Navigating the New Beneficial Ownership Regulations: July 2025 Amendments

n 1 July 2025, the Government of the British Virgin Islands implemented a significant update to the jurisdiction’s beneficial ownership regime through amendments to the Business Companies and Limited Partnerships (Beneficial Ownership) Regulations 2024. These changes are part of an ongoing effort to refine the BVI’s regulatory landscape, balancing global transparency standards with the jurisdiction’s long-standing commitment to privacy, efficiency, and investor confidence.

Strengthening the Framework: Key Amendments

The latest amendments focus on two key areas: (1) clarifying and expanding exemptions to beneficial ownership reporting requirements, and (2) implementing the framework for “legitimate interest” access to ownership information.

Expanded Exemptions

The Regulations introduce welcome clarifications to the scope of existing exemptions. Companies may now qualify for exemptions where:

• They are subsidiaries of investment funds (including foreign funds) that maintain and can provide beneficial ownership information upon request.
• They are subsidiaries of companies listed on a recognised stock exchange.
• More than 50% of their shares or voting rights are held by a foreign government or the BVI Government.
• Their shares are held by a trustee regulated for AML/CFT/CPF purposes in another jurisdiction.

These exemptions will be particularly relevant for structures involving regulated trustees, international investment entities, and publicly listed parents.

Legitimate Interest Access Regime

The BVI has now established a framework allowing access to beneficial ownership information based on a “legitimate interest” test. This regime will become operational in April 2026 and applies only to individuals or entities that can demonstrate a direct and lawful interest in the information—for example, in connection with regulatory investigations or legal proceedings related to financial crime.

The regime is deliberately narrow in scope and accompanied by a number of procedural safeguards:

• Only beneficial owners with a 25% or greater interest may be disclosed.
• Requests must be submitted via the VIRRGIN platform and supported by specific information.
• Entities will be notified of any access requests and have five business days to file an objection.
• Grounds for objection or exemption include risks of harm, national security considerations, and concerns over the public interest.
• If an objection or exemption request is denied, an appeal process is available, during which disclosure will be suspended.

What This Means for BVI Entities

While these changes primarily concern regulators and parties seeking access, BVI entities should take this opportunity to review their compliance posture. We recommend:

• Verifying that all beneficial ownership information on record is current and accurate.
• Assessing whether your structure qualifies for any of the newly clarified exemptions.
• Preparing internal protocols in case of a notification regarding an access request.
• Seeking legal advice promptly if an objection or exemption may be necessary.

A Balanced Approach to Transparency and Privacy

The BVI’s regulatory strategy continues to evolve in response to international expectations, while remaining mindful of the legitimate privacy concerns of investors, family offices, and commercial enterprises. These amendments reinforce the BVI’s position as a leading financial services jurisdiction—one that supports global standards without compromising the rights of stakeholders.

At CCP BVI, we are closely monitoring these developments and are well-positioned to assist clients in navigating the new framework. Whether your entity may qualify for an exemption or you simply wish to understand how these changes impact your structure, our team is here to help.