From 2 January 2025, all BVI Business Companies and Limited Partnerships must file their beneficial ownership information through the VIRRGIN system. This regulatory development aligns with international transparency standards and is a significant move toward strengthening corporate compliance within the jurisdiction.

The BO filing regime is being rolled out in phases to ease the transition process for stakeholders.

Below are the essential components and timelines to keep in mind.

Key dates:

• 2 January 2025– Filing requirements officially commenced
• 31 March 2025– Schema for batch or bulk filings to be released, facilitating filings for entities handling higher volumes
• 17 April 2025– Batch/bulk filing functionality to become operational

The incremental approach provides companies and their agents ample time to adapt to the new system.

To address industry concerns, several aspects of the new system have been clarified:

• Batch/bulk filing feature:Highly anticipated by agents managing large-scale filings, this feature will streamline multi-entity data submissions
• Interdependency of registers:Information for registers of directors, members, and beneficial owners can be filed independently and in no specific order
• Supporting documentation requirements: Documentation is only required if data anomalies, such as missing names or dates of birth, occur

The BVI FSC has provided additional details to clarify some of the recurring concerns raised by stakeholders:

• Exemptions:Entities that are subsidiaries of publicly listed companies are exempt from certain BO filing requirements. However, at this time, the filing function in VIRRGIN is not yet available. Please refer to the schedule of timelines/dates for the release of all functions accessible through the schedule included in the circular.
• Technical issues: Errors in VIRRGIN (ie, 505 Error Page and 500 Error Page) could be related to the internet browser being used by the user. Chrome and Firefox are recommended browsers for optimal performance. The BVI FSC recommends clearing your cache, try using a different browser, and submit your request again. If the problem continues, the BVI FSC requests to send an email with the error message to support@bvifsc.vg or bo@bvifsc.vg.
• Penalties for non-compliance:If attempts to file a transaction are made and the function is not available in VIRRGIN, the company will not incur penalties if the Registry is notified of the attempt to file a transaction. A list of entities and the reasons for their non-filing should be submitted to the Registrar, and a penalty fee will not be charged to these entities.
• Future updates: Updated FAQs to address additional concerns are expected to be published shortly and periodically thereafter. For assistance, the BO Unit may be contacted by emailing queries to bo@bvifsc.vg or through the help desk at support@bvifsc.vg.

The FSC emphasises the importance of adhering to deadlines as outlined in the updated timeline. Agents and corporations are advised to monitor the FSC site regularly for updates.

Circular 12 can be found here.

Find our in-depth guide here, offering comprehensive insights into the latest developments on BVI's BO regulations.