The BVI Financial Services Commission (FSC) has issued a new form for the annual financial return that BVI companies file with their registered agents. The BVI Business Companies (Financial Return) (Amendment) Order, 2026 was gazetted on 30 October 2026. It came into force on 2 November 2026 and replaces the Schedule to the 2023 Order, applicable from 1 January 2027.
The filing obligation itself is not new. What changes is the level of detail the form requires.
Quick answer: BVI companies must still file an annual financial return with their registered agent. The new form asks for a detailed breakdown of assets, revenue and expenses. The FSC has said it applies to 2026 annual returns, so companies should prepare their records now.
Why is the form changing?
The annual return exists to help the BVI meet the Global Forum standard on exchange of information on request. A Global Forum review found the BVI non-compliant on the availability of accounting records, known as Element A2.
The FSC says the revisions aim to make annual returns more valuable for exchanging information for tax purposes. It stresses that this is not a new requirement. The forms used to comply with the existing obligation are simply being modified.
What changes in the return?
The return still consists of a balance sheet and an income statement. The Order adds a definition for each asset category and asks for a value for each type of asset held:
- Cash and cash equivalents: each type held. Where held with a bank or other institution, its name and jurisdiction.
- Loans and receivables: principal plus accrued interest. Where these are 25% or more of total assets, details of each loan and receivable, valued by type (related party loans, third party loans, other).
- Investments and other financial assets: shares, bonds, mutual funds, REITs, derivatives, virtual assets and other, each valued.
- Tangible fixed assets: property, machinery, vehicles, furniture and fixtures, and equipment.
- Intangible assets: intellectual property, goodwill and software. “Intellectual property asset” has the meaning given in the Economic Substance Act.
- Other assets: anything that does not fit above, listed by type.
Revenue and expenses must also be categorised, with a value for each item. Examples include sales revenue, gains and interest income, as well as equipment, interest expense, sales commissions and cost of goods sold. The categories depend on what the company does.
Please note that these are based on the current financial return order released. We expect more clarifications, therefore please be alert in case clarifications/guidance is released by the authorities until the end of the year.
What stays the same?
Companies must still file the return with their registered agent within 9 months after the end of the financial year. Companies that qualify for an exemption under section 98A(5) of the BVI Business Companies Act remain exempt. The FSC confirms that the Order does not change the filing requirement.
The returns are not sent to the FSC. Registered agents keep them for at least 5 years after they cease to act, and must provide a copy to competent authorities on request. If a company fails to file on time, its registered agent must notify the Registrar of Corporate Affairs within 30 days after the due date.
The FSC has also said that no decision has been made to accept standard financial statements signed by BVI accountants in place of the prescribed form.
When does the new form apply?
The FSC has stated that the revised format applies to annual returns for 2026. These returns are filed with registered agents from September 2027 onwards. For example, a company with a 31 December 2026 year end has until 30 September 2027.
The Order contains no transitional provisions. Companies with a year end falling during 2026 should therefore confirm with their registered agent which format applies to them.
The FSC has also said it will publish guidance on what to report and how. Companies should review it once available.
What should companies do now?
Preparation is mostly a bookkeeping exercise. Companies should:
- Record revenue and expenses by category throughout the year, not only at year end.
- Keep a clear schedule of bank accounts.
- Maintain details of loans, including related party loans, particularly where they reach 25% of total assets.
- List investments and virtual assets by type, with a valuation for each.
- Speak to their registered agent early about the format and timing of the return.
As accountants to BVI companies, we can map your accounting records to the new categories and prepare the return on the company’s behalf. Ready to speak to our team? Contact us via email here.
Sources
- BVI Financial Services Commission: BVI Business Companies (Financial Return) (Amendment) Order, 2026 (S.I. 2026 No. 71), gazetted 30 October 2026.
- FSC, Upcoming Revisions to the Financial Return Orders: Frequently Asked Questions, published 15 October 2026.
This article is intended for general informational purposes only and does not constitute tax, legal, or professional advice. Every group structure is different, and the application of these rules to your specific facts requires a proper professional assessment. Asterisk BVI accepts no liability for any action taken or not taken in reliance on the information contained in this article. If you need advice specific to your situation, contact us today.
