BVI annual financial return: the new form from 2027 and what the FSC guidance requires
The BVI FSC published guidance on 6 November 2026 for the amended annual financial return. Returns due from 2027 use the new form, still within nine months of year end. No accountant is required by law, but banks, loans and investments must now be broken down.
On 6 November 2026 the BVI Financial Services Commission (FSC) issued Industry Circular 31 of 2026 together with an 18-page Guidance on Completing Annual Financial Returns. The amendment order that took effect four days earlier had already replaced the form; what it did not say was how each line should be completed. The guidance fills that gap. It is issued under section 98A of the BVI Business Companies Act and section 54A of the Limited Partnership Act, and covers both BVI business companies and limited partnerships.
In short: every annual financial return that must be filed from 2027 onwards uses the new form. The deadline is unchanged at nine months after the end of the relevant financial year, and the return still goes to the company's registered agent. The law does not require an accountant, but bank accounts, loans and receivables, and investments must now be reported in more detail. The preparation work will grow, so it pays to map your accounts to the new form early.
What has changed and what has not
| Item | Current position |
|---|---|
| Which form (changed) | Returns that must be filed from 2027 use the amended form |
| Deadline (unchanged) | Within nine months after the end of the financial year |
| Filed with (unchanged) | The registered agent; returns are not filed with the FSC |
| Accountant required? (clarified) | Not required by law; entities may prepare the return themselves or seek professional help |
| Accounting basis (clarified) | No framework is prescribed, but the basis used must be stated |
| Level of detail (changed) | Lists of banks and institutions, loan and receivable categories, investment types, and line items for assets, liabilities, income and expenses |
| Government fees, new incorporations (not addressed) | Neither the circular nor the guidance mentions a new government fee or any change to incorporation |
Why the form was amended
The annual financial return is not a new obligation. According to the Q&A the FSC published after its October 2026 webinar, BVI business companies have been required to file annual financial returns with their registered agents since January 2023, with the first returns filed from July 2025. Limited partnerships came under the same requirement from December 2024, with first returns filed from September 2026.
What changed is the content of the form. The FSC explains that the return was designed to meet the Global Forum on Transparency and Exchange of Information for Tax Purposes standard on exchange of information on request, a matter for the International Tax Authority. The last Global Forum review rated the BVI non-compliant on the availability of accounting information, and the new form is meant to make returns more useful for tax information exchange. The FSC also notes that the return is not filed with the FSC and does not serve its own supervisory purposes.
For a company, this means the figures may be requested and checked. Registered agents must keep returns for at least five years after they cease to act for the entity and provide copies to competent authorities on request. Every figure should be supported by records you can produce.
Who must file and who is exempt
Under paragraph 1.1 of the guidance, four types of entity do not need to file an annual financial return:
- listed companies;
- entities regulated under financial services legislation that already submit financial statements to the FSC under that legislation;
- entities that file an annual tax return with financial statements with the BVI Inland Revenue Department; and
- entities in liquidation.
An entity in liquidation need not file, but returns that fell due before the liquidation began must still be filed. The FSC's October Q&A also says the liquidation exemption for limited partnerships is expected to be introduced by amending the Limited Partnership Act. Having no business or only holding shares, on the other hand, is not an exemption. Such companies still file, entering N/A where a line does not apply; a pure holding company with no cost of sales, for example, enters N/A on that line.
Completing the new form: eight points
1. Accounting basis, currency and figures
No accounting framework is prescribed. An entity may use IFRS, IFRS for SMEs, US GAAP or UK GAAP, or a cash, modified cash or tax basis, but it must state the framework or basis used. Whichever it chooses, the return must accurately and completely reflect the financial position at year end.
Figures may be in US dollars or in the currency in which the entity prepares its financial statements, with the column headings amended to show the currency. Amounts are rounded to whole units. Assets and liabilities are shown at net carrying amounts, after accumulated depreciation, amortisation and impairment or expected credit losses. Negative figures go in brackets, for example (1,000), except for expenses.
2. Cash and the list of banks
Cash (such as current and savings deposits) and cash equivalents (such as treasury bills and money market funds that can be realised in the short term) are reported separately. Where cash or cash equivalents are held with a bank or other institution, the name of each institution and its jurisdiction must be listed. Companies with several accounts should first confirm which ones still held funds at year end.
3. Loans and receivables: the 25% test
Using year-end net carrying amounts, divide total loans and receivables by total assets. If the result is 25% or more, report related-party loans, third-party loans and other loans and receivables separately, with the number of items in each category. Below 25%, state that the threshold is not met and report the total only.
An illustration (figures for explanation only): a BVI holding company has total assets of USD 1 million at year end, including a USD 300,000 loan to an affiliate. At 30%, the loans must be broken down by category with the number of items. If the loan were USD 100,000, or 10%, stating that the threshold is not met and giving the total would be enough.
4. Investments and virtual assets
Investments and other financial assets are reported as a total, followed by the types held and the value of each: shares, bonds, mutual funds, real estate investment trusts, derivatives, virtual assets, investments in other companies and other. Where a breakdown is genuinely impracticable, a single amount may be given with the reason stated.
5. Fixed, intangible and other assets
Tangible fixed assets are split into property, machinery, vehicles, furniture and fixtures, equipment and other. Intangible assets are split into intellectual property, goodwill, software and other; only goodwill arising on an acquisition is recorded, not internally generated goodwill. Inventory, prepayments and deposits, deferred tax assets, right-of-use assets, assets held for sale and similar items go under other assets, each described and valued.
6. Liabilities and equity
Liabilities fall into three groups: payables due within 12 months (including short-term bank loans and overdrafts), long-term debts due after more than 12 months (including bank loans, mortgages and related-party and third-party borrowings) and other liabilities, with a total. Shareholders' equity equals total assets less total liabilities, and the balance sheet must balance.
7. Income and expenses
Income is categorised according to what the company actually does: dividends, interest and investment gains for a holding or investment company; sales or service revenue for a trading company. Where there is no cost of sales, enter N/A. Expenses are grouped into operating expenses, broken down further by business, income tax expense and other expenses. Income tax expense includes current tax, foreign taxes, withholding taxes and movements in deferred tax.
8. Stand-alone figures and template adjustments
A parent company reports its own stand-alone figures, not consolidated group figures. The annexes to the guidance contain sample templates for companies and limited partnerships. Wording and layout may be adapted to the business and further relevant information may be added, but the information required by law must not be materially changed or omitted.
How limited partnerships differ
BVI limited partnerships apply the same 25% test to receivables. At or above the threshold they report trade receivables, related-party receivables, interest receivable and other receivables separately, with the number of items. Liabilities are shown as trade and other payables, borrowings and other liabilities. Partners' capital is reported separately for general and limited partners, and the income statement also shows unrealised and realised gains or losses, interest income and expense, and net income before and after interest.
Timeline: which return uses the new form
| Date | Event |
|---|---|
| 8 October 2026 | FSC webinar on the changes, followed by a published Q&A and slides |
| 30 October 2026 | BVI Business Companies (Financial Return) (Amendment) Order, 2026 (S.I. 2026 No. 71) gazetted |
| 2 November 2026 | Amendment orders in force; FSC issues Industry Circular 29 |
| 6 November 2026 | FSC issues Industry Circular 31 and the completion guidance |
| 30 September 2027 | Deadline for an entity with a year ending 31 December 2026 to file the new-form return with its registered agent |
Companies whose financial year does not end on 31 December should take care. The guidance applies the new form to returns that must be filed from 2027 onwards, so a year ending between April and November 2026, with a deadline between January and August 2027, would also use the new form on that wording. The FSC's October Q&A, however, described the change as applying to 2026 returns filed from September 2027. Where the two differ, follow the amendment order and the guidance, and confirm early with your registered agent which version it will accept and its internal cut-off date.
What happens if a return is late
The guidance states that failing to file on time may lead to an administrative penalty. Under the administrative penalty tiers in the BVI Business Companies Regulations as amended in 2024, failing to file the annual financial return with the registered agent on time is a Tier 3 matter with a ceiling of USD 50,000. This is a maximum, not a fixed amount; the actual penalty depends on the circumstances. The registered agent must also notify the Registrar within 30 days after the due date if a return has not been filed, which can affect the issue of a certificate of good standing.
What you can prepare now
| Records | Section of the new form | Preparation note |
|---|---|---|
| Year-end statements for every bank and institution account | Cash and cash equivalents | Check institution names and jurisdictions; confirm which accounts held funds at year end |
| Loan agreements and intercompany ledgers | Loans and receivables | Run the 25% test first, then split related-party and third-party items and count them |
| Investment and custody statements, virtual asset holdings and valuation evidence | Investments and other financial assets | Value by type: shares, bonds, funds, virtual assets and so on |
| Registers of fixed assets, intellectual property and software | Fixed and intangible assets | Use net carrying amounts; record only acquired goodwill |
| Payables and borrowing records | Liabilities | Separate amounts due within and after 12 months |
| Income and expense ledgers and tax receipts | Income statement | Include foreign and withholding taxes in income tax expense |
| The chosen accounting basis | Statement of accounting basis | Keeping it consistent from year to year makes figures comparable |
Companies that are changing, or plan to change, registered agent should also check whether returns for earlier years were filed and whether the underlying records are available. Sorting this out in advance reduces back-and-forth during the handover.
Frequently asked questions
Does the new form mean an audit is required?
No. The guidance states that the law does not require an accounting professional to prepare or review the return; entities may prepare it themselves or seek professional help. The categorised figures must still be complete, accurate and supported by records.
Can we submit financial statements instead of the form?
According to the FSC's October Q&A, no decision has been taken to accept standard financial statements in place of the return, so the form should be completed as required. Entities that file an annual tax return with financial statements with the BVI Inland Revenue Department are exempt.
Does a BVI parent company report consolidated figures?
No. A parent reports its own stand-alone figures only.
Our company has no business. What do we file?
Unless one of the four exemptions applies, the return is still due on time. Enter N/A where a line does not apply, and report any bank balances, loans or investments as they are.
Who keeps the return?
The company's registered agent. The return is not filed with the FSC. The agent must keep it for at least five years after ceasing to act and provide copies to competent authorities on request.
How Offshore Isle can help
Under our BVI annual renewal service we prepare a records checklist mapped to the new form and confirm the registered agent's template, file format and internal cut-off before agreeing a delivery date with you. Fees are confirmed according to how complex the financial records are: a dormant company with one account involves far less work than one holding several accounts, investments, loans or virtual assets.
If you already have a BVI company and are considering a new agent, see offshore company agent transfer. If you have not incorporated yet, BVI company formation sets out the requirements and annual maintenance. For economic substance reporting, see Economic substance: the compliance baseline for offshore companies. To check the new form against your company's position, contact an adviser or call 400-860-5600.
Official sources
- BVI FSC, Industry Circular 31 of 2026: Guidance On Completing Annual Financial Returns, 6 November 2026
- BVI FSC, Guidance on Completing Annual Financial Returns (PDF, 18 pages), 6 November 2026
- BVI FSC, Industry Circular 29 of 2026: Amendments To The BVI Business Companies (Financial Return) Order & Limited Partnership (Financial Return) Order Published, 2 November 2026
- BVI FSC, BVI Business Companies (Financial Return) (Amendment) Order, 2026 (S.I. 2026 No. 71, PDF), 30 October 2026
- BVI FSC, Limited Partnership (Financial Return) (Amendment) Order, 2026 (PDF), 2026
- BVI FSC, Webinar Q&A on the amended annual financial return (PDF), October 2026
- Government of the Virgin Islands, BVI Business Companies (Amendment) Regulations, 2024 (S.I. 2024 No. 58, PDF), 2024
This article is based on BVI FSC documents public at the time of writing, the latest being the completion guidance of 6 November 2026. It is general information only and is not legal, tax or accounting advice; the filing requirements are those set by the law, the FSC's latest documents and your registered agent.
This page summarises publicly available regulations for general reference only and does not constitute legal or tax advice. Rules in each jurisdiction may change at any time; please confirm the latest position with an Offshore Isle advisor.
