FATCA IDES technical FAQs

System that allows IRS to exchange taxpayer information with foreign tax authorities. An overview of data transmission to the IDES system is currently available on the IRS website at FATCA International Data Exchange Resources and Support Information (IDES).

Updated: 02-20-2015

System that allows IRS to send/receive, process, store, and manage FATCA data received from various sources to support needed compliance activities.

Updated: 02-20-2015

IDES issues email alerts via unsecured, plain-text email and they contain information about the transmission processing within the IDES system. An ICMM notification is a “transmission” file archive that contains encrypted documents that are sent from the United States Internal Revenue Service (IRS) to a Foreign Financial Institution (FFI), direct reporting non-financial foreign entity (NFFE), or Host Country Tax Authority (HCTA) in response to the transmission of a FATCA report submitted on the Intergovernmental FATCA XML schema or the paper Form 8966.

Added: 05-08-2015

The transmission can occur on the ad-hoc basis as HCTA receives the information from FFIs, or the HCTA can provide a single submission at or before the submission date and time as specified in the IGA. This applies to all jurisdictions.

Standards for request and/or response to information requests are defined in the IGAs and the Competent Authority Arrangement (CAA).

Updated: 02-20-2015

All data provided should fully comply with the most recent FATCA XML schemas posted on IRS.gov. The schema user guides describe fields that are mandatory for FATCA reporting.

Updated: 03-01-2018

The IRS publishes this information on the FATCA site on IRS.gov making it universally available at the same time. Additionally, users can subscribe to the FATCA newsletter for updates on the latest IRS news, guidance, regulations and other public information related to FATCA.

Updated: 02-20-2015

The IDES vendor will provide help desk support under their contract with the IRS during testing to address technical issues related to the use of IDES. For testing related issues, the IDES help desk can be reached at testing@ides-support.com. If you have any particular issues related to data preparation, you can submit an email to lbi.fatca.ides@irs.gov.

Updated: 06-08-2015

The IDES vendor will be responsible for resolving technical issues or questions regarding IDES. The IDES help desk can be reached at 800-613-IDES (4337), 605-271-0311, or via email at questions@ides-support.com.

Updated: 02-20-2015

The HCTA should direct questions regarding reporting requirements to the United States Competent Authority.

The IDES enrollment site is now open and can be accessed at IDES enrollment. For HCTAs, once you receive your enrollment letter from the IRS, it will include HCTA-specific instructions to enroll.

Updated: 02-20-2015

No, GIINs are specific to financial institutions, direct reporting NFFEs, and sponsoring entities. However, when an HCTA enrolls, they will receive a FATCA entity ID number, which resembles a GIIN. For example, the FATCA entity ID number of the IRS is 000000.00000.TA.840.

Added: 02-20-2015

IDES will not be providing an API or application for data encryption and transmission. The file format has been described and the file preparation guide has been published on IRS.gov to assist users. There are currently samples of data preparation code available on GitHub in the IRS.gov repository.

Updated 07-14-2015

The IRS developed a process that allows you to use IDES. You will obtain a second GIIN that reflects that you are located in a Model 2 or non-IGA jurisdiction. 

1. Enter the IRS registration portal and create a new account.

2. Select the Financial Institution Type, Sponsoring Entity and click Next to continue.

3. Complete other questions and proceed to Part 1, Questions 3A-4.

• Question 3: Select Financial Institutions Country of Residence, Other.
• Question 3B: Enter your financial institution’s country/jurisdiction tax ID, if available.
• Question 4: Select the Financial Institution’s classification in its jurisdiction of tax residence, None of the Above.

4. Complete the application and other entries as you did originally.

After the approved GIIN appears on the FFI list, use the GIIN to enroll in IDES. Detailed information on IDES enrollment process can be found at https://www.ides-support.com/.

Updated: 07-28-2015

The general guidelines for rounding are the same in the instructions to Form 8966 and the schema. In the instructions to Form 8966, you may round fractional currency amounts up (or down) to the closest non-fractional (whole) currency amount. If you choose to round currency amounts, you must round all currency amounts reported. The schema defines the format of the money amount; it does not address the general accounting practices to round off to the whole amount.

The schema allows whole numbers and decimal numbers with 2 fraction digits (e.g. 12345, 12345.76 and 12345.7 are valid amounts). If an amount has more than 2 fraction digits, the amount will be invalid (e.g. 12345.768 is invalid amount).

Added: 07-14-2015

IDES only accepts FATCA XML schema v2.0 files, as of January 2017, and files submitted using other than version 2.0 of the schema will generate error notifications. More information is available on the FATCA XML schemas and business rules for Form 8966 page.

The IRS will conduct open user testing for all FATCA filers biannually. User participation in IDES open testing is voluntary. In order to participate in testing, you need to have an active password. All passwords and profile information should be updated BEFORE the enrollment cutoff. Users should also verify the digital certificate uploaded to IDES for their organization is valid. All testing sessions will be announced on the IDES testing schedule page.

Updated: 12-03-2019

The IRS developed a process that allows you to use IDES. You will obtain a second GIIN that reflects an "Other" country/jurisdiction of residence instead of a Model 1 IGA jurisdiction.

1. Enter the IRS registration portal and create a new account.

2. Select the Financial Institution Type "Single" and click Next

3. Complete other questions and proceed to Part 1, Questions 3A-4.to continue.

• Question 3A: Select Financial Institution's country/jurisdiction of residence for tax purposes: "Other".
• Question 3B: Enter your financial institution's country/jurisdiction tax ID.
• Question 4: Select the Financial Institution's FATCA classification in its country/jurisdiction of tax residence: "None of the Above".

4. Complete the application and other questions as you did originally.

Additional information on the registration process can be found at FATCA foreign financial institution registration system. After the approved GIIN appears on the FFI list, use the GIIN to enroll in IDES only. When you complete the FATCA XML schema, enter the GIIN that reflects your actual country/jurisdiction of residence for tax purposes in the "TIN" data element for ReportingFI. Detailed information on IDES enrollment process can be found at https://www.ides-support.com/.

A direct reporting Non-Financial Foreign Entity (NFFEs) reports directly to the IRS rather than through their Host Country Tax Authority (HCTA). Under IRS business rules, all files uploaded by an FI in a M1O2 jurisdiction will be routed to the HCTA. When a direct reporting NFFE applies for its GIIN through the FATCA online registration portal it must specify its jurisdiction as ‘Other’ if it is located in a M1O2 jurisdiction. The GIIN assigned as a result of this registration option instructs IDES to route transmissions directly to the IRS and delivers transmission notifications directly to the direct reporting NFFE and not to the M1O2 HCTA.

Added: 08-10-2016

IDES is designed to be "always on" and available to receive files. The system will be unavailable during planned maintenance periods. Generally, maintenance is performed on Saturdays between 6 p.m. and midnight EST. Any additional outages will be announced on the FATCA IRS.gov website.

Updated: 07-14-2015

The IDES system is intended to support both SFTP and HTTPS transfers.

No, IDES will be IPv4 compatible only at the current time. Information about IPv6 compatibility will be published at a later date.

Information on IDES alert codes.

Information on ICMM notifications can be found on IRS.gov at IRS FATCA report notifications. The IRS has recently published a user guide containing information on ICMM notifications.

Updated: 03-03-2015

First, they need to be an enrolled user of IDES. When a testing window has been identified, all enrolled users will receive an email notifying them of the window as well as instructions for signing up for that specific window. Additional information regarding testing can be found on the IRS.gov website.

Added: 03-03-2015

The IRS conducts periodic testing of IDES. Dates for testing windows will be made available at IDES testing schedule.

Updated: 07-14-2015

Please make sure that you're email spam filter will accept emails from the IDES enrollment site (@ides-support.com). This is not only important for the enrollment email, but IDES alerts.

Added: 02-20-2015

All those that are registered users with IDES will receive an email that provides details for the upcoming testing window. The email will include the start and end date of the window as well as the URL for that specific window. If you are an enrolled IDES user, you will be enrolled in the testing window.

Added: 07-14-2015

The URL is different for each testing window. The URL will be included in the email to registered IDES users alerting them of the upcoming test window.

Added: 07-14-2015

The April 2016 maintenance release addressed the following issues:

1. Allows submission of Amended, Corrected or Voided account reports where the Reporting FI TIN field in the original New record was either empty or contained an invalid entry. For filers that already submitted a subsequent New record to correct the information, this will permit you to now Void the original erroneous account report (s) and/or pooled reports.
2. Updates record-level validations to allow zero or negative amounts to be considered valid payment amounts and/or a valid account balance in account reports. 
3. Updates record-level validations to perform validations on ALL substantial owners listed for a specific account report. Previously only the first listed substantial owner was validated.

Updated: 08-10-2016

In April 2016, the IRS updated FATCA reporting to allow zero or negative amounts to be considered valid payment amounts. If you provide the Payment element by entering zero or a negative PaymentAmnt, you are required to enter value for the Type element also. Alternatively, you can submit the record without providing the Payment element. Both examples below are considered acceptable.

Example 1 -- Zero payment amount and type: 

<ftc:AccountBalance currCode="USD">50000.00</ftc:AccountBalance>

<ftc:Payment> 

<ftc:Type>FATCA501</ftc:Type>

<ftc:PaymentAmnt currCode="USD">0</ftc:PaymentAmnt>

<ftc:Payment>

Example 2 -- No payment amount:

<ftc:AccountBalance currCode="USD">50000.00</ftc:AccountBalance>

Added: 08-10-2016

Data should be provided in the XML format, which complies with the Inter-governmental FATCA XML schema as agreed by the international community and published on the IRS FATCA web site. See IRS Publication 5124 FATCA XML v2.0 user guide.

No, there is currently no naming convention required at this time. If there is a change to this requirement, it will be published on the IRS FATCA web site.

Sample XML documents for the FATCA NIL reports, sender metadata, and notifications have been uploaded to the IRS.gov website and can be found at FATCA XML schemas and business rules for Form 8966. Additional sample XML packets are being developed and will be posted on IRS.gov as soon as available.

Added: 05-08-2015

Information regarding the metadata schema is documented in the IDES metadata schema user guide, which can be found at IDES user guide PDF.

Are there any restrictions on the range of characters that can be used? Yes, the FATCA XML schema v2.0 was developed using UTF-8. Additional specifications regarding acceptable characters can be found in the Competent Authority Arrangements.

Is there a method to associate and/or merge files if transmission split due to size restrictions? At the current time, the maximum recommended file size is 200MB compressed. There is currently no method to merge files; this will be addressed at a later date if this becomes a recurring need. There is no need to associate the files, all the information can be sent in as many transmissions as needed.

The IRS will not rely on the SendingCompanyIN data element to determine the origin of a file. The sender will be identified in the metadata that accompanies each IDES transmission.

There is a 'test' Doc Type indicator in the schema that corresponds to each production indicator. It is expected all partners will make use of the 'test' doc type indicators during testing periods. The sender should not send data with ‘test” doc type indicators to IDES in production. Test data should only be transmitted to the test environment during test window.

Updated: 04-08-2015

In June 2016, the IRS released FATCA XML schema v2.0 to be deployed in January 2017. FATCA reporting will only accept XML files created using schema v2.0; multiple versions are not supported. All FATCA XML files should be created and validated using the current schema in effect at the time of filing. Prior to January 2017, use schema v1.1 for all FATCA submissions; after January 2017, only use v2.0 to amend, correct and void reports that were previously created using schema v1.1. In addition, if you are a Model 2 jurisdiction and received a group request from the IRS prior to January 2017, respond to the request using schema v2.0.

Updated: 03-01-2018

If an individual has not received a particular payment type, zero amount is acceptable. If a particular payment type is not relevant to the individual, it is preferred that the information be omitted.

The IRS will send notifications regarding the submission of test files in the same way as in the production environment. If additional questions are generated after receiving a notification, feel free to contact the IRS at the number indicated on the notification.

Updated: 03-03-2015

Yes. The only requirement is that the field be unique for each sender for the lifetime of the system and that it not exceed the maximum length of 200 characters.

Updated: 06-22-2015

• Corrected data (FATCA2) is used for records being re-transmitted after the IRS has notified the sender of a problem with the file or underlying data. Corrected data should ONLY be used when responding to an IRS request to correct the data.
• Amended data (FATCA4) is used to amend a record(s) previously transmitted to, received and processed by the IRS, but is later found to contain erroneous information. 
• Void data instructs IRS to disregard previously filed records when data needs to be re-transmitted. Please see IRS Pub 5124 for specific scenarios where this would be required. The original records should be re-transmitted with code FATCA3 which instructs IRS to void the original transmission. After voiding records, the revised records should then be transmitted to IRS with code FATCA1 as new data.

Added: 05-08-2015

The MessageRefId should be a unique identifying number for the new file that includes the updated entries. The CorrMessageRefId should be the MessageRefId of the original file submission.

Updated: 06-22-2015

• The data format is <reporting FI GIIN><period character (.)><unique value across all time for the reporting FI>
• The first part – <reporting FI GIIN> is the GIIN for the reporting FI associated with the reporting group
• The second part is a period character (.)
• The third part – <unique value across all time for the reporting FI> is an identifying value for the referenced record that is unique within the reporting FI for all time. Use of a GUID is recommended but not required.
• The DocRefID must not include any non-alphanumeric characters, excluding periods and dashes. Prohibited non-alphanumeric characters include but are not limited to_, @, +, &, ! and *.

This element should contain at least 21 characters, which includes the first part – reporting FI GIIN, the second part – period character (.), and at least one alphanumeric character to represent the third part. The maximum length of DocRefID is 200 characters. 

 DocRefID Examples (XXXXXX.XXXXX.XX.XXX.X):
 S519K4.99999.SL.392.12291cc2-37cb-42a9-ad74-06bb5746b60b
 127BM7.00001.ME.124.406abc8a1830490e847890ba3b13a646

Updated: 04-18-2018

The use of the ampersand (&) and less than (<) symbols as XML text content is not allowed by XML syntax rules. These characters must be replaced by predefined entity references “&amp;” and “&lt;” respectively. If the XML text content contains these prohibited characters, you will receive a failed schema error notification (XML not well-formed).

The use of the greater than (>), apostrophe (‘) and quotation mark (“) characters is not restricted by current SQL injection rules. To conform to XML schema best practices, these characters should be replaced by predefined entity references, “&gt;”, “&apos;” and “&quot;” respectively. For more information, visit FATCA XML schema best practices for Form 8966.

Updated: 08-10-2015

Previously the apostrophe (‘), double dash (--), quotation mark ("), and hash (#) symbols were prohibited due to a possible security threat. Currently the double dash (--), slash asterisk (/*) and ampersand hash (&#) character patterns are the only prohibited characters. To prevent file error notifications, do not include any of these character patterns.

Updated: 08-10-2015

Yes. Inclusion of any restricted characters will only cause a rejection if they are within the XML data elements. Restricted characters in escaped portions of the file, i.e. comments, will not cause a rejection.

Added: 04-08-2015

Pooled reports may not be submitted by HCTAs with respect to FIs in Model 1 jurisdictions. Pool reports may be submitted by FIs in Model 2 and Non-IGA jurisdictions. Pooled reports are submitted using the same method as account reports. Pooled reports can be submitted using the FATCA schema and by selecting pooled report in the reporting group.

Added: 02-20-2015

Generally, only direct reporting Non-Financial Foreign Entities (NFFEs) and sponsoring entities’ reporting on behalf of a sponsored direct reporting NFFEs are required to submit a Nil report. A Nil report is optional for all other filers. Also note that nil reporting may not be required by the IRS, it may be required by the local jurisdiction. Consult your local tax administration for more information. For more information, sample nil reports are available at FATCA XML schemas and business rules for Form 8966 webpage.

Updated: 08-10-2016

The IRS has noted that some signature tools may insert illegal characters in the KeyInfo element when generating a signature. If so, the KeyInfo element should be removed before submitting the package. The package will validate without it. Also check the updated guidance around restricted characters, referenced in FAQ C17. There has been recent change in the guidance and apostrophes, even in entity reference form, will cause a Failed Threat Detection notification.

Updated: 07-14-2015

To void a record:

• A FATCA report must include an account report and/or a pool report.
• Typically, a record is equivalent to one paper Form 8966. A record is an account report and/or pool report, plus the associated organizational filer. The filer may be a Reporting FI, Sponsor or Intermediary.
• A Reporting FI cannot be voided, amended or corrected alone. Only a whole record including AccountReport, PoolReport and ReportingFI, Sponsor (if present), can be voided.
• All fields in the void record must equal the same values as the original record previously submitted.

Added: 09-09-2015

To amend a record:

Note: A FATCA report should contain similar <DocTypeIndic> elements in the same file. Do not combine void, amended and corrected records in the same file.

Added: 09-09-2015

The IRS has created a new workaround for the TY 16 schema for organization to allow entities or organizations to be reported as substantial owners. Beginning in TY 2016, to report an entity as the substantial owner use the First Name field to specify the name of the entity or organization and use the Middle Name field to indicate “ENTITY2015” that the filer intends to report the entity as the substantial owner. This new workaround is strictly optional for TY2015 reporting. For further guidance on how the term substantial owner is defined by entity type, please refer to the schema user guide.

Updated: 03-29-2016

Beginning January 16, 2017, FATCA reporting will only support the XML schema v2.0. All new, nil, amended, corrected, and void reports should use version 2.0. The two versions of the FATCA XML schema are not backwards compatible and files submitted using schema version 1.1 will not validate against version 2.0. Example: In November 2016, a user submits Report2015 and receives a notification to correct record level errors within 120 days. In February 2017, the user should make all corrections using XML schema version 2.0.

Updated: 01-06-2017

If there are duplicate DocRefIDs existing in the system, you may not be able to submit a corrected, amended or voided record in the usual process. The IRS has created the following workaround to submit the necessary changes: For all submissions under this procedure, use FATCA1 (New Data) as the DocTypeIndic. While we are aware this idenitifes a New record, for purposes of validation the use of FATCA1 will avoid the record being identified as a duplicate DocRefId. Prepare the record with a unique DocRefID (different than that used on the original record) according to the new DocRefID format.

For Individual Account Holders, enter the following in the MiddleName data element:

• For Corrected records, enter CORRECTTY2014
• For Amended Records, enter AMENDTY2014
• For Voided Records enter, VOIDTY2014

If you have a MiddleName to enter in that field you may enter it after the above language has been inserted in the field.

For Entity Account Holders, enter the codes (shown above) at the beginning of the entity Name field. You can enter the entity’s legal or business name following the specified language. For example, to correct a record for account holder "ABC Inc", enter “CORRECTTY2014 ABC Inc”.

Added: 08-10-2016

For tax years 2015 and 2016, NPFFI account reporting for aggregate amounts of payments made to such accounts are required. The Model 1 IGA does not require the reporting of an account balance of an account held by an NPFFI.

The FilerCategory identifies the filer category code for a reporting financial institution and/or sponsor. It is required based on specific filing status. For example:

• The FilerCategory element is mandatory for reporting financial institutions that are not a sponsored FFI, sponsored direct reporting NFFE, or trustee-documented trust.
• The FilerCategory is mandatory if the report contains a sponsoring entity.
• Intermediaries are not allowed to use FilerCategory element.

In all other instances, the Filer Category element is optional. The FilerCategory element should not be used for 2014 or 2015 tax years.

Added: 03-22-2017

The AccountClosed element permits financial institutions to declare the account status as closed or transferred during the calendar year. Do not report the account closed if an account holder rolls over the amounts in one account into another account with the same FFI during the calendar year. Withholding agents should not complete this element.

The AccountClosed element is optional. The AccountClosed element should not be used for 2014 or 2015 tax years.

Added: 03-22-2017

The AccountNumber element provides the account number assigned by the financial institution to uniquely identify the account holder. The account number can be any of the following:

• A custodial account or depository account
• A custodial account or depository account
• Code related to a debt or equity interest, not held in a custody account.
• Identification code of a cash value insurance contract or annuity contract.

The AcctNumberType attribute allows financial institutions to declare the uniquely used account number format. The value of the AcctNumberType attribute should be from the list below:

The AcctNumberType attribute is optional and is not required for FATCA reporting. The AcctNumberType attribute should not be used for 2014 or 2015 tax years.

Added: 03-22-2017

All files will be submitted through IDES. IDES supports transfers through HTTPS and SFTP. Specific operational procedures for data preparation are documented in the IDES user guide PDF.

Metadata files needs to be included in the transmission file submitted to IDES. Specific operational procedures for sending metadata files are documented in the IDES user guide PDF. Additionally, a sample metadata XML file can be found at FATCA XML schemas and business rules for Form 8966.

No, all IRS requests for information will be transmitted via IDES. Format of the message exchange between IRS and HCTA will be via PDF.

Updated: 03-03-2015

Yes, IDES will be used as the transmission path for ICMM notifications. A message type in the metadata will be used to distinguish notifications from FATCA reports.

The data will be sent through IDES. The format of the XML specification is the same as the Form 8966 XML schema published on the IRS website and can be found in the IRS publication intergovernmental FATCA XML schema v2.0.

The HCTA should direct information regarding system outages to the United States Competent Authority.

Procedure for submitting corrected or amended data will be the same as the submission of a new report. Specific operational procedures for data preparation are documented in the IDES user guide PDF. The resubmission will only include the corrected/amended entries, with a reference to the original report. Please refer to the FATCA XML user guide for preparing corrected or amended reports.

The FATCA report data XML file must be validated against FATCA XML schema published on IRS site. IRS Publication 5124 FATCA XML v2.0 user guide contains all information required to ensure data is valid within the report. The user guide outlines which fields are mandatory as well as specific business rules for each data element.

The IDES alert of a successful upload is information about the transmission of your file. IDES alerts cannot provide information about the receipt and processing of your files by IRS ICMM. The IRS should issue an ICMM notification for every FATCA report that is successfully transmitted through IDES letting you know the status of your FATCA report. You should always receive a notification within 24 hours, and in most cases within a few minutes, of the IRS ICMM system receiving your file. However, the IRS has identified specific instances during testing where ICMM notifications are not issued to filers when certain errors are present. In addition, the IRS has identified circumstances in which filers did not download their notifications before the 7-day retention period expired, and these notifications were deleted and are no longer available for download. The IRS is working to address and resolve these issues. 

In the meantime, there are a few things you can do to maximize your ability to receive notifications sent to you, and to determine whether a notification has been sent to in response to your file. These are as follow:

• First, make sure that email alerts from IDES are not blocked as SPAM by your own email system. Your email system may have deleted it or may have sent it to you SPAM inbox. If you have been sent an alert that a notification is present, but the alert email is blocked you may never be aware of the notification’s availability for download. 
• Second, make sure your IDES user profile is configured to allow IDES to send you email alerts, including those regarding notifications. There is a box that can be set to either send or not send you email alerts. If you would like to receive email alerts, including those about notifications, make sure it is set to send email alerts.
• Third, check your IDES inbox over the next 24 hours following the upload of your file to IDES to determine whether there is a notification waiting for download. Even if you have not received an email Alert, the notification could still be in your folder ready for download. After seven days the notification will automatically be deleted from the system.

If you have checked your folder in IDES and there is no notification present after 48 hours or longer since your file was uploaded successfully, an error types which is suppressing a notification from being sent may have been detected on your file. A few things to check that may help include the following:

• Making sure the digital certificate you are using for signature and encryption for FATCA data has not expired or been revoked by your Certificate Authority. 
• Also, you should double check the Metadata XML file that is part of your data packet, to ensure all of the mandatory data elements are correct. In particular, please make sure that FATCAEntCommunicationTypeCd is set to “RPT”, and that the TaxYear is set to “2014.”
• Make sure all of the entries are correct. Did you indicate you were submitting a FATCA report? Did you select the correct tax reporting year (it should be 2014)? Etc.

After you’ve checked these items, you should resubmit your file.

Updated: 05-08-2015

It is possible that you submitted your FATCA report production files to the FATCA report test environment instead of to the FATCA report production environment. Any production files that are submitted to the test environment will not be processed and will need to be re-submitted to the production environment. Please do not submit production files to the test environment. In addition, please do not submit test files to the production environment.

Added: 05-14-2015

The data packet to be transmitted is an archive in .ZIP file format. For Model 1 and 2 IGAs, this packet should include 3 files (FATCAEntitySenderId_Metadata.xml, FATCAEntityReceiverId_Key, and FATCAEntitySenderId_Payload). For Model 1 Option 2 IGAs, the packet should have 4 files, all of those mentioned previously plus the HCTAFATCAEntityId_Key. You are receiving RC026 because for your respective jurisdiction, there are more than the 3 or 4 files in the data packet.

Added: 05-08-2015

This will be done via the notifications. The Valid File notification lets you know that the IRS has determined that the referenced file is in a valid format. Individual records submitted within the file have been processed and any errors detected during processing are provided in the Error Details included. This notification should be received within 24 hours of receiving alert RC001 (indicating file was successfully uploaded to IDES).

Updated: 09-09-2015

The IRS identified files that could not be automatically downloaded because the files may have contained an invalid date in the metadata file. Please ensure the metadata element <FileCreateTs> contains a valid timestamp in valid pattern; for example, do not use 00 as a month and do not use any future year.

Updated: 11-03-2015

A digital signature shall be applied to XML and notification files, referred to hereafter as data files. FATCA digital signatures use the SHA-256 hashing algorithm in conjunction with the private key for the sending party who will upload the file to IDES. The private key corresponds to the public key (RSA 2048-bit) that is stored on IDES. Following the creation of a digital signature and compression, the data file is encrypted using the AES algorithm and a randomly generated 256-bit key. The AES key is stored in a separate file and encrypted using the receiving party's public key, which is obtained from IDES. Both the data file and the key file shall be combined into a single zip file along with a separate metadata file for transmission to IDES.

Updated: 07-14-2015

For the IDES web user interface, the user connects using a web browser and the HTTPS protocol, which in turn utilizes Transport Layer Security (TLS 1.2) to protect sensitive data during electronic dissemination across the Internet. Alternately, the end user can interface with IDES using SSH File Transfer Protocol (SFTP) which is based on Secure Shell (SSH) version 2.0 or higher.

Updated: 07-14-2015

The public key of the IRS for the users will be available through IDES. Each user will have a unique password.

Updated: 06-02-2015

Each user, to include both HCTA/FFIs and IRS, will connect to IDES using a secure transmission protocol and an encrypted session. More information can be found in the IDES user guide PDF.

The encryption tools and processes are the same regardless of the direction of the transmission.

During the FFI, direct reporting NFFE, and HCTA enrollment process, the digital certificate must be uploaded to the IDES website. IDES accepts digital certificate products from several Certificate Authorities (CAs). A list of acceptable certificate authorities and products can be found at digital certificates.

Updated: 03-23-2022

The AES key must always be considered a “one time use” key. Software of the IDES user guide in response to inquiries regarding data preparation.

The IRS will continue to update the FAQ and the data preparation section of the IDES user guide in response to inquiries regarding data preparation.

There are currently samples of data preparation code available on GitHub in the IRS.gov repository.

Updated: 05-08-2015

A digital certificate is required to complete the FFI, direct reporting NFFE, and HCTA enrollment process for IDES. Only the entity that prepares an encrypted file and uploads it to IDES needs to obtain an account on IDES, and therefore needs to obtain a digital certificate. The private key used to sign the XML file must correspond to the public key in the digital certificate used to enroll in IDES.

Updated: 07-14-2015

A digital certificate is issued to a single organization. The digital certificate contains a public key. Sharing of the corresponding private key between organizations is a poor security practice and, as such, it is strongly discouraged.

Added: 03-03-2015

Only the submitting entity needs to have a certificate.

Added: 04-08-2015

Of the digital certificate products which IDES will accept, there is one that is not an SSL certificate and therefore does not require the organization to have a FQDN. More information may be found at http://identrust.com/irs/fatca/index.html.

No, the FQDN in question is the entity's FQDN, not the IDES FQDN.

Added: 03-03-2015

Whichever organization is planning on doing the actual filing, is the only organization that requires a certificate and that is the one whose domain name should be used for the certificate.

Updated: 06-22-2015

There are existing data preparation software packages on the commercial market; however, the IRS does not endorse any specific software packages. There are currently samples of data preparation code available on GitHub in the IRS.gov repository.

Updated: 03-29-2016

The IRS has posted a variety of different methods for decrypting notifications on Github in the IRSgov repository.

Updated: 06-22-2015

You should verify the certificate has not expired, been revoked, and is one of the certificate products approved for use by FATCA. Other types of SSL or organizational certificates are not allowed. If the certificate is invalid, correct and update the IDES enrollment site with a valid certificate.

Added: 08-10-2015

The encryption standard used by the IRS meets current ISO standard(s). We continuously evaluate encryption algorithms to improve data security. During a routine security review, the IRS decided to improve encryption by replacing the Electronic Code Book (ECB) cipher mode with the Cipher Block Chaining (CBC) cipher mode. CBC is a stronger algorithm for encrypting data and its adoption will improve the current secure data packaging process. CBC requires an Initialization Vector (IV) for data packaging. Review the IDES resources webpage for more information.

Added: 03-29-2016

E20. How do we create an Initialization Vector (IV)? Beginning July 9, 2016, the Initialization Vector (IV) is a 16-byte random number. An IV can be generated in code or your current data packaging software.

Added: 03-29-2016

The current data packaging process uses the Electronic Code Book (ECB) cipher mode where the 32-byte AES key is encrypted with the IRS Public Key. The revised data packaging process uses the Cipher Block Chaining (CBC) cipher mode where the 16-byte Initialization Vector (IV) is concatenated to the end of the 32-byte AES key. The resulting 48-byte value (32-byte AES key and 16 byte IV) is then encrypted with the IRS public key. All data packets received from the IRS must follow the same data packaging process with the updated CBC cipher mode. For decryption, the data packaging process is reversed, with the 48-byte key file separated into a 32-byte AES key and a 16 byte IV. Review the IDES resources webpage for more information.

Note: You will receive a NKS (Incorrect AES-key size) error notification if you (1) use the ECB cipher mode (2) do not include the IV in the key file and/or (3) incorrectly concatenate the key and IV.

Updated: 05-27-2016

There are two possible problems if a public key certificate is updated while the file exchange is in progress. (1) If an encrypted file is sent to IRS that has not been processed yet, then digital signature validation will fail because the public key obtained from IDES will no longer correspond to the private key used to sign the payload file. (2) If the IRS sends a notification using the old public key certificate, and the recipient updates the public-private key pair before they retrieve the notification from IDES, then the recipient cannot decrypt the AES key file unless they kept a copy of their old private key. To avoid either situation, it is recommended that you wait until you have received a notification from IRS for all files uploaded to IDES for transmission to IRS. You should update your public key certificate after you have received a notification. If this is not possible and situation No. 1 arises, then you should receive a notification from the IRS related to the digital signature verification failure. If this occurs, you should then resubmit the file using the newest public-private key pair. If situation No. 2 arises, please send the request to the lbi.fatca.ides@irs.gov mailbox to have the notification retransmitted.

Added: 05-27-2016

If you have a valid certificate from an approved certificate authority that is no longer on the list, you can continue to use it until it expires. Once it expires, it will have to be replaced with a certificate from the current list.

Added: 07-25-2017

All of the EV-SSL certificates listed are accepted by IDES.

Added: 07-25-2017

The digital certificate uploaded to the International Data Exchange Service (IDES) for your entity is invalid. The IRS cannot download a file from IDES if the transmitter certificate is not valid. You may have received an alert due to one of the issues below:

1. Error:
“8522 errors: Communications error with the Certificate Authority”

Reason:
The entity attempted to transmit a file to the IRS that we have been unable to download due to a communications error with the Certificate Authority. The transmitted file will expire and be removed in 7-days. The digital certificate uploaded to IDES for the entity may not have been issued by an IRS approved Certificate Authority. As a result, the IRS can neither send to, nor receive any transmissions from your entity until the certificate issue is resolved.

Resolution:
Please check your settings, contact the issuing Certificate Authority for assistance with resolving the communications error, obtain a replacement or contact one of the IRS approved certificate providers for a new digital certificate. Update your digital certificate to ensure your ability to transmit and receive IRS transmissions.

2. Error:
Invalid/Revoked/Superseded digital certificate
The digital certificate uploaded to International Data Exchange Service (IDES) is invalid or was revoked/superseded by a newer version.

Reason:
While attempting to send a notification through IDES to your entity concerning your earlier FATCA submissions, the Internal Revenue Service (IRS) has determined that your entity’s digital certificate is no longer valid. As a result, the IRS can neither send to, nor receive from your entity any transmissions until the certificate issue is resolved.

Resolution:
Please contact the Certificate Authority (CA) for a replacement or one of the IRS approved certificate providers for a new certificate. Update your digital certificate to ensure your ability to receive IRS transmissions.

3. Error:
Online Certificate Status Protocol (OCSP) invalid certificate path

Reason:
The IRS could not validate the digital signature on the payload for your entity. The Online Certificate Status Protocol (OCSP) client is unable to send a status request or receive information if the certificate is valid or revoked. As a result, the IRS can neither send to, nor receive any transmissions from your entity until the certificate issue is resolved.

Resolution:
Please contact your Certificate Authority for a new certificate with a functional OCSP or one of the IRS approved certificate providers for a new certificate. Update your digital certificate to ensure your ability to receive IRS transmissions.

IDES only recognizes and accepts digital certificates issued by IRS approved certificate authorities.

Follow the upload digital certificate instructions found in the IDES user guide PDF, beginning on page 41, to upload a new certificate.

After uploading a valid digital certificate to IDES, re-encrypt the FATCA XML file with a new AES key.

Re-package and re-submit the payload file to IDES using the new valid digital certificate.

Added: 01-09-2020

Certain entities, such as USWAs, TFIs, or other third-party preparers (not sponsoring entities) submitting information on behalf of another entity, are not required to register or to obtain a GIIN and, therefore, should not do so. USWAs, TFIs, and other entities that are not required to have a GIIN (“non-GIIN filers”) must follow the procedure, below, in order to obtain a FATCA ID number (FIN) that they will use in lieu of a GIIN to enroll in and use IDES (including submitting an Intergovernmental FATCA XML schema v2.0 (electronic Form 8966)). 

The FIN, along with the associated identifying information that you provide, will be treated as return information by the IRS. This FIN and the associated information provided will be used by the IRS to validate the non-GIIN filer’s IDES enrollment and submission of files via IDES and for other FATCA purposes. The FIN, but not the associated information (such as your name), will be published on the Foreign Financial Institution (FFI) List to facilitate the IDES enrollment and your submission of files via IDES. For more information about the FFI list, see IRS FFI list FAQs.

Your published FIN will be accompanied by a generic name (e.g., “U.S. Withholding Agent 1”) on the FFI List, and publication of your FIN on the FFI list does not change your status for FATCA purposes. That is, having your FIN published on the FFI list does not make you an FFI, and the FIN does not serve any function related to withholding tax on payments under FATCA.

If you are a USWA or TFI, you complete the FATCA XML schema in the same manner as if you were a “ReportingFI”. In the “TIN” data element, make sure to use your U.S. EIN (or, if you are a TFI that does not have a U.S. EIN, use the EIN used by the relevant U.S. territory tax administration to identify the TFI). 

Note: For additional information, please read FAQ Q2 under the “Reporting” section on the general FAQ page.

Updated: 07-14-2015

If you are a third party preparer (not a sponsoring entity) or commercial software vendor and you are submitting the FATCA XML schema on behalf of another entity (or on behalf of several other entities), enter your FIN, which you obtained to enroll and use IDES, in (1) “SendingCompanyIN” data element in the FATCA XML schema message header and (2) "FATCAEntitySenderID" data element in the FATCA XML metadata schema.

Note: For additional information, please read FAQ Q2 under the “Reporting” section on the General FAQ page.

Updated: 07-14-2015

No, IDES does not perform a validation.

Added: 06-08-2015

As the entity performing the actual submission, the third party would use their own digital signature.

Added: 06-08-2015

The entity that submits the package will receive the alerts and notification.

Added: 07-14-2015

You can request a FATCA Identification Number (FIN) to enroll in IDES and submit FATCA reports. If you are reporting information to a Model 1 Option 2 (M1O2) jurisdiction, you MUST obtain a FIN where the last three digits correspond to the ISO country code for the M1O2 jurisdiction. If you are reporting on behalf of other jurisdictions, you should obtain a second FIN with the jurisdiction code of ‘Other’ to report for those other jurisdictions. 

Please consult your local jurisdiction to determine if it has elected Model 1 Option 2 for FATCA reporting. Review the IDES resources and FIN webpages for information about how to obtain a FIN and enroll in IDES.

Added: 07-14-2015

The general rule for FATCA is that reporting entities in Model 1 IGA jurisdictions do not report directly to the IRS, but instead report directly to their host country tax authority. IDES follows the business rules of the IGAs. In order to use IDES to report you, need to request a FIN that identifies your tax jurisdiction code as ‘Other’. Review the IDES resources and FIN webpages for information on obtaining a FIN and enrolling in IDES.

Added: 07-14-2015

The FATCA XML schema v1.1 does not allow a controlling person to be an entity. A controlling US person must be a natural US person. This issue will be addressed in a future revision of the FATCA reporting XML schema.

Added: 10-28-2015

The ReportingFI/TIN element should contain the GIIN of the sponsoring entity. Until the sponsor entities can obtain their own GIIN, you should continue to use the sponsoring entity’s GIIN. Do not leave this field blank.

Added: 10-28-2015

The FATCA XML schema v1.1 definition supports the representation of two types of addresses, using two distinct data elements <AddressFix> and <AddressFree>. There is also the ability to use <AddressFix> with supplemental <AddressFree>, which is optional.

The <AddressFix> data element supports using 9 separate elements, listed below:

• <Street>
•  <BuildingIdentifier>
•  <SuiteIdentifier>
•  <FloorIdentifier>
•  <DistrictName>
•  <POB>
•  <PostCode>
•  <City>
•  <CountrySubentity>

Of the supported data elements listed above, only the <City> data element is required. If a value for <City> is not provided, then a validation error will be communicated back to the submitter explaining that “City or Town Not Provided”.

Please note that while an empty <City> data element and a value containing only whitespaces will successfully pass schema validation, ICMM requires at least one non-whitespace character to be provided. In these cases, a validation error will be communicated back to the submitter explaining that “City or Town Not Provided”.

The <AddressFree> data element supports a less structured representation of an address. In this representation, the address is presented as one string of bytes, where various delimiters could be used to separate the various parts of the address.

There are no validations performed on the data provided in the <AddressFree> data element.

Updated: 12-10-2015

The sponsoring entity agreed to perform the due diligence, withholding, and reporting obligations of one or more sponsored entities pursuant to Treas. Reg. §1.1471-5(f)(1)(i)(F). The sponsoring entity should continue FATCA reporting on behalf its sponsored entities. Sponsored entities CANNOT enroll in IDES.

The reporting FI GIIN field in the Form 8966 will contain the sponsored entity’s GIIN. The sponsor GIIN would be the sponsoring entity’s GIIN. If the sponsoring entity actually submits the file to IDES (as opposed to a third-party acting on their behalf) then their GIIN would also be present in the SendingCompanyIN data element in the message header.

Added: 12-10-2015

The ReportingFI/TIN element should contain the GIIN of the sponsoring entity. Until the sponsored entities can obtain their own GIIN, you should continue to use the sponsoring entity’s GIIN and do not leave this field blank. You should use the sponsored entity’s own GIIN to populate the ReportingFI/TIN starting January 1, 2017.

Added: 01-26-2016

A reporting FI that is not obligated to have a US TIN or GIIN should leave the reporting FI TIN element blank. This will cause a record-level error notification; however, because the absence of a TIN in this NFFE example is correct, the notification does not require a correction. Do not substitute any other characters for the TIN in this case.

If the TIN element was left blank due to the transition rule for Model 1 IGA filers reporting on pre-existing accounts, please see IDES FAQ A17 for more information.

Added: 02-09-2017

No. Prior to 2017, Article 3(4) of the Model 1 IGA provided that a reporting Model 1 FFI was not required to report a U.S. TIN for the account holder of a preexisting account if the TIN was not in the FFI’s records; instead, the FFI could report the account holder’s date of birth if the date of birth was in the FFI’s records. The IRS published an FAQ to explain how to report an account holder for which the FFI did not have a TIN. See ICMM FAQ Q9 for updated rules for complying with Article 3(4) for reporting in 2017 with respect to the 2016 year.

Article 6(3)(b) of the Model 1 IGA provides that by January 1, 2017, the Model 1 jurisdiction commits to establish rules requiring reporting Model 1 FFIs to obtain U.S. TINs for preexisting accounts for reporting with respect to 2017 and later years. Beginning January 2018, the IRS will update its record validation rules so that error notifications will be sent if a reporting Model 1 FFI reports nine zeros as the TIN for an account holder. 

If you have questions regarding the obligations under the IGA between the U.S. and your jurisdiction, or any domestic legislation passed to implement the provisions of the IGA, please contact the office of the Competent Authority in your jurisdiction.

Added: 04-11-2017

The new communication types can be transmitted through IDES:

For more information regarding these communication types, please reference the current version of the IDES user guide PDF.

Added: 08-04-2020

Please see the table below for when an enrolled user would send the IRS this communication type:

Added: 08-04-2020

The maximum file size is 200MB uncompressed.

Added: 08-04-2020

Testing of these new communication types can be done during the regularly scheduled IDES testing windows. Testing information can be found on the IDES testing schedule page.

Added: 08-04-2020