Beneficial ownership guidance notes issued
Draft guidance notes to help companies comply with beneficial ownership rules have been issued, says the Office of the Registrar of Companies.
The documents are being provided ahead of anticipated legislative amendments expected this summer and are intended to assist entities in preparing for compliance and filing requirements.
The notes come as part of the implementation of the Beneficial Ownership Act 2025, which establishes a modernised framework requiring Bermuda registered entities to identify and maintain accurate, up-to-date information on their beneficial owners.
It is designed to strengthen oversight by the Registrar of Companies and supports Bermuda’s obligations to international standard-setting bodies on transparency and anti-money laundering.
David Burt, the Premier and Minister of Finance, said, “Strengthening Bermuda’s beneficial ownership framework reinforces our longstanding commitment to transparency, effective regulation, and maintaining our reputation as a well-regulated international financial centre.
“These measures support global standards while ensuring Bermuda remains a trusted and co-operative jurisdiction.”
The Act outlines requirements for identifying individuals who ultimately own or control legal entities, maintaining records, and submitting information to the Registrar within prescribed time frames. It also sets out enforcement provisions, including administrative actions for non-compliance.
The accompanying draft Regulations 2026 provide further detail on how entities must comply with the Act. This includes procedures for filing beneficial ownership information, verification requirements, timelines for updates, and the operational processes for maintaining the central register.
The regulations also address specific scenarios such as exemptions, reporting obligations for complex structures, and access to information in defined circumstances.
The revised draft Guidance Notes are intended to support practical understanding and implementation. They outline key definitions, clarify reporting expectations, and provide examples to assist entities in determining beneficial ownership and meeting their obligations. The notes also explain the scope of the regime, due diligence expectations, and the roles of corporate service providers and compliance professionals.
Stakeholders should note that these materials reflect the current Act and draft Regulations and are being issued as an interim measure, a government press release stated.
Further revisions are expected in the coming weeks, including amendments to the Act and Regulations, proposed exemption orders relating to trusts and funds, and updates relating to legitimate interest access.
The commencement of enforcement action has been deferred until August 31, 2026 to allow entities additional time to prepare.
Registered entities are encouraged to review the documents carefully and begin aligning their internal processes to meet the forthcoming requirements. Early preparation will support a smoother transition once the legislative framework is finalised and fully in force.
• The draft Beneficial Ownership Regulations 2026 can be accessed here and the revised Beneficial Ownership Guidance Notes here
