Under the BVI Business Companies Act (Revised Edition 2020), existing companies that were incorporated or continued before 2 January 2025 and are not struck off can still make the required filings under sections 41 (register of members), 43A (registration of register of members) and 96A (company to collect, keep and maintain beneficial ownership information) with a US$0 filing fee through 31 March 2026. In plain terms, these sections deal with bringing a company's core statutory records and key particulars up to date on the public register (for example, information held in statutory registers and other prescribed company details), and the moratorium lets older companies make those catch‑up filings without paying the usual fee.

Similarly, under the Limited Partnership Act (Revised Edition 2020), existing limited partnerships that were registered or continued before 2 January 2025 and are not struck off can make the required filings under sections 53A (registration of registers of general partners and limited partners) and 53B (limited partnership to collect, keep and maintain beneficial ownership information) with a US$0 filing fee through 31 March 2026. Put simply, these sections cover filing updates to prescribed limited partnership particulars and registered records, enabling existing LPs to bring their filings into line at no charge while the moratorium is in place.

For entities that are non-compliant with the framework they should work to ensure full compliance as quickly as possible so as not to impact any corporate good standing issues.

These updates were published by the BVI FSC on 31 December 2025 through Industry Circular 46 of 2025. For more information, readers can consult the official Notice and Industry Circular 46, which provide additional context on the filing framework.

For further details, the official Notice can be accessed here and Circular 46 can be found here