BVI Key Updates on Access to BO Information
The British Virgin Islands continues to align its beneficial ownership framework with international standards on transparency and anti-financial crime measures. The BVI Business Companies and Limited Partnerships (Beneficial Ownership) (Amendment) Regulations, 2025 took effect on 1 July 2025. These changes introduce structured rules for accessing the beneficial ownership (BO) register maintained by the Registrar of Corporate Affairs, while maintaining strong privacy safeguards.
Although the amendments are already in force, a transitional period applies. Requests from persons demonstrating a legitimate interest will only start being accepted from 1 April 2026.
Definition of Beneficial Owner for Access Purposes
Beneficial ownership information access is limited to direct or indirect ownership or control of 25% or more of the shares or voting rights.
This threshold ensures that only significant ownership or control positions are subject to potential disclosure under legitimate-interest requests, consistent with the BVI's balanced approach to transparency and privacy protection.
Who Has Access Rights?
Access to BO information remains restricted and purpose-driven. The following categories have rights:
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Competent Authorities — including the Attorney General, the Governor of the BVI, the Financial Investigation Agency (FIA), the Financial Services Commission (FSC), the International Tax Authority (ITA), and any other body designated by the Governor; and
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Law enforcement agencies and parties under exchange arrangements between the BVI and UK Governments.
Beyond these, access is available to persons or entities that can clearly demonstrate a legitimate interest, specifically for purposes related to investigating, preventing, or detecting:
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Money laundering
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Terrorist financing
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Proliferation financing
Examples of those who may qualify include:
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Financial institutions and designated professionals — such as banks, lawyers, and corporate service providers performing mandatory customer due diligence (CDD) or enhanced due diligence under the BVI AML regime.
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Parties conducting forensic or investigative work — seeking to connect a BVI entity to individuals convicted of (or charged with) relevant financial crimes.
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NGOs, civil society organizations, and media/journalists — actively probing financial crime matters (subject to rigorous verification by the Registrar).
What Entities Should Do Now
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Review your current BVI structure to identify any automatic exemptions from filing or disclosure obligations (e.g., subsidiaries of funds, entities with listed parents, government-owned bodies, or those involving regulated foreign trustees).
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If privacy, security, or other significant concerns exist (such as risks to personal safety or sensitive commercial interests), contact your Relationship Manager promptly to discuss options, including potential applications for exemptions (available from 2 January 2026).
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Maintain accurate, up-to-date BO records to respond effectively to any future legitimate-interest requests.
These enhancements reinforce the BVI's commitment to combating financial crime while protecting legitimate privacy interests. The regime is not a public register — access remains tightly controlled and evidence-based.
For personalized guidance on how these changes may affect your entities or to prepare accordingly, please reach out to your Relationship Manager or any member of our team.