Notice – CBAR System – New Validation Rules

13th January 2021

The FIAU would like to inform CBAR Reporting Entities that the XML Schema and Validation Rules document – which is downloadable from the below link – has been updated to reflect the following changes:

A) Section 2: Data Requirements for XML File includes illustrative examples to provide further clarity on existing data structure requirements. The section highlights the importance of uniquely identifying natural and non-natural persons. It is critical to provide these records once in the Natural Persons and Non-Natural Persons elements of the schema, even when such parties are involved with different accounts and / or in different capacities.

B) Three new validation rules have been put in place to enforce existing data structure requirements:

• L3.43: Document number and type for the same country is unique across all Natural Persons (previously implied in L3.28 which has now been revised)
• L3.44: Registration number for same registration country is unique across all Non-Natural Persons
• L3.45: Accounts cannot be reported without an account holder

Given the potentially disruptive nature of these changes, the FIAU has packaged the new ruleset under a new schema (XSD Version 2) which will run in parallel to the existing schema and ruleset (XSD Version 1) for a period of six weeks, i.e. until 25/02/2021. During this period, Reporting Entities are allowed to report against either of the two schemas depending on their progress towards the new validation rules. The applicable ruleset for an XML submission can be specified by changing the XSDVersion attribute in the XML File header from one (XSDVersion=”1″) to two (XSDVersion=”2″). On 25/02/2021 at 11 AM, XSD Version 1 will be archived and reporting will only be permissible against XSD Version 2.

In summary, while the new changes have been packaged under a new schema version, the XML schema definition itself has remained unchanged and no new data fields are being introduced.