Industry Update: BVI Statutory Filings – Concession Period Extended to 31 March 2026

The BVI Financial Services Commission (FSC) has issued Registered Agents Circular No. 2 of 2025, granting a three-month concession period for certain statutory filings. This extension comes as welcome relief to entities and registered agents who were experiencing major challenges trying to meet the previous December 31, 2025 deadline as a result of operational issues experienced with the VIRRGIN registry system, particularly in relation to batch filings.

What Has Changed?

Under this concession, entities now have until 31 March 2026 to complete the following statutory filings without the enforcement of fees or penalties:

· Register of Members

· Beneficial Ownership (BO) Register

· Register of General Partners

· Register of Limited Partners

This applies to both outstanding and corrective filings that may have been delayed due to system limitations.

Registry Status and Enforcement Timeline

· From January 2026, entities with outstanding filings may temporarily reflect an “in-penalty” status on the Registry.

· No fees or penalties will be enforced until 1 April 2026.

· Once the required filings are completed during the concession period, the entity’s status will automatically revert to active.

Clients should note that the temporary “in-penalty” status is administrative in nature during this period and does not result in financial penalties if filings are regularised by the March deadline.

Operational Improvements to Support Compliance

To further assist registered agents and clients during this period, the Registry has introduced several operational enhancements:

· Manual batch filings are now permitted for items previously unavailable, including:

o Exemptions

o Exempted Owners

o Limited Partnership Registers

· Temporary access to VIRRGIN Lite for Hong Kong teams has also been extended until 31 March 2026, allowing continued operational support across jurisdictions.

Why This Matters for Clients

This concession provides valuable additional time for entities to bring their statutory records up to date without financial consequence, while also benefitting from improved filing functionality. However, clients are strongly encouraged not to delay action until the final deadline, as early compliance helps avoid registry status issues, administrative disruption, and unnecessary pressure closer to April 2026.

How CCP Can Assist

CCP Financial Consultants Limited continues to closely monitor regulatory developments and is well-positioned to support clients during this concession period. Our team can:

· Review your current statutory filing status

· Identify outstanding or corrective filings

· Coordinate and submit filings within the concession window

· Help ensure your entities remain in good standing ahead of the April 2026 enforcement date

📩 If you have any questions or would like assistance with your statutory filings, please contact the CCP team via email at mail@ccpbvi.com or call us at 1-284-494-6777 to discuss your next steps.