FATCA

Overview

This article outlines how to use XML Authority to create FATCA submissions in XML format, simplifying the schema to meet your specific reporting needs.

XML Authority contains the FATCA schema as released by the IRS, as well as other national variations in its schema library. The schema is used not only for filers to report their information to the IRS or to their local tax authority, but also for authorities to share this information amongst each other.

This means that the schema structure may be overly complex for an individual reporter and includes complexities such as:

• Support for multiple FATCA reports within a single XML file.
• Allowing for multiple reporting groups in one report.
• Allowing for more than one name, TIN or address for a reporting entity, sponsor, intermediary, account holder or substantial owner.
• Inclusion of extended name components (e.g. multiple middle names and titles, suffixes like “PhD”, or generational identifiers like “Jnr”).

To help navigate this complexity, XML Authority allows for schema masking, which hides or removes non-mandatory schema elements to streamline your reporting. This results in a cleaner interface and a simplified Excel import template.

Note: The unmasked IRS FATCA schema would result in 47 separate tables to deal with the complexity as it was designed, while an appropriately masked schema for an individual filer may only consist of 3 or 4 tables.

Creating a New Submission

Report Setup Wizard

When you create a new FATCA report, click Yes when asked if you want to use the Report Setup Wizard

The wizard tailors the schema structure based on your answers, automating schema masks and removing unnecessary schema complexity:

Tip: Schema masks can be edited at any time. If a hidden, non-mandatory element becomes necessary, simply unhide it using the standard schema masking functionality.

Creating an Excel Import Template

To generate an Excel import template, click Excel – Import Template on the main ribbon. XML Authority will produce an Excel file with sheets matching the schema masks in your document.

Note: If you subsequently adjust your schema masks, you may need to recreate your Excel Import template.

Populating the Excel Import Template

Refer to this article for full instructions on how to complete the import template.

Enumerated values (e.g. “FATCA601”) may be unfamiliar. To understand these, hover over the “i” icon within the XML Authority UI to see descriptive annotations:

Note: Light grey cells in the Excel template represent non-mandatory fields according to the schema. However, some of these may still be required upon submission, depending on your jurisdiction.

Template Structure

Your template will generally include the following four sheets, but this may vary based on your schema mask or report setup choices:

1. FATCA OECD
2. Account Report
3. Substantial Owner (List)
4. Payment

FATCA OECD

Includes information about the overall report and the reporting entity:

Key notes:

• Fields like Version, Sending Company IN, Res Country Code, and TIN are technically optional in the schema but must be completed.
• Message Ref Id and Doc Ref Id are automatically generated by XML Authority when exporting to XML.

Account Report

This sheet contains the list of accounts:

Please note:

• ID (Column A): Used for cross-referencing between other sheets (e.g. Payments, Substantial Owners). This ID is not exported to XML - used only for internal referencing of records between tables. We recommend duplicating the account number (Column E) as the ID for consistency (assuming it is a unique identifer).
• Doc Ref Id: Automatically generated on export to XML.
• Account Holder: A choice element—populate either the Organisation columns or the Natural Person columns per row, not both.

Substantial Owner (List)

List of substantial owners linked to each account:

Key fields:

• Account Report ID: Must match the ID used in the Account Report sheet (Columns A & E).
• Account Holder: Again, a choice element—fill in either Organisation or Natural Person fields as appropriate.

Note: If your data contains only one substantial owner per account, you can mask this element to integrate its columns into the Account Report sheet.

Payment

Details all payments made across accounts:

Note:

• Account Report ID: Must reference the appropriate row in the Account Report (Value in Column A & E).
• Each payment type (four in total) should be listed separately. For example, one account with four payment types will have four rows in this sheet.

Validating

Before generating the XML file, validate your data:

• Refer to this article for validation instructions.
• XML Authority checks compliance with the schema only. Additional validation rules may be applied by your local tax authority or the IRS upon submission.

Ensure all validation errors are resolved to avoid submission failures.

Exporting the XML File

To export your submission:

• Click the top half of the XML – Export button for a standard export.
• For digitally signed submissions (e.g. for IDES), click the bottom half of the XML – Export button and choose With Advanced Options…

For further guidance on the IDES signing process, see this article.

How to Create a FATCA Correction

If you need to correct a previously submitted FATCA report, follow the steps below.

1. Create a New Document

• Go to File > New in XML Authority.
• Use the Report Setup Wizard and select the Correction option.
• This will unlock the ability to import your previously submitted FATCA XML file.

[Insert screenshot showing the Correction selection and import option]

2. Import the Previously Submitted XML

• Browse for and select your original submission XML file.

  Upon import:

  • All Doc Ref Id values from the original report are moved into the Corr Doc Ref Id fields.
  • The original Message Ref Id is moved into the Corr Message Ref Id fields.

This ensures your correction references the correct original submission.

3. Update the Document Type Indicators

• Set the DocTypeIndic field to FATCA2 (indicating corrected data).

  This update is required in both the:

  • FATCA OECD sheet, and
  • Account Report sheet.

4. Apply Your Corrections

• Export the data into Excel using the Excel -> Export button in the main ribbon.
• Make the necessary updates directly in the Excel sheets.
• Only update the fields that need correction; leave all unchanged data as is.
• Import the data back into XML Authority

5. Generate the Corrected XML

• Ensure all validation errors are cleared.
• Use the Generate XML functionality to produce your corrected FATCA submission file.

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