Industry Circular 33 of 2025 - Updated Guidance on Using the Batch/Bulk Filing Template for BO Information

UPDATED GUIDANCE ON USING THE BATCH/BULK FILING TEMPLATE FOR BO INFORMATION
 

Further to the release of the batch/bulk filing template on 22 May 2025 to facilitate the submission of Beneficial Ownership (BO) information in batches and the previously issued Guidance on the effective use of the template, Industry Circular No 21 of 2025. The BVI Financial Services Commission (the Commission) has been made aware of, and is concerned that the Industry has been experiencing a number of ongoing challenges in utilising the template, which has impacted progress with the filings.

Having reviewed many of the issues brought to our attention, the Commission has found it necessary to issue updated Guidance to assist Agents with their filings with the aim of minimising the number of rejected filings and ensuring accurate and timely filings.

Agents and practitioners are reminded to exercise care when populating the template due to the sensitive nature of the document and to strictly adhere to the following:

Template Format

• Use an updated or recent version of Excel. Only Excel files with valid extensions such as .xls, or .xlsx, or .xlsm
• DO NOT modify the template’s format or structure to match 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 are mandatory:
  • Given Name
  • Date of Birth
  • Place of Birth
  • Nationality
  • Gender
  • Occupation
  • Address 1
  • Country
  • Interest by Control
  • Interest by Ownership
  • Voting Rights
  • Joint Owner
  • Effective Date
• 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.
• Text columns are case sensitive (upper and lower case should be used appropriately).

Avoid Common Errors

• Ensure that an entity's status is Active (including Active in liquidation).
• Only file BO information for those companies to which you act as Agent and not companies that have been transferred.
• DO NOT include entities that are not Active.
• Ensure there are no extra spaces, tabs, carriage returns, special characters, or incorrect field types.
• DO NOT cut and paste information into the template.
• DO NOT leave mandatory fields blank.
• Verify that all date entries strictly follow the DD/MM/YYYY format.

Failing to follow the Data Entry Requirements? will result in VIRRGIN automatically rejecting any batch files that do not meet these formatting standards.

While there has been strong early interest in using the batch filing process, this interest has not materialised in the number of filings submitted since the transaction was deployed. We encourage Agents and practitioners to utilise the template as soon as possible and as often as possible, since doing so will help to identify and triage any issues and ensure that filings are processed efficiently and approvals are granted without unnecessary errors and avoidable delays.

The Commission is committed to supporting agents and practitioners in their efforts toward full compliance with the BO Regime, and reiterates that proper use of the batch filing template is essential to achieving this common goal.

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

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