Key takeaways

Legislation + record-keeping changes

• BVI companies are now subject to increased reporting and compliance obligations following recent legislative changes introduced during 2024 and implemented throughout 2025.
• The BVI Registry is actively monitoring compliance and, in some cases, issuing automated penalty notifications shortly after filing deadlines are missed.

Registers

• Beneficial ownership register filings are now fully operational within the VIRRGIN system, with recent system updates making the submission process more streamlined.
• Certain entities, including foreign trustees and state-owned entities, may be eligible for exemptions from disclosure, which can now be filed through the standard system process.

Financial Annual Returns

• All BVI companies and limited partnerships are required to provide an annual financial return to their registered agent. While this return is not publicly filed, it must be submitted within the prescribed deadline.
• Where an annual financial return is not provided on time, the registered agent is required to notify the regulator, which will result in the entity being marked as not in good standing.
• An entity that is not in good standing will not be able to obtain a certificate of good standing. This position can be rectified once the outstanding filing is completed, but delays may cause transactional or administrative disruption.
• Due to an extension in relation to the first filing period, many entities were required to submit two annual financial returns in 2025, covering financial periods ending 31 December 2023 and 31 December 2024, within a relatively short timeframe.

Accessibility of beneficial ownership information

• From early January 2026, beneficial owners will be able to apply for non-disclosure of their information where specific conditions are met, including in cases involving minors or personal risk. Evidence will be required to support any application.
• Applications for non-disclosure will begin to be accepted in January 2026 and should be considered well in advance of 1 April 2026, when accessibility of certain beneficial ownership information is expected to begin, subject to legitimate interest.

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