Key 2024 regulatory filing deadlines for BVI Approved Managers

Filing requirement

Date due

Notes

Annual return filings

By 31 January 2024

Annual return must be filed in the prescribed form and provide details of the following, as at 31 December of the prior year:

• number of persons for which the Approved Manager provides services
• assets under management for each person for which the Approved Manager acts
• number of investors in each person for which the Approved Manager acts
• any significant complaints received by the Approved Manager

In addition, the return needs to include confirmation that:

• each director and senior officer of, and shareholder holding a significant interest in, the Approved Manager is "fit and proper"
• the manager is not in breach of the Regulations that entitle it to continue as an Approved Manager

AML/CFT Return

By 31 March 2024

Filings are made on the BVI Financial Service Commission's dedicated portal:BVI FSC - VIRRGIN Returns.

This is the user guide for the filing portal: aml-cft_user_guide_interactive.pdf (bvifsc.vg).

Unaudited financial statements

Within 6 months of Approved Manager's financial year end (ie by 30 June 2024 for approved manager with a 31 December 2023 year-end)

In limited circumstances, it is possible to request an extension to the filing deadline for filing such accounts.

Extension requests must be submitted to the commission within six months after the relevant financial year end. The maximum extension permitted under law is six months.

AEOI reporting

Annual reporting submission deadline for FATCA*/CRS is 31 May each year

Filings are made on the International Tax Authority's reporting portal: BVIFARS - BVI ITA.

Economic substance

Annual self-certification due within six months of the end of the applicable reporting period

Self-certifications are submitted via the approved manager's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS).

As an approved manager, significantly the manager will not fall within the statutory definition of "fund management business" for the purposes of the BVI's economic substance legislation.