We would like to draw your attention to a recent development concerning the British Virgin Islands (“BVI“) beneficial ownership regime.
From 1 April 2026, persons who can demonstrate a legitimate interest may apply to the BVI Registrar of Corporate Affairs for access to certain beneficial ownership information. Applications for exemption from disclosure are now available and may be submitted in advance of the commencement of the legitimate interest access regime. An application should be considered where disclosure could expose a beneficial owner, or their immediate family, to specific risks, or where other recognised grounds for non-disclosure may apply. Applications should be supported by clear reasons and appropriate evidence and should ideally be prepared in advance of any disclosure request.
The process once the Registrar receives a legitimate interest access request is as follows:
Accordingly, beneficial owners who may qualify for protection should consider applying for an exemption before legitimate interest access requests become operational.
Once a legitimate interest access request is received, the statutory response timelines are relatively short. If the Registrar determines that the requested information should be disclosed, rights to object and appeal may be available, but these are subject to strict statutory deadlines. Accordingly, beneficial owners who may have grounds for exemption may wish to consider making an exemption application proactively before legitimate interest access requests become operational on 1 April 2026.
A heartfelt thank you to FOAHK and its partners for curating such a thoughtful and well-executed event. We look forward to continuing our support of the family office community and contributing to its development in Hong Kong and beyond.
The table below illustrates the process once the Registrar receives a request for information and the applicable timelines for responding or objecting:
Action | Timeline |
Notice of Objection filed following notification of proposed disclosure | Within 5 days of notification |
Application opposing disclosure | Within a further 5 days |
Registry processing period (where no objection is filed) | 12 days |
An application for exemption from disclosure may be made where:
We are pleased to assist in:
If you would like to discuss whether an exemption application may be suitable for any beneficial owner connected to your BVI structure, please do not hesitate to contact us.