The BVI Financial Services Commission (“the Commission”) updated its statutory filing requirements under the BVI Business Companies Act, Revised Edition 2020 (the “Act”) and the Limited Partnership Act, Limited Partnership Act, Revised Edition 2020 (the “LP Act”).
The Commission has approved transitional measures to support the full implementation of the Beneficial Ownership regime and related register filing requirements. These time-limited measures, developed in response to feedback from industry stakeholders, aim to help mitigate operational and systemic issues experienced by the industry and are designed to further facilitate full compliance with BO filing requirements. Upon expiry of the concession period, relevant enforcement measures will be consistently applied.
TEMPORARY SUSPENSION OF FILING FEES AND DEFERRAL OF APPLICATION OF PENALTIES
The Commission has approved an extension of the period during which existing entities may file Registers of Members (ROM), Registers of General Partners (ROGP), Registers of Limited Partners (ROLP), and Beneficial Ownership (BO) information for existing entities (incorporated before 2 January 2025), without filing fees and penalties, until 31 March 2026.
FEES AND PENALTIES
Filing fees and late filing penalties for ROM, ROGP, ROLP, and BO will be reinstated from 1 April 2026. This extension does not amend the statutory transitional filing deadline but represents only a deferral of enforcement of penalties and a temporary suspension of filing fees for a period of 3 months.
Companies that have not filed the requisite information will have their status reflected as “in penalty”. However, no penalties will be charged for the stated period. The status will be changed to active once the requisite filings are made.
FILING FOR ENTITIES IN PENALTY
Existing companies and limited partnerships currently in penalty status are now permitted to file ROM, ROGP, ROLP, and BO documents with or without payment of annual fees until 31 March 2026.