The BVI International Tax Authority (ITA) has migrated all Economic Substance (ES) filing from the legacy Beneficial Ownership Secure Search system (BOSSs) to VIRRGIN, the Virtual Integrated Registry Regulatory General Information Network. The migration took effect January 2, 2026. Registered agents lost access to BOSSs on December 26, 2025. All future Economic Substance filings — new filings, amendments, and annual returns — must now be submitted exclusively through VIRRGIN.
What the Migration Means
BVI companies with Economic Substance obligations under the Economic Substance (Companies and Limited Partnerships) Act 2018 file annual ES declarations that demonstrate they maintain adequate substance in the BVI for their relevant activities. Under the legacy system, these declarations were filed through BOSSs. That system has now been decommissioned for registered agent use.
VIRRGIN is the BVI's consolidated regulatory filing platform, which now hosts BO filings, ROM filings, and ES declarations. Registered agents that were active in VIRRGIN for BO and ROM purposes following the January 2025 amendments to the Business Companies Act will already have VIRRGIN access. However, filing ES declarations through VIRRGIN requires confirmation that the registered agent has completed the relevant transition steps specific to ES filing capability.
The Risk of Assuming the Transition Is Complete
The practical risk with platform migrations is that companies and their principals assume the registered agent has transitioned and that filings are proceeding normally. BOSSs access was cut off on December 26, 2025. Any ES filing that was in preparation or pending submission through BOSSs at that point would need to have been resubmitted through VIRRGIN. Entities that have not confirmed the transition with their registered agent should do so promptly — ES filings submitted late attract financial penalties and can lead to striking off.
What To Do Now
Confirm with your registered agent that they are filing Economic Substance declarations through VIRRGIN. Check whether your company has relevant activities under the Economic Substance Act 2018 that create an ES declaration obligation. Ensure your ES declaration has been filed for the applicable financial period. If your registered agent is not yet set up for ES filing on VIRRGIN, contact the ITA or seek a registered agent that has completed the transition.