes cannot: objective evidence.
When Revenue Jersey or a global client asks, “Show us how this classification was derived,” the answer can be produced in seconds, not weeks.
The shift from reactive to proactive governance
AEOI assurance is no longer about getting the file out on time.
It’s about building a living compliance system, one that updates classifications automatically, records every change, and allows Boards to prove supervision.
As CRS 2.0 expands into e-money, central bank digital currencies, and crypto-linked products, the firms that survive regulatory tightening will be those that have invested in transparent, data-driven infrastructure.
The call to action
Continuum is now partnering with Channel Islands fiduciary groups to pilot the AEOI Assurance Platform ahead of CRS 2.0 implementation in 2026.
Automation doesn’t replace governance, it makes it visible.
Boards need proof, not promises. That’s exactly what we deliver