BVI overhauls the annual financial return: new FSC form in force from 2 November 2026

The BVI Financial Services Commission (BVI FSC) brought a new annual financial return form for BVI companies and limited partnerships into force on 2 November 2026. The BVI Business Companies (Financial Return) (Amendment) Order, 2026 (S.I. 2026 No. 71) replaces the form schedule of the 2023 Order and asks for more detail on assets, revenue and expenses. The new form applies to returns filed from 2027 onwards. For a holding company or family office with a 31 December 2026 year end, this is the first return under the new rules: it goes to the registered agent within 9 months, by 30 September 2027. On 6 November the FSC published completion guidance with worked templates (Industry Circular 31 of 2026).

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What the FSC changed on 2 November 2026

The annual financial return obligation sits in section 98A of the BVI Business Companies Act, Revised Edition 2020, and in section 54A of the Limited Partnership Act for limited partnerships. The return is filed with the company's registered agent. The FSC sets the form by order.

In the FSC's words, the changes cover the form of filing and the information required: companies report additional information on assets, revenue and expenses, and limited partnerships on assets, income and expenses.

What the revised return asks for

The revised form has a balance sheet (assets, liabilities, equity) and an income statement. Total assets must equal liabilities plus shareholders' equity. Assets fall into six categories, each with a list and a valuation.

1. Cash and cash equivalents. Cash and cash equivalents (for example treasury bills or money market funds) are shown separately. For each bank or institution, give its name and jurisdiction.
2. Loans and receivables. Where they make up 25% or more of total assets, split them into related party loans, third party loans and other, with the number of loans in each group. Below the threshold, report the total only.
3. Investments and other financial assets. Shares, bonds, mutual funds, REITs, derivatives, virtual assets, investments in other companies and other, each valued.
4. Tangible fixed assets. Property, machinery, vehicles, furniture and fixtures, equipment, other.
5. Intangible assets. Intellectual property, goodwill (acquired only), software.
6. Other assets. Inventory, prepayments, deposits, deferred tax assets and anything else, with a description.

In the income statement, revenue is categorised by type: for a holding company that means dividend income, interest income and gains. A holding company usually has no cost of sales and enters N/A. Expenses split into operating expenses (by type), other expenses and income tax expense, which includes foreign income taxes and withholding taxes.

Completion rules from the FSC guidance

• Deadline: 9 months after the financial year end. Late filing can lead to an administrative penalty.
• Accounting basis is the company's choice: IFRS, IFRS for SMEs, US GAAP, UK GAAP or a cash basis. The return states which one is used.
• Currency: US dollars or the currency of the company's financial statements, in whole units.
• A parent company reports on a standalone basis, without consolidating subsidiaries.
• The law does not require an accountant to prepare the return; the company may engage one if it wishes.
• Exempt: listed companies; regulated entities that file financial statements with the FSC; entities that file a tax return with financial statements to the BVI Inland Revenue Department; entities in liquidation.

What it means for a holding company or family office

For a BVI family office structure, the 2026 return will show the agent every bank with its jurisdiction, the portfolio split by asset type, and intra-family or intra-group loans where they exceed a quarter of the balance sheet. Collect this data before the year closes, while statements and 31 December valuations are easy to obtain.

Before 31 December 2026:

1. Confirm the company's financial year end and filing deadline with the registered agent.
2. Choose an accounting basis and keep it for future returns.
3. List all banks, brokers and custodians with their jurisdictions.
4. Map the portfolio to the six asset categories and value it at year end.
5. Document related party loans: agreements, balances, interest.
6. Prepare a breakdown of holding income: dividends, interest, gains, withholding taxes.

Agree the timeline and valuation approach with the agent early. Preparing data for a complex portfolio usually takes several weeks.

FAQ

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Sources: BVI FSC, Industry Circular 29 of 2026 (02.11.2026); BVI Business Companies (Financial Return) (Amendment) Order, 2026, S.I. 2026 No. 71; Limited Partnership (Financial Return) (Amendment) Order, 2026, S.I. 2026 No. 72; BVI FSC, Industry Circular 31 of 2026 (06.11.2026); Guidance on Completing Annual Financial Returns (06.11.2026).

Information only, primary sources as of 07.11.2026. Filing practice and asset valuation are confirmed with the company's registered agent.