BVI beneficial ownership filings: An update for clients

Following recent changes to the BVI’s beneficial ownership (BO) framework, this update outlines where matters currently stand, particularly for existing entities (incorporated before 2 January 2025) that have not yet filed their beneficial ownership and other statutory registers (register of members / registers of general and limited partners).

Whilst no financial penalties are being imposed currently the compliance requirements are now fully in effect and entities which have not yet arranged the filing of their registers should do so without further delay.

Filing deadline remains unchanged

The statutory deadline for filing BO information has not been extended. Entities that have not yet filed their BO registers are therefore not in good standing.

Enforcement timing

The BVI authorities have confirmed that penalties and filing fees will not be enforced until after 31 March 2026, allowing time for current filing volumes to be addressed. Once enforcement begins on 1 April 2026, penalties will apply automatically and increase on a monthly basis. The Registrar can also impose administrative penalties for varying offences under the beneficial ownership regime with penalties ranging from $10,000 to $75,000 for more serious offences.

Existing entities that fail to file their outstanding registers will be automatically liable to a fixed penalty of $600 for the first three months that the register is outstanding, $800 for the second three months that the register is outstanding and will then be liable to be struck off by the Registrar at the end of the six months. These penalties will be levied for each register that is outstanding. If your entity has two registers outstanding for example, your entity will incur a $1,200 penalty in addition to the Registry filing fees becoming payable for each register.

Practical impact for entities

Entities that are not in good standing cannot process transactions at the BVI Registry. This may delay routine corporate matters, particularly where transactions or corporate changes are planned.

Addressing any outstanding filings as soon as possible will help minimise disruption.

Current filing volumes and our February cut-off

Registered agents across the BVI are managing high volumes of BO filings.

At Harneys Fiduciary, we are progressing filings promptly where complete information has been provided.

To provide certainty, we have set a cut-off of 26 February 2026 for clients to supply the necessary information for filing the registers. Where complete information is received by this date, we can confirm filings will be completed ahead of enforcement action.

What should clients do next

• We recommend that clients review the status of their entity’s register and, where it remains outstanding, attend to the required submissions.

Taking action now will help ensure entities remain operational and avoid issues later.

Once registers have been filed, the registry must be updated within 30 days of any changes – this includes changes to people, and their particulars – name, address, percentage band, mechanism of control etc., and transactions – new share certificates. The registry is issuing penalties automatically where registers are updated more than 30 days after the change so entities need to be very conscious of the timing of their updates.

How we can assist

Our teams continue to support clients with the BVI’s evolving BO requirements, helping to clarify obligations, manage filings, and address good standing issues where needed.

If you have any questions or would like assistance, please contact your usual Harneys Fiduciary relationship manager.