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Industry Circular 39 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, designed to facilitate the submission of Beneficial Ownership (BO) information in batches, and the previously issued Industry Circulars No. 21 of 2025 and No. 33 of 2025 guiding the process, the BVI Financial Services Commission (the Commission) has observed that the Industry continues to face a range of challenges in effectively utilising the template. These challenges have significantly impacted the progress of BO filings.
In response, and following consultation with the external developers, the Commission has taken steps to:
- Update the batch filing template to address key usability and formatting issues reported.
- Enhance the accompanying guidance, particularly as it relates to correcting rejected batch filings, to facilitate timely resubmissions and approvals.
BATCH REJECTION
The Commission is aware that a significant number of batch filings are being rejected due to user error and system errors. In several cases, the error messages received do not provide sufficient detail to guide Agents in making the required corrections.
To address this, the Commission has:
- Streamlined the wording of rejection error messages to assist users in identifying necessary corrective actions; and
- Developed step-by-step Register of Members (ROMs) Import Procedures and BO Import Procedures, outlining required column formats, character limits, and other critical validation rules to support correct population of the template.
Agents should also continue to refer to the Guidance issued in Industry Circular No. 33 of 2025 and use the information in tandem with the additional Guidance regarding filing BO information provided.
The updated Guidance aims to minimise the number of rejected filings and promote accurate and timely submissions.
IMPORTANT REMINDERS FOR AGENTS AND PRACTITIONERS:
Given the sensitive nature of the information being submitted, Agents are strongly advised to:
- Exercise great care when populating the batch template.
- Strictly adhere to the updated guidance provided.
- Review and validate all data prior to submission to avoid common errors.
- Act promptly on any rejection notices by referring to the specific guidance for corrections.
- Contact support at or for assistance where necessary.
EXTENSION OF FILING LINK EXPIRY PERIOD FOR RODS, ROMS, AND BOS
The Commission has extended the expiry period for all filing links related to Registers of Directors (RODs), ROMs, and Beneficial Owners (BOs), including both single and bulk filings, to 31 March 2026.
This extension aligns with the extension of the filing period ending 1 January 2026 and provides an additional three months of continued access to filing links, especially for submissions made close to the filing deadline.
The extensions aim to:
- Reduce administrative burden on agents
- Minimise compliance risks
- Support timely and complete filings
Important Reminder: After 31 March 2026, filing link access will automatically revert to a standard 10-day download period. Agents are strongly encouraged to promptly download and store all relevant documents to ensure the proper maintenance of statutory registers.
The Commission remains committed to supporting agents and practitioners in achieving full compliance with the BO Regime and reiterates that the proper use of the batch filing template is essential to achieving this shared objective.
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]
