Accessing beneficial ownership information in the BVI: the new "legitimate interest" regime

Effective 1 April 2026, the BVI will implement a "legitimate interest" framework for accessing beneficial ownership information.  

The purpose of this legislative update is to ensure the BVI remains a leading and compliant jurisdiction, while also protecting privacy of individuals. Only those with a valid and specific reason, such as investigating or preventing financial crime, can access beneficial ownership (BO) information. This means transparency will only be used where necessary.

Who can access the registry for beneficial ownership information? 

Access to beneficial ownership information is now no longer restricted solely to certain competent authorities and law enforcement, but is now extended to other persons who can demonstrate a "legitimate interest" to view that information to the BVI Registrar to demonstrate a legitimate interest however the request must meet strict criteria, these are that:

• the purpose of the request must be to investigate, prevent or detect money laundering, terrorist financing or proliferation financing
• the legal entity to which the request relates is connected to a person (i.e. the beneficial owner) convicted of or subject to criminal proceedings for the offence of money laundering, terrorist financing or proliferation financing
• the request is made by an "obliged entity" (i.e. law firm or other professional undertaking) which is required to conduct client due diligence under BVI anti-money laundering or counter terrorist or proliferation financing laws

However, while the ability to seek disclosure has been broadened, significantly the new rules allow beneficial owners to apply for standing exemptions from disclosures or object to particular requests to protect themselves on various grounds including safety concerns or other sensitivities. More information on the grounds for exemption or objection is set out below.

Requirements for access to beneficial ownership information 

To request an inspection via the Virtual Integrated Registry and Regulatory General Information Network (VIRRGIN) platform, an applicant must demonstrate interest by providing credible evidence that the request is for investigating money laundering, terrorist financing or fulfilling regulatory AML / KYC obligations and pay a non-refundable US$75.00 inspection fee, per request.

While entities file at a 10% threshold, disclosure is limited to beneficial owners holding 25% or more interest. 
  

Objection and appeal process  

The BVI regime includes strong checks and balances to protect individuals from unnecessary exposure. When a valid request is received by the Registrar, the entity’s Registered Agent will be notified.

Objection: the entity has five business days to file a "notice of objection" with the registry. Valid grounds include a reasonable belief that disclosure would expose the beneficial owner to a serious risk of fraud, kidnapping, violence or intimidation, or where the owner is a minor.

Appeal: if the Registrar intends to proceed despite an objection, the entity has a three business day window to file a "notice of intent" to appeal. This filing acts as an automatic stay, preventing the release of data while the matter is reviewed by the registrar. 

Appeal board: a formal appeal must be submitted to the registrar within 21 days. This ensures that requester's interest truly outweighs the potential for serious harm to the individual. 

Exemptions 

As of 2 January 2026, entities can apply for advance exemptions, ensuring their privacy is shielded before a third-party request is made. The grounds on which an exemption may be filed are:

• reasonable grounds to believe that any disclosure would place a BO or a BO's spouse, live-in partner, child (biological or adopted), parent or sibling (full blood or half-blood) at serious risk of fraud, kidnapping, blackmail extortion, harassment, violence, intimidation or other similar harm information relates to a child or an individual who lacks legal capacity
• information will or is likely to raise or affect issues of national security, whether in the British Virgin Islands or elsewhere
• request is of a nature that the Registrar should consider not to be in the public interest to accede to
• any other special reasons existing that would warrant refusal

Should you have any questions on the Legitimate Interest Regime or require assistance with applying for an advanced exception reach out to your usual Ogier contact or the team below. 

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Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

Regulatory information can be found under Legal Notice