Beginning 1 April 2026, the BVI Registrar (“Registrar”) will accept applications from persons seeking access to beneficial ownership information held on the Register of Beneficial Ownership. Access will only be granted where the applicant can demonstrate a legitimate interest in obtaining the information.
S13D scheme is a self-assessment regime. Funds vehicles are not required to submit an application to the MAS for approval, nor file annual declarations with the MAS to avail of the S13D scheme. Instead, the fund itself is responsible for ensuring that it meets the qualifying conditions for tax exemption under the S13D scheme.
What This Means
• Applicants must show a legitimate interest, meaning their request is directly connected to investigating, preventing, or detecting money laundering, terrorist financing, or proliferation financing.
• Access is not automatic. Each request will be assessed by the Registrar against legislative requirements.
• If approved, the applicant will receive limited information: the beneficial owner’s name, month and year of birth, nationality, and the nature of their interest (where the individual owns or controls 25% or more of the BVI entity).
• When a valid request is received, the Registrar will notify the legal entity (via its registered agent) and provide an opportunity to object to disclosure.
Tight Objection Deadlines
• Entities have 5 days from notification to file a Notice of Objection.
• A further 5 days are allowed to submit a full application, with evidence and reasons, opposing disclosure.
• If no objection is filed, no further action is required.
• An objection does not guarantee that disclosure will be prevented. The Registrar will review the objection and may refuse or grant it. If refused, entities retain the right to appeal.
