Recent changes to the BVI Business Companies Act, 2004 and Limited Partnership Act, 2017, include a new statutory requirement. This requirement, effective from 2 January 2025, mandates all BVI entities to submit beneficial ownership information to the BVI Registrar of Corporate Affairs (Registrar), including details about the entity’s ultimate owners. Although this information is not publicly accessible, the amendment seeks to enhance transparency and help combat financial crimes in the jurisdiction. 

New requirements for BOI filing: What are the exemptions?

Certain limited exemptions from the requirement to file beneficial ownership information include licensed BVI investment funds. This means that they do not need to file beneficial ownership information with the Registry. However, they must maintain this information and be prepared to provide it to the Registry within 24 hours if requested.  

Additionally, beneficial ownership information must be held by a Category 6 license holder under the Securities and Investment Business Act, 2010 (SIBA), the fund’s authorised representative or another person licensed by the BVI Financial Services Commission with a local presence.  

This legislative amendment currently has a six-month transitional period ending on 1 July 2025. To qualify for this exemption, all existing funds must have filed with the Registry on or before the end of this transitory period.  

The exemptions to the new beneficial ownership information filing requirement also apply to listed companies, subsidiaries and companies subject to specified disclosure or transparency rules.  

We will provide an update once additional details are confirmed.  

Bolder fund solutions

As a leading global fund solutions provider, Bolder Group is committed to delivering exceptional client-focused services to our global clients, specifically in the BVI. Our team of experts can help you navigate the changing requirements for managing a fund and ensure compliance with regulatory requirements.  

For more information about our services, contact our team.  

Bolder Group does not provide financial, tax or legal advice and the information contained herein is meant for general information purposes only. We strongly recommend that before acting on any of the information contained herein, readers should consult with their professional advisers. The Bolder Group accepts no liability for any errors or omissions in the information, or the consequences resulting from any action taken by a reader based on the information provided herein.

Bolder Group refers to the global network of independent subsidiaries of Bolder Group Holding BV. Bolder Group Holding BV provides no client services. Such services are provided solely by the independent companies within the Bolder Group which are each legally distinct and separate entities and have no authority (actual, apparent, implied or otherwise) to obligate or bind Bolder Group Holding BV in any manner whatsoever. The operations of the Bolder Group are conducted independently and have no affiliation with third party financial, tax or legal advisory firms or corporations.