BVI Financial Services Commission: Updates to Statutory Filing Requirements

This article was originally posted on 24 Dec 2025, at a time when the organisation operated as Harneys Fiduciary. 

The BVI Financial Services Commission has published a new industry update providing clarity on statutory filing requirements under the BVI Business Companies Act and the Limited Partnership Act, particularly in relation to Beneficial Ownership (BO) and related registers.

Set out below is a short summary of the key points, for full details, please refer to the FSC’s industry circular.

Temporary Pause on Fees and Penalties

Existing companies and limited partnerships (formed before 2 January 2025) can file ROM, ROGP, ROLP and BO information without filing fees or late penalties until 31 March 2026.

Important to note

This doesn’t change the underlying filing obligations, it’s a temporary pause on enforcement. Fees and penalties return from 1 April 2026.

“In Penalty” status

Entities that haven’t filed yet may show as “in penalty”, but no penalties will be charged during the concession period. Status will update once filings are completed. Certificates of good standing and incumbencies may not be available during this period. 

Entities Already in Penalty

Existing entities already marked as in penalty can now submit outstanding filings (with or without paying annual fees) up to 31 March 2026.

What Happens Next

From 1 April 2026, the FSC will move to full enforcement, including penalties where applicable.

If you have any questions, please do not hesitate to reach out to your usual key contact.