This article considers difficulties in interpreting the common reporting standard (CRS) – particularly the definitions of “financial account” and “investment entities”. These definitions underpin reporting, and it is essential their wording be clear and not undermined by guidance given in the Commentary. This is particularly relevant where the Commentary’s status differs from jurisdiction to jurisdiction. This uncertainty about the definition of “financial account” may encourage over-reporting, which could have serious repercussions for both clients and financial institutions.