On 6 November 2026, the BVI Financial Services Commission (FSC) published guidance on completing the revised annual financial return. It was issued with Industry Circular 31 of 2026. The guidance explains, step by step, what BVI companies must report and how. This article is continuation of our initial article announcing the changes found here.
It follows the BVI Business Companies (Financial Return) (Amendment) Order, 2026, which replaced the form with effect from 2 November 2026. This article summarises what the guidance means for BVI companies.
Quick answer: BVI companies must still file the annual return with their registered agent within 9 months after the year end. The change is in the detail. The revised form requires each asset category to be broken down by type and valued, including bank names and jurisdictions, loans and receivables at or above the 25% threshold, investments and virtual assets. Revenue and expenses must also be categorised. Any recognised accounting framework, may be used and the return states which one.
Who must file an annual return?
Every BVI company must file, unless it is:
- a listed company;
- regulated under financial services legislation and providing financial statements to the FSC;
- filing its annual tax return with the Inland Revenue Department together with its financial statements; or
- in liquidation.
The return goes to the company’s registered agent, not to the FSC. A company that fails to file within the prescribed period may face an administrative penalty. This requirement remains unchanged. Limited partnerships have their own revised form, which this article does not cover.
General rules for completing the return
The changes guidance sets out several rules that apply to every entity (some points are same as before):
- Accounting framework: none is prescribed. A company may use IFRS, IFRS for SMEs, US GAAP, UK GAAP, or another basis such as cash, modified cash or tax. It must state which one it used.
- Accuracy: whichever basis is used, the return must give an accurate and complete assessment of the financial position at year end.
- Valuation: assets and liabilities are shown at net carrying amount, for example after depreciation, amortisation and expected credit loss allowances.
- Currency: US$ or the currency of the company’s financial statements. If it is not US$, the column header must be changed. Amounts are rounded to whole units.
- Negative amounts: shown in brackets, except expenses in the income statement.
- Categories that do not apply: marked “N/A”.
- Parent companies: report their own standalone figures only.
The form sets out the minimum information required. A company may add other relevant financial information and may adapt the FSC’s template, provided the changes do not materially alter what must be reported. Using an accounting professional is optional.
The FSC guidance includes a worked example of a completed company return (Annex I). The form itself is on the FSC website under Library, Legislation, Corporate Structures.
What has changed?
The obligation to file is the same. What has changed is the form. The Order replaced the Schedule to the 2023 Order with a new one. The FSC says the new form requires additional information on assets, revenue and expenses. It lists these as new reporting obligations:
- Definitions: each asset category now comes with a definition, and so do revenue and expenses.
- Cash and cash equivalents: a value for each type held, plus the name and jurisdiction of every bank or institution holding them.
- Loans and receivables: where they are 25% or more of total assets, a value for each type (related party loans, third party loans, other), with the number of loans in each.
- Investments and other financial assets: a value for each type, such as shares, bonds, mutual funds, REITs, derivatives and virtual assets.
- Tangible, intangible and other assets: a value for each type of tangible and intangible asset, and a description and value for any other asset.
- Revenue and expenses: categorised according to the company’s activity, with a value for each category.
The guidance adds that the return must state the accounting framework or basis used.
Completing the balance sheet
The balance sheet must balance: total assets equal total liabilities plus shareholders’ equity. For assets, the changes guidance explains what to report in each category:
Asset category | What to report under the new rules |
|---|---|
Cash and cash equivalents | An amount for cash (cash on hand, current and savings account deposits, cashier’s cheques and money orders) and an amount for cash equivalents (highly liquid items convertible within about 3 months, such as treasury bills and money market funds). List each bank or institution with its jurisdiction. |
Loans and receivables | Details are required only if they are 25% or more of total assets. If so, give the amount and number of related party loans, third party loans and other. If not, state that and give one total. |
Investments and other financial assets | A total, plus a valuation for each type held: shares, bonds, mutual funds, REITs, derivatives, virtual assets, investments in other companies and other. If splitting is impractical, one amount with an explanation. |
Tangible fixed assets | A value for each type: property, machinery, vehicles, furniture and fixtures, equipment, other. |
Intangible assets | A value for intellectual property (as defined in the Economic Substance Act), goodwill and software. Only acquired goodwill is recorded, not internally generated goodwill. |
Other assets | A description and value for each type, such as inventory, prepayments and deposits, deferred tax assets, right-of-use assets and assets held for sale. |
The 25% test is total loans and receivables divided by total assets, multiplied by 100, using year-end net carrying amounts.
For liabilities, report three figures and their total. Accounts payable are balances due within 12 months, including short-term bank loans and overdrafts. Long-term debts are amounts due after more than 12 months, including bank loans, mortgages, related party loans and third party loans. Everything else is other liabilities. Shareholders’ equity is total assets less total liabilities.
Completing the income statement
The income statement follows a simple sequence. Revenue less cost of sales gives gross profit. Total expenses are then deducted to arrive at net income.
- Revenue: categorise it according to the type of company, with an amount for each category. A holding or investment company might report dividend income, interest income and gains. A trading company would report sales or service revenue.
- Cost of sales: the direct cost of producing or delivering what the company sells. If there is none, enter “N/A”.
- Expenses: operating expenses, sub-categorised by the company’s operations; income tax expense; and other expenses.
- Income tax expense: current tax, including foreign income taxes and withholding taxes, plus deferred tax.
- Net income: total profit or loss after all expenses, costs and taxes.
When does the revised form apply?
The Order came into force on 2 November 2026. The guidance states that the revised form should be used for any annual return required to be filed from 2027 onwards.
The FSC’s earlier Q&A described this as returns for 2026, filed with registered agents from September 2027. The two descriptions may not align for every year end. Companies with a financial year end during 2026 should confirm with their registered agent which form applies.
The guidance will be kept under review and amended as necessary. It does not replace the legislation, which takes precedence.
Frequently asked questions
Is this a new requirement?
No. The FSC stresses that the obligation to file an annual return under section 98A of the BVI Business Companies Act is unchanged. Only the form has been modified, to require more financial detail.
Why has the form changed?
The returns 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. The FSC says the revisions aim to make annual returns more useful for exchanging information for tax purposes.
What is different from the previous annual return form?
The FSC says the new form requires additional information on assets, revenue and expenses. Each asset category now has a definition and a value for each type, and revenue and expenses must be categorised. See “What has changed?” above for the full list.
Do we need to amend returns we have already filed?
No, the guidance does not say so. It states that the revised form applies to returns required to be filed from 2027 onwards. If you are unsure about an earlier return, ask your registered agent.
Is the return filed with the FSC?
No. It is still filed with the company’s registered agent as previously done. The agent keeps it for at least 5 years after ceasing to act and must give a copy to competent authorities on request. If a company fails to file, the agent must notify the Registrar of Corporate Affairs within 30 days after the due date.
Can we file our financial statements instead of the form?
No. The FSC has said that no decision has been made to accept standard financial statements signed by BVI accountants in place of the prescribed form.
Do we need an accountant to prepare the return?
There is no legal requirement to use an accounting professional, but its certainly good management practice. A company may seek professional help if it considers it appropriate.
Which accounting basis can we use?
Any recognised framework, such as IFRS, IFRS for SMEs, US GAAP or UK GAAP. A cash, modified cash or tax basis is also acceptable. The return must state the basis used.
What if our loans and receivables are below 25% of total assets?
State in the return that the threshold has not been met and report one total for loans and receivables.
What if a category does not apply to us?
Enter “N/A” against that category.
Does a parent company report consolidated figures?
No. A parent company reports only its own standalone amounts.
What happens if we file late?
A company that fails to file within the prescribed period may be liable to an administrative penalty.
How we can help
As accountants to BVI companies, we can prepare accounting records and annual returns for your company and prepare the information your registered agent needs to complete the submission. Ready to speak to our team? Contact us through our website at bviaccountants.com.
This article is intended for general informational purposes only and does not constitute tax, legal, or professional advice. Every company is different, and the application of these rules to your specific facts requires a proper professional assessment. Asterisk (BVI) Limited 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.
