TO: All Corporate Service Providers and Industry Stakeholders,

The Registrar of Companies advises that the Beneficial Ownership Amendment Act 2026 has been enacted following passage by the Legislature and receipt of the Governor’s assent on 14 September 2026.

Further to the Act, the Minister of Finance has also made the Beneficial Ownership Regulations 2026 and the Beneficial Ownership Exemption Order 2016.

Together, these measures update and strengthen Bermuda’s beneficial ownership framework.

Beneficial Ownership Amendment Act 2026

The Amendment Act strengthens the statutory framework for identifying and verifying beneficial owners and for maintaining adequate, accurate and up-to-date beneficial ownership information. Legal persons subject to the Act are required to take reasonable steps to verify the required information using a reliable and independent source.

It also updates requirements relating to the filing and updating of information, clarifies the treatment of certain ownership and control arrangements, provides for access to beneficial ownership information by authorized persons and enhances the Registrar’s compliance and enforcement powers. Certain time periods for updating and filing beneficial ownership information have also increased from 14 to 30 days.

The Act further strengthens the framework governing access to beneficial ownership information. Information is not generally available to the public. Different access arrangements apply to competent authorities carrying out their statutory functions, obliged entities for specified customer due diligence and discrepancy-reporting purposes, and persons who meet the requirements for legitimate interest access. Beneficial ownership information must also be securely protected, with restrictions applying to the further disclosure of information obtained from the Registrar.

Beneficial Ownership Regulations 2026

The regulations provide the detailed requirements and procedures necessary to give effect to the Act. They address matters including how beneficial ownership information is filed, the appointment and role of contact persons and the provision of information to the Registrar, applications for disclosure of beneficial ownership information, legitimate interest access, applications by beneficial owners for exemption from disclosure, the reporting of discrepancies in beneficial ownership information, and appeals against certain decisions of the Registrar.

Beneficial Ownership Exemption Order 2026

The Exemption Order identifies the categories of legal persons that may be exempt from filing beneficial ownership information with the Registrar, subject to the conditions set out in the order.

An exemption from filing does not remove the obligation to maintain the required beneficial ownership information and to ensure that it can be provided to the Registrar when required.

Effective Date

The Beneficial Ownership Amendment Act 2026 took effect on 14 September 2026

The Beneficial Ownership Regulations 2026 takes effect on 25 September 2026

The Beneficial Ownership Exemption Order 2026 takes effect on 25 September 2026

Documents

The Principal Act, Amendment Act, Regulations and Exemption Order are available through the links below:

The Beneficial Ownership Act 2025

The Beneficial Ownership Amendment Act 2026

The Beneficial Ownership Exemption Order 2026

The Beneficial Ownership Regulations 2026

Industry is accordingly advised so that affected entities and their advisors can review the new requirements and ensure that their beneficial ownership records, verification procedures and filings comply with the revised framework from the applicable effective date.

Should you have any questions in relation to this notice, please contact us at helpcenter@rocbda.bm.