The British Virgin Islands Financial Services Commission (BVI FSC) has issued guidance that specifies the target dates by which the Registry of Corporate Affairs must receive reports on almost all transactions related to beneficial ownership.
Beneficial ownership reporting via the recently constructed VIRRGIN system was officially initiated on January 2, 2025; however, the system is still in the process of being implemented.
Consequently, the initial function to be implemented is the Amendment to Register of Directors – Notice of Changes (Single Filing), with a target launch date of March 16, 2025. On April 4, 2025, an amendment to the Register of Directors will be implemented, which will include the correction of directors (by single filing). On May 1, 2025, it will be possible to submit individual modifications to the membership registry. From May 16, notices of individual modifications to the Beneficial Ownership register will be permitted. The BVI FSC acknowledges that dates that are so far in the future may be altered if necessary.
Given the substantial volume of filing that must be completed, the majority of agents will opt for batch- or bulk-filing to simplify their filing obligations. The schema for this type of filing is presently being finalised by the development team and will be distributed to all agents prior to the launch of the function.
Industry practitioners have expressed numerous technical, legislative, and logistical concerns since the implementation of beneficial ownership reporting on January 2, 2025.
The BVI FSC observes that Regulation 25 of the BVI Business Companies and Limited Partnerships (Beneficial Ownership) Regulations 2024 emphasises the restriction of access to beneficial ownership information to designated competent authorities and law enforcement agencies. This could be employed by a legal professional or insolvency practitioner who is investigating suspected financial or business misconduct, for example, as notifying the beneficial proprietor of the request could jeopardise the investigation.
