Industry Circular 11 of 2026 - Launch of Legitimate Interest Transactions and Request To Inspect BO

LAUNCH OF LEGITIMATE INTEREST TRANSACTIONS AND REQUEST TO INSPECT BO

With the launch of the Legitimate Interest (LI) transaction functionality on 1st April 2026, the BVI Financial Services Commission (the Commission) is reminding Registered Agents to exercise due care when using this function, particularly with respect to the applicable timeframes stipulated in the request to Inspect the Beneficial Ownership Register.

Key Process Timelines
Upon receipt of a request:

• The legal entity's Registered Agent will have five (5) days to file a Notice of Objection.
• The Registered Agent will then have a further five (5) days to file an Application Opposing Disclosure of Beneficial Ownership Information.

Following the Registrar's decision:

• Any Intent to Appeal must be filed within three (3) days (of the Registrar's decision).
• A Notice of Appeal must be filed within twenty-one (21) days thereafter.

Registered Agents are also reminded that the operational processing timeline for a LI transaction is twelve (12) days, where there has been no objection or opposition to disclosure. Agents are expected to manage applications carefully to ensure compliance with all prescribed timelines.

Dedicated Email Address
Agents should provide the Registry with a dedicated email address to receive notifications, to ensure their notifications are received and processed in a timely manner; failing this, emails will go to the default email address currently listed on the Agent's profile.

Dedicated email addresses should be submitted to [email protected]or [email protected]

General Filing Transactions
Agents should note the following transactions that will be available initially in General Filings:

• Notice to Registrar / No-Response from Beneficial Owner (R437)
• Withdrawal of Application Opposing Disclosure of Beneficial Ownership Information (R433)
• Notice of intent Appeal (R434)
• Notice of Appeal (R435)
• Decision of Appeal Board (R436)

Transactions in VIRRGIN
Agents should note the current status of the following transactions:

• Exemptions from disclosure of Particulars - Available
• Notice of Erroneous Filing and Notice of Recission of Erroneous Filing - Available
• Application for Extension to file BO Information - Only available for New Incorporations
• Notice of Correction and Notice of Change - Disabled for Exemptions only

Supporting Documents
All supporting documents should be submitted in English or, where relevant, translated into English and provided in PDF format. Information must not be submitted via links to documents, articles, or media websites, etc.

Certification
The Commission requires that all valid KYC documents uploaded be certified. These may include, but are not limited to, passport identification page or national ID card, driver's licence, utility bills, licenses, and certificates.

Update: Further Extension of Filing Link Access
A further extension has been granted for access to all filing links related to Registers of Directors (RODs), Registers of Members (ROMs), Beneficial Ownership (BO) filings, Register of General Partners (ROGP), and Register of Limited Partners (ROLP).

Filing links will now remain active until 31st May 2026. This additional extension is intended to allow Registered Agents sufficient time to download registers following the conclusion of the concession period.

Registered agents are encouraged to utilise this extended access period to ensure that all relevant registers are retrieved and records are properly maintained.

Local Companies and Non-Profit Organisations (NPOs)
Local companies and non-profit organisations (NPOs) are reminded of their obligation to file Beneficial Ownership (BO) information and Registers of Members (ROM) in accordance with the applicable requirements. Failure to comply with these filing obligations will result in the imposition of the relevant penalties.

Registered Agents are expected to take all necessary steps to ensure that entities under their administration meet these requirements by the deadline. No exceptions will be granted for companies or NPOs conducting business in the Virgin Islands.

Manual Filings
To facilitate the submission of manual filings by 31st March 2026, Agents should submit the templates via a secure method and provide the access details to the BO Unit at [email protected].

Zendesk Queries/ Open Tickets
As the concession period ends on 31st March 2026, the Commission is aware that Agents may have a number of outstanding matters requiring resolution. In certain cases, entities may be at risk of incurring penalties due to delays in filing while awaiting responses to email queries or open Zendesk tickets.

Agents are hereby informed that, where such instances are identified, penalties will not be applied until the matters have been reviewed and assessed on their individual merits. However, where the circumstances do not justify a waiver, all applicable penalties will be enforced.

To facilitate a timely and efficient review process, Agents are required to submit a consolidated list of all outstanding matters. This submission must include the relevant ticket numbers, transaction numbers, and dates, etc., to support the Commission's assessment.

Important Reminders for Registered Agents and Legal Practitioners:

• Upon the conclusion of the concession period, penalties will be assessed from 1st January 2026.

The maximum total Transitional Penalty per entity will amount to $1,400.00. Please refer to the Transitional Penalty Fee Table below:

• Additionally, entities will be required to pay the applicable filing fee of US$125.00 for filing beneficial ownership information for registration by the Registrar after 31st March 2026.
• VIRRGIN Lite access temporarily granted to overseas agents will be removed, and all access to VIRRGIN will be unavailable after 31st March 2026.

Please direct enquiries regarding this Industry Circular to [email protected] or [email protected].