Bermuda's Beneficial Ownership Act 2025: Enhancing Clarity, Compliance And Confidence

• Published date: 21 October 2025
• Law Firm: Walkers
• Author: Leonie Tear

Key takeaways

• It is anticipated that the BOA, along with related regulations and guidance, will come into force on 3 November 2025.

• The BOA makes a number of changes to Bermuda's beneficial ownership regime, including expanding its scope, amending the definition of 'beneficial owner', requiring additional information to be entered on the beneficial ownership register, new verification obligations and allowing access to beneficial ownership information held on the Central Register to certain regulatory authorities and obliged entities.

• The BOA also provides that the ROC (rather than the BMA) will be the competent authority for the purposes of this regime.

Introduction

Bermuda has had a beneficial ownership regime (the BOR) in operation since March 2018 which requires each in-scope entity to: (a) take reasonable steps to identify, and monitor changes to, its beneficial owners; (b) establish and maintain a beneficial ownership register at its registered office; and (c) file with the Bermuda Monetary Authority (the BMA) required beneficial ownership information and notify the BMA of any changes to such information (the Current BOR).

The Beneficial Ownership Act 2025 (the BOA) received Governor's Assent on 28 September 2025. It is anticipated that the BOA, along with related regulations, will be brought into force by notice in the Official Gazette on 3 November 2025. It is also expected that during October 2025, the Bermuda Registrar of Companies (the ROC) will issue guidance notes to assist entities understand their obligations under the new beneficial ownership regime.

The Current BOR is set out across numerous pieces of legislation, including the Companies Act 1981 (as amended), the Limited Liability Company Act 2016 (as amended), the Limited Partnership Act 1883 (as amended), the Exempted Partnership Act 1992 (as amended), the Partnership Act 1902 (as amended) and the Exchange Control Act 1972 (as amended) and related regulations. The BOA consolidates the provisions of the Current BOR into one single Act. Importantly, it does not change requirements that apply to entities that are regulated by the BMA.

The BOA also makes a number of changes to the Current BOR which are intended to ensure that Bermuda satisfies its obligations under the revised Financial Action Task Force (FATF) international standards on beneficial ownership and transparency. It also addresses key recommended actions identified by the Caribbean FATF in Bermuda's last mutual...