To determine if you are required to complete a Certification of Preexisting Accounts (COPA) or a periodic certification, you will receive a notification through a message board message indicating that a certification is available. The requirement to submit a certification generally depends on the classification you select at the start of the certification process. Once you select your classification, the system will display a screen indicating whether you are required or not required to submit a certification, and you will also receive a message board message confirming this.
For COPA, certain Financial Institutions (FIs) based on their country/jurisdiction of tax residence and FATCA classification, who are in approved status or were previously in approved status, need to submit a one-time certification of compliance with the due diligence requirements for preexisting accounts.
For periodic certifications, certain FIs based on their country/jurisdiction of tax residence and FATCA classification, who are in approved status or were previously in approved status, are required to submit periodic certifications. The periodic certification period covers three full calendar years, from January 1st of year one to December 31st of year three. The initial periodic certification will cover the three full calendar years plus the time from the effective date of the FFI agreement (or the date the GIIN is issued for entities that do not enter into an FFI agreement) to the beginning of the first full calendar year.
Additionally, for PTIN holders, the IRS may require completion of a Criminal Offense Record Investigation (COPA) or periodic certification to verify continued eligibility for a PTIN. If you are unsure whether you are required to complete a COPA or periodic certification, you should contact the IRS for guidance.
Sources:
Rev. Proc. 2007-21
Publication 5118 (07/2021)
Publication 3114 (4/2011)
Publication 5262 (10/2022)
