FATCA Exemption Codes: The A–M List and When to Leave W-9 Blank

The FATCA exemption codes on Form W-9 are a set of single letters, A through M, that a U.S. entity enters to signal it is not a “specified U.S. person” subject to Foreign Account Tax Compliance Act reporting. The field only matters when you are giving the W-9 to a foreign financial institution that holds an account for you outside the United States. If you are an individual, or if the W-9 is for a purely domestic account, leave the FATCA exemption code line blank.¹

When the FATCA Code Field on Form W-9 Applies

Form W-9 is the standard taxpayer identification form for U.S. persons. It has a line labeled “Exemption from FATCA reporting code,” and that line has a narrow job. It tells a foreign financial institution that the account it is opening or maintaining for you does not need to be reported to the IRS under FATCA’s Chapter 4 rules.¹

Two conditions have to line up before you enter anything. First, the requester of your W-9 must be a foreign financial institution, not a U.S. bank, broker, or business. Second, you must be one of the entity types the IRS lists as exempt. If either condition is missing, the field stays blank. Opening a checking account at a U.S. branch? Blank. Filling out a W-9 as an independent contractor for a domestic client? Blank.

The A Through M Exemption Codes

If both conditions are met, enter the one letter that matches your entity type:²

A — A tax-exempt organization under section 501(a), or any individual retirement plan.
B — The United States or any of its agencies or instrumentalities.
C — A state, the District of Columbia, a U.S. commonwealth or territory, or any of their political subdivisions or instrumentalities.
D — A corporation whose stock is regularly traded on one or more established securities markets.
E — A corporation in the same expanded affiliated group as a publicly traded corporation described in code D.
F — A securities, commodities, or derivative financial instruments dealer registered under U.S. or state law.
G — A real estate investment trust.
H — A regulated investment company or an entity registered under the Investment Company Act of 1940.
I — A common trust fund.
J — A bank.
K — A broker.
L — A trust exempt from tax under section 664 or described in section 4947.
M — A tax-exempt trust under a section 403(b) plan or section 457(g) plan.

Each of these categories identifies a U.S. payee that FATCA treats as low risk for offshore tax evasion. A publicly traded corporation, a state pension trust, a registered mutual fund, a chartered bank — the IRS already has visibility into them, so a foreign institution holding their account is excused from filing a FATCA report on it.¹

Who Should Leave the Field Blank

Most people who fill out a W-9 will leave this line empty. A few common situations:

You are an individual. The A–M codes are entity categories. There is no code for a natural person, and the instructions say individuals should not enter a code.¹
You are an entity, but the account or payment is domestic. FATCA reporting is a foreign-institution obligation. A U.S. requester has no reason to collect a FATCA code from you.
You are an entity that does not fit any of the thirteen categories. A privately held U.S. LLC that is not a bank, broker, dealer, REIT, RIC, or exempt trust has no code to claim. Leave the line blank.

Leaving the line blank when you have no exemption is the correct answer. It is not an admission of anything. It simply tells the requester that you are a specified U.S. person whose account is reportable under normal FATCA rules, which is the default for most private U.S. taxpayers.

What Happens If You Get the Code Wrong

The stakes attach to the foreign financial institution’s reporting duty, not to your own tax return. If the institution accepts an exemption code that turns out to be incorrect, its FATCA compliance is on the line. That is why foreign banks and brokers scrutinize the entry closely and often ask for supporting documentation before they accept a code.

On the payment side, FATCA’s enforcement mechanism is a 30% withholding tax on U.S.-source payments to accounts that are not properly documented. A missing or incorrect classification can cause a withholding agent to apply that 30% to payments that would otherwise flow through untouched.³ Picking a code you do not actually qualify for is worse than picking none: it is a false certification on a signed IRS form.

The safer path when in doubt is to leave the line blank and let the foreign institution report the account normally. Being reported to the IRS is not a penalty; it is the default.

Foreign Entities Use a Different Form

If you are not a U.S. person, Form W-9 is the wrong form entirely, and the A–M exemption codes are not for you. Foreign entities certify their FATCA status on Form W-8BEN-E, which uses a separate system called “Chapter 4 Status.” That form has dozens of possible classifications covering exempt beneficial owners, deemed-compliant foreign financial institutions, active and passive non-financial foreign entities, and others. The certification is given to the withholding agent, not sent to the IRS, and it also carries a 30% withholding consequence if it is missing or wrong.⁴

The W-9 Code Is Separate From Your Own FATCA Filing

One more boundary worth drawing. The FATCA exemption code on someone else’s W-9 concerns a foreign institution’s reporting duty about your account. It has nothing to do with your personal FATCA filing obligation, which lives on Form 8938 and travels with your annual tax return.⁵

Form 8938 kicks in when a U.S. taxpayer holds foreign financial assets above set thresholds — $50,000 at year-end or $75,000 at any point for single filers living in the U.S., higher for joint filers and those living abroad. Entering an exemption code on a W-9 does not excuse you from Form 8938, and not being required to file Form 8938 does not entitle you to enter an exemption code. They answer different questions for different filers.⁵

So when the W-9 lands in front of you and the FATCA exemption code line stares back, the decision is short. Domestic requester or individual filer: blank. Foreign requester and one of the thirteen listed entity types: the matching letter, and only that letter.

1
Internal Revenue Service. Instructions for the Requester of Form W-9
2
Internal Revenue Service. Form W-9
3
Office of the Law Revision Counsel. 26 U.S. Code 1471 – Withholdable Payments to Foreign Financial Institutions
4
Internal Revenue Service. Instructions for Form W-8BEN-E (10/2021)
5
Internal Revenue Service. Do I Need to File Form 8938, Statement of Specified Foreign Financial Assets