The Bermuda Ministry of Finance has circulated the latest draft Beneficial Ownership Regulations 2026 and revised draft Guidance Notes to support implementation of the Beneficial Ownership Act 2025. The documents are intended as an interim measure ahead of legislative amendments expected this summer and are meant to help Bermuda-registered entities prepare for compliance and filing requirements under the new beneficial ownership regime. The Beneficial Ownership Act 2025 requires registered entities to identify and maintain accurate, up-to-date information on their beneficial owners, submit information to the Registrar of Companies within prescribed timeframes, and comply with enforcement provisions for non-compliance. The draft regulations add operational detail on filing procedures, verification requirements, update timelines, maintenance of the central register, exemptions, reporting for complex structures and access to information in defined circumstances. The revised guidance notes clarify key definitions, reporting expectations, the scope of the regime, due diligence expectations, and the roles of corporate service providers and compliance professionals. Further revisions are expected in the coming weeks, including amendments to the act and regulations, proposed exemption orders for trusts and funds, and updates on legitimate interest access. Enforcement action has been deferred until 31 August 2026 to give entities more time to align internal processes before the framework is finalised and fully in force.

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