Compliance calendar for BVI Approved Managers – 2026

Deadline

Requirement

Action required / notes

1 January 2026

Beneficial ownership filings

By 1 January 2026, the manager must have filed its beneficial ownership information with the BVI Registrar of Corporate Affairs in accordance with the BVI Business Companies and Limited Partnerships (Beneficial Ownership) Regulations, 2024 (as amended).

If Ogier Global is the manager's registered agent, they will make the relevant filings (following receipt of required information from the manager).

31 January 2026

Annual return deadline

An annual return must be filed with FSC in the prescribed form providing details of the following, as at 31 December 2025:

(1) number of persons for which the manager provides services

(2) assets under management for each person for which the manager acts

(3) number of investors in each person for which the manager acts 

(4) any significant complaints received by the manager

(5) confirmation that each director and senior officer of, and shareholder holding a significant interest in, the manager is "fit and proper"

(6) that the manager is not in breach of the Regulations that entitle it to continue as a manager

Ogier's legal team can assist with the preparation and filing of the annual return.

31 March 2026

Annual fee due

Annual fee of US$1,800 is payable by the fund to the FSC.

If Ogier Global is the manager's authorised representative, they will include this fee as part of their annual bill to the manager and they will make the payment to the FSC.

31 March 2026

AML / CFT return deadline

The AML / CFT return must be filed for the period from 1 January to 31 December 2025 on the dedicated portal FSC AML / CFT return portal. 

If not already registered, the manager needs to register on the portal as a new user. The FSC have issued the below user guide on how to file an AML / CFT return. 

Access the AML / CFT return user guide.

31 May 2026

FATCA / CRS reporting deadline

The manager's FATCA authorised person is required to make the relevant FATCA / CRS filings via the BVI International Tax Authority's reporting portal. 

Ogier can provide FATCA / CRS services on request. 

31 March 2026

30 June 2026

30 September 2026

31 December 2026

Unaudited financial statements deadline

Unaudited financial statements for the manager must be submitted to the FSC within six months of the manager's financial year end (that is, by 30 June 2026 for funds with a 31 December 2025 year end). 

The financial statements must be approved or signed by a director or the general partner of the manager and must be accompanied by a director’s certificate, a report on the affairs of the manager made in respect of the relevant financial year and any other documents that may be prescribed by the Regulations. 

In limited circumstances, it is possible to request an extension to the filing deadline or an exemption from filing such accounts. The FSC will not accept late exemption / extension applications and so it is important that any such applications are made in advance of the filing deadline. The maximum extension permitted under law is six months. 

Ogier's legal team can assist with the filing of the unaudited financial statements. 

30 June 2026

Economic substance

Economic substance annual self-certification is due within six months of the end of the applicable reporting period. Self-certifications are submitted via the manager's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS). 

The statutory definition of "fund management business" does not currently require an Approved Manager to maintain substance in the BVI unless its activities also require an investment business licence. 

If Ogier Global is the manager's registered agent, they will make this filing as part of their services (following receipt of required information). 

30 September 2026

CRS additional information forms reporting deadline

The manager is required to make the relevant CRS filings via the BVI International Tax Authority's (the ITA) reporting portal - BVIFARS.

The ITA has released a guide: Guide to Completing the Additional Information Forms. 

Ogier Global's AEOI team provide FATCA / CRS services, including CRS training, and will be happy to discuss further on request.