Bermuda's New Beneficial Ownership Act 2025 - What You Need To Know

• Published date: 22 October 2025
• Law Firm: Carey Olsen
• Author: Mr Alexander Collis, Michelle Falcucci, Matthew Grigg, Steven Rees Davies, Gavin Woods, Michael Frith, Charissa Ball, Khayl'La Ball and Susie Tindall

Briefing Summary:

The Beneficial Ownership Act 2025 (the "BO Act") received Royal Assent on 28 September 2025 and is anticipated to come into force on or around 3 November 2025. The BO Act replaces the previous beneficial ownership regime in Bermuda and significantly expands beneficial ownership transparency requirements to align with international standards. The new regime mandates more comprehensive transparency measures concerning beneficial ownership to combat money laundering, tax evasion and terrorist financing.

Key changes

• Extended scope: the BO Act brings new entities into scope and applies to all Bermuda Legal Persons, including companies, limited liability companies, permit companies, exempted partnerships, limited partnerships, exempted limited partnerships and overseas partnerships (each, a "Legal Person").
• Removal of exemptions: many of the exemptions that previously applied (e.g. certain regulated financial institutions and permit companies) have been removed, meaning more entities will need to maintain beneficial ownership registers Under the BO Act, the only exemption from the requirement to establish and maintain a beneficial ownership register is for Legal Persons listed, and subsidiaries of Legal Persons listed, on the Bermuda Stock Exchange or an appointed stock exchange¹. Accordingly, all Legal Persons, except Listed Legal Persons and subsidiaries of listed legal persons ("In-Scope Entities") are required to establish and maintain a beneficial ownership register.
• Transfer of the central register: upon the BO Act coming into force, responsibility for Bermuda's beneficial ownership central register will transfer from the Bermuda Monetary Authority ("BMA") to the Registrar of Companies ("ROC"). The ROC will also become responsible for approving persons seeking to become a Beneficial Owner of entities in scope of the BO Act.
• New verification requirements: the BO Act introduces new verification requirements which require In-Scope Entities to take reasonable measures to verify the minimum required information of their Beneficial Owners and keep records of the documentation and measures used.

Key obligations for In-Scope Entities

The beneficial ownership information requirements (and related definitions) under the BO Act largely replicate the previous beneficial ownership regime, with the addition of new verification obligations, and certain additional information requirements.

Under the new regime, all In-Scope Entities must:

• Identify...