EU Greylist

The EU Greylist refers to Annex II of the European Union tax list, naming cooperating non-EU jurisdictions which have committed to pending tax governance reforms.
EU Greylist – definition card from the Heavnn University tax and residency glossary

What Is the EU Greylist?

The EU Greylist refers to Annex II of the European Union tax list, naming cooperating non-EU jurisdictions which have committed to pending tax governance reforms.

Also known as: EU Annex II, EU State of Play List.

How EU Greylist works

The EU Greylist is the informal name for Annex II, the state of play document attached to the EU list of non-cooperative jurisdictions for tax purposes, and it names non-EU jurisdictions which do not yet meet all international tax standards but have committed to reforms within agreed deadlines. Following the February 2026 revision, Annex II named nine jurisdictions, and the Council reviews progress at each twice-yearly update, with the next revision due in October 2026. A jurisdiction which delivers its commitments is generally removed, while one which misses deadlines may be moved to Annex I.

EU Greylist vs FATF grey list

Unlike the FATF grey list of jurisdictions under increased monitoring for money laundering and terrorist financing deficiencies, the EU Greylist concerns tax transparency, fair taxation and anti-BEPS commitments.

Example

Illustrative example: A nomad founder compares holding a company in Country A, which appears in Annex II, with Country B, which appears on no EU list. Annex II status by itself generally triggers no EU defensive tax measures, although banks and advisers may apply extra due diligence, and later delisting or blacklisting of Country A would change the assessment.

Common misconception

Myth: A company in a greylisted jurisdiction faces the same EU tax sanctions as one in a blacklisted jurisdiction.

Reality: The EU Greylist records pending commitments, and the defensive measures linked to non-cooperative status generally attach to Annex I jurisdictions rather than Annex II.

Frequently asked questions

Which countries are on the EU grey list?

The EU Greylist, Annex II, named nine jurisdictions after the February 2026 revision, including Belize, the British Virgin Islands, Montenegro, Morocco and Türkiye, with the next Council revision due in October 2026.

Is the EU grey list the same as the FATF grey list?

The EU Greylist is not the FATF grey list: the EU list tracks tax governance commitments, whereas the FATF list covers jurisdictions under increased monitoring for anti-money laundering and counter-terrorist financing deficiencies.

  • EU Blacklist — Annex I list of non-cooperative jurisdictions
  • Black List — National lists distinct from EU annexes
  • Tax Haven — Informal label distinct from formal EU listing
  • Economic Substance — Substance commitments often drive Annex II entries

Sources

Last verified: 2026-10-08. This entry is general information, not tax or legal advice; rules vary by country and change over time.

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Heavnn

Heavnn is a borderless tax technology solution supporting the future of work. We assist international remote workers with the design and implementation of their global tax setups.

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