Marie-Claire Fudge
Partner | Legal
British Virgin Islands
Marie-Claire Fudge
Partner
British Virgin Islands
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Set out below is a legal and regulatory compliance calendar for 2026, providing the key dates for British Virgin Islands investment funds in the year ahead.
To help you keep track of upcoming deadlines, select the calendar(s) for your BVI fund entity type in the calendar feature below. This will auto-populate your calendar with all the key dates for each type of fund selected. Alternatively, you can select the individual dates you would like to be reminded about.
| Deadline | Requirement | Action required / notes |
| 1 January 2026 | Beneficial ownership filings |
By 1 January 2026, the fund must have either:
Ogier can advise on how to claim the exemption referred to above. If Ogier Global is the fund's registered agent, they will make the relevant filings (following receipt of required information from the fund). |
| 31 January 2026 | Semi-annual return deadline |
A semi-annual return must be filed with the BVI Financial Services Commission (the FSC) in the prescribed form providing details of the following, as at 31 December 2025: (1) number of investors in the fund (2) total investments in the fund (3) aggregate subscriptions to the fund (4) aggregate redemptions paid to investors (5) net asset value of the fund (6) details of any significant complaint received by the fund and how the complaint was dealt with (7) confirmation the fund is not in breach of the Securities and Investment Business (Incubator and Approved Funds) Regulations, 2015 (as amended) Ogier can assist with the preparation and filing of the semi-annual return. |
| 31 March 2026 | Annual fee due |
Annual fee of US$1,200 is payable by the fund to the FSC. If Ogier Global is the fund's authorised representative, they will include this fee as part of their annual bill to the fund and they will make the payment to the FSC. |
| 31 May 2026 | FATCA / CRS reporting deadline |
The fund's FATCA authorised person is required to make the relevant FATCA / CRS filings via the International Tax Authority's reporting portal. Ogier Global's Automatic Exchange of Information (AEOI) team provide FATCA / CRS services, including CRS training, and will be happy to discuss further on request. |
|
31 March 2026 30 June 2026 30 September 2026 31 December 2026 |
Unaudited financial statements deadline |
Unaudited financial statements for the fund must be submitted to the FSC within six months of the fund'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 fund. 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 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 fund's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS). An incubator fund will be considered to be undertaking "investment funds business" for the purposes of the BVI's economic substance legislation, which is not a relevant activity for the purposes of that legislation. If Ogier Global is the fund's registered agent, they will make this filing as part of their services (following receipt of required information). |
| 31 July 2026 | Semi-annual return deadline |
A semi-annual return must be filed with the FSC in the prescribed form providing details of the following, as at 30 June 2026: (1) number of investors in the fund (2) total investments in the fund (3) aggregate subscriptions to the fund (4) aggregate redemptions paid to investors (5) net asset value of the fund (6) any significant investor complaint received by the fund and how the complaint was dealt with Ogier can assist with the preparation and filing of the semi-annual return. |
| 30 September 2026 | CRS additional information forms reporting deadline |
The fund 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 to Completing the Additional Information Form. Ogier Global's AEOI team provide FATCA / CRS services, including CRS training, and will be happy to discuss further on request. |
| Deadline | Requirement | Action required / notes |
| 1 January 2026 | Beneficial ownership filings |
By 1 January 2026, the fund must have either:
Ogier can advise on how to claim the exemption referred to above. If Ogier Global is the fund's registered agent, they will make the relevant filings (following receipt of required information from the fund). |
| 31 January 2026 | Annual return deadline |
An annual return must be filed with the BVI Financial Services Commission (the FSC) in the prescribed form providing details of the following, as at 31 December 2025: (1) number of investors in the fund (2) total investments in the fund (3) aggregate subscriptions to the fund (4) aggregate redemptions paid to investors (5) net asset value of the fund (6) details of any significant complaint received by the fund and how the complaint was dealt with (7) confirmation the fund is not in breach of the Securities and Investment Business (Incubator and Approved Funds) Regulations, 2015 (as amended) Ogier can assist with the preparation and filing of the annual return. |
| 31 March 2026 | Annual fee due |
Annual fee of US$1,200 is payable by the fund to the FSC. If Ogier Global is the fund's authorised representative, they will include this fee as part of their annual bill to the fund and they will make the payment to the FSC. |
| 31 May 2026 | FATCA / CRS reporting deadline |
The fund's FATCA authorised person is required to make the relevant FATCA / CRS filings via the International Tax Authority's reporting portal. Ogier Global's AEOI team provide FATCA / CRS services, including CRS training, and will be happy to discuss further on request. |
|
31 March 2026 30 June 2026 30 September 2026 31 December 2026 |
Unaudited financial statements deadline |
Unaudited financial statements for the fund must be submitted to the FSC within six months of the fund'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 fund. 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 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 fund's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS). An approved fund will be considered to be undertaking "investment funds business" for the purposes of the BVI's economic substance legislation, which is not a relevant activity for the purposes of that legislation. |
| 30 September 2026 | CRS additional information forms reporting deadline |
The fund is required to make the relevant CRS filings via the International Tax Authority's (ITA) reporting portal - BVIFARS. The ITA has released a 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. |
| Deadline | Requirement | Action required / notes |
| 1 January 2026 | Beneficial ownership filings |
By 1 January 2026, the fund must have either:
Ogier can advise on how to claim the exemption referred to above. If Ogier Global is the fund's registered agent, they will make the relevant filings (following receipt of required information from the fund). |
| 31 March 2026 | Annual fee due |
Annual fee of US$1,200 is payable by the fund to the BVI Financial Services Commission (the FSC). If Ogier Global is the fund's authorised representative, they will include this fee as part of their annual bill to the fund and they will make the payment to the FSC. |
| 31 May 2026 | FATCA / CRS reporting deadline |
The fund's FATCA authorised person is required to make the relevant FATCA / CRS filings via the International Tax Authority's reporting portal. Ogier Global's AEOI team provide FATCA / CRS services, including CRS training, and will be happy to discuss further on request. |
| 30 June 2026 | Mutual funds annual return (MFAR) deadline |
MFAR filing with the FSC is undertaken via a dedicated Mutual Funds Annual Returns Application portal in relation to the calendar year ending 31 December 2025. Registration on the portal is required, if not previously done. The FSC has issued Mutual Fund Annual Returns Guidance Notes on the MFAR submission. |
|
31 March 2026 30 June 2026 30 September 2026 31 December 2026 |
Audited financial statements deadline |
Audited financial statements for the fund must be submitted to the FSC within six months of the fund's financial year end (that is by 30 June 2026 for funds with a 31 December 2026 year end). In limited circumstances, it is possible to request an extension to the filing deadline or an exemption from filing such accounts. Extension and exemption requests must be submitted to the FSC within six months after the relevant financial year end. 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 nine months. Ogier can assist with the filing of the audited 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 fund's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS). Professional and private funds will be considered to be undertaking "investment funds business" for the purposes of the BVI's economic substance legislation, which is not a relevant activity for the purposes of that legislation. |
| 30 September 2026 | CRS additional information forms reporting deadline |
The fund 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 to completing the additional information forms. 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. |
| Deadline | Requirement | Action required / notes |
| 1 January 2026 | Beneficial ownership filings |
By 1 January 2026, the fund must have either:
Ogier can advise on how to claim the exemption referred to above. If Ogier Global is the fund's registered agent, they will make the relevant filings (following receipt of required information from the fund). |
| 31 March 2026 | Annual fee due |
Annual fee of US$1,200 is payable by the fund to the BVI Financial Services Commission (the FSC). If Ogier Global is the fund's authorised representative, they will include this fee as part of their annual bill to the fund and they will make the payment to the FSC. |
| 31 May 2026 | FATCA / CRS reporting deadline |
The fund's FATCA authorised person is required to make the relevant FATCA / CRS filings via the International Tax Authority's reporting portal. Ogier Global's AEOI team provide FATCA / CRS services, including CRS training, and will be happy to discuss further on request. |
|
31 March 2026 30 June 2026 30 September 2026 31 December 2026 |
Audited financial statements deadline |
Audited financial statements for the fund must be submitted to the FSC within six months of the fund's financial year end (that is by 30 June 2026 for funds with a 31 December 2025 year end). In limited circumstances, it is possible to request an extension to the filing deadline or an exemption from filing such accounts. Extension and exemption requests must be submitted to the FSC within six months after the relevant financial year end. 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 nine months. Ogier can assist with the filing of the audited 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 fund's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS). A private investment fund will be considered to be undertaking "investment funds business" for the purposes of the BVI's economic substance legislation, which is not a relevant activity for the purposes of that legislation. |
| 30 September 2026 | CRS additional information forms reporting deadline |
The fund 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 to completing the additional information forms. 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. |
Ogier's team of fund regulatory experts can advise on all aspects of Cayman Islands fund regulation.
Our legal team works closely with Ogier Global, who can offer services such as AML officers and FATCA and CRS compliance and reporting services.
Reach out to your regular Ogier contact, or any member of the team listed below, should you require any assistance.
Ogier is a professional services firm with the knowledge and expertise to handle the most demanding and complex transactions and provide expert, efficient and cost-effective services to all our clients. We regularly win awards for the quality of our client service, our work and our people.
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
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