The BVI Business Companies (Amendment) Act 2024 introduced mandatory Beneficial Ownership (BO) and Register of Members (ROM) filing requirements for all BVI Business Companies. When the Act came into force on January 2, 2025, a moratorium on penalties for missed filings was put in place to allow companies time to comply. That moratorium expires in four days, on March 31, 2026.
What Changes on April 1, 2026
From April 1, 2026, any BVI company that has not completed its BO and ROM filings will be classified as In Penalty and will face the full suite of enforcement consequences under the Act. This includes financial penalties and potential striking-off of the company from the BVI register.
The filing links issued to existing pre-2025 companies also expire on March 31, 2026. Companies that have received but not yet used their filing links must act before that deadline. After March 31, obtaining new links will require direct engagement with the registered agent.
What Becomes Public on April 1, 2026
Separately, from April 1, 2026, BVI beneficial ownership information becomes accessible by members of the public under a legitimate interest regime. Individuals or entities that hold or represent interests of 25% or more will be able to access BO records through the VIRRGIN platform by demonstrating a legitimate interest. This marks a significant change from the current restricted-access model and affects how beneficial ownership data is treated going forward.
Who Is Exempt
BVI-listed companies and BVI-regulated funds are exempt from BO and ROM filing requirements. All other BVI Business Companies must file.
What To Do Now
If your BVI company has not yet completed its BO and ROM filings, you must act before March 31, 2026. Contact your BVI registered agent today to confirm whether your filings are complete and, if not, to submit them before the moratorium and filing links expire.