Industry Circular 21 of 2025 - Guidance On Using The Batch/Bulk Filing Template For BO Information

Guidance on Using the Batch/Bulk Filing Template for BO Information

As previously communicated by the BVI Financial Services Commission (the Commission) in Industry Circular No 20 of 2025, the batch/bulk filing template is now available to facilitate the submission of Beneficial Ownership (BO) information in large batches.

Agents and practitioners are reminded of the following important requirements to ensure accurate and timely filings:

Template Format

• Do not modify the template’s format or structure to match your internal templates.
• Column headings must remain exactly as provided; any changes will result in filing errors.
• The order of columns must not be altered, as it must align precisely with the VIRRGIN system.

Data Entry Requirements

• The following fields must be formatted as dates:
  • Date of Birth
  • Effective Date
  • Cessation Date
  • Joint Date of Birth (for joint owners)
• All dates must be entered in the DD/MM/YYYY format.
• All non-date fields must be formatted as text.

Avoid Common Errors

• Ensure there are no extra spaces, tabs, carriage returns, special characters, or incorrect field types.
• Do not leave mandatory fields blank.
• Verify that all date entries strictly follow the DD/MM/YYYY format.

Please note: VIRRGIN will automatically reject any batch files that do not meet these formatting standards.

While there has been strong early interest in using the batch filing process, we urge all agents and practitioners to take the necessary care to complete the template accurately. Doing so will help ensure that filings are processed efficiently and approvals are granted without unnecessary delays caused by avoidable errors.

The Commission sincerely appreciates the continued cooperation and commitment of agents and practitioners as it works toward full compliance with the BO Regime. Proper use of the batch filing template is essential to achieving this goal.

For assistance or further guidance on filing BO information, please direct your queries to [email protected] or [email protected].

Queries related to this Industry Circular should be directed to [email protected].