Navigating Bermuda’s Evolving Regulatory Landscape

Home > Legal and Fiduciary Services > Legal Services > Regulatory & Compliance > Bermuda Regulatory & Risk Advisory > Navigating Bermuda’s Evolving Regulatory Landscape

Key filing deadlines and compliance insights for Bermuda domiciled entities.¹

Bermuda’s top-tier regulatory framework continues to evolve, with Bermuda domiciled entities required to comply with various statutory and reporting obligations. Ongoing developments in areas such as economic substance, AML/ATF, PIPA, Common Reporting Standard (“CRS”) and Country-by-Country Reporting (“CbCR”) and beneficial ownership result in regulatory focus on accuracy, transparency and timely disclosures.

As regulatory obligations expand, non compliance carries increased regulatory and reputational risk and directors, managers and service providers should be well equipped to manage such risk. Strong, effective governance is therefore underpinned by maintaining robust internal processes that support timely filings and accurate reporting to the relevant authorities, including the Bermuda Registrar of Companies (the “Registrar”), the Bermuda Monetary Authority (BMA) and the Ministry of Finance.

To help you stay on track, please see below an overview of the annual key regulatory filing dates, including annual returns, economic substance filings, fund related requirements, AML/ATF updates, CRS and CbCR reporting, and other general regulatory ongoing obligations. The overview is designed to be a helpful reference tool but is not exhaustive. Clients and prospective clients should seek legal advice with respect to their specific regulatory filings as needed.

If you have any questions regarding these filings or ongoing regulatory and compliance requirements, our Regulatory & Risk Advisory team is available to provide tailored guidance and practical support to help you navigate your compliance obligations with confidence.

Authors

Jennifer Panchaud

Director, Head of Regulatory & Risk Advisory (Bermuda)

Katie Martin

Senior Associate

Bermuda Regulatory Filing Dates

Key Annual Dates / Filing Deadlines

Ongoing Annual Requirements

AML/ATF Training is required for all relevant persons in scope of the Bermuda AML/ATF regime to recognize and address potential money laundering or terrorist financing activity.

At least annually, in scope AML/ATF entities should also ensure their independent audit function conducts and documents an independent and objective evaluation of their AML/ATF framework.

In addition, Bermuda entities have ongoing statutory obligations to maintain accurate beneficial ownership information and to make all required statutory filings, including filings relating to changes in directors or officers, constitutional documents, and share capital.

Key Annual Dates/Filing Deadlines

21 January

IBA licenced investment providers with standard licences and certain Class A Registered Persons² must file quarterly returns within 21 days of the end of each quarter.

31 January

Exempted companies’ annual declaration and³ fees due to the Registrar, including the appropriate annual government fee and annual corporate regulatory fee.

31 March

Local companies' annual declaration, annual tax, return of shareholdings as at 31 December, and corporate regulatory fee due to the Registrar.

31 March

Permit companies' annual fees and corporate regulatory fee due to the Registrar.

31 March

All Bermuda regulated entities annual BMA fees due, including investment funds, investment providers, insurers, fund administration providers, digital asset businesses, corporate service providers, recognised bodies, and non-licensed AML/ATF regulated financial institutions.

31 March

Foreign Financial Institutions (FFIs) annual FATCA return filings for the previous calendar year are due to the Internal Revenue Service. An automatic 90-day extension may be requested by Reporting Financial Institutions no later than 31 March.

21 April

IBA licenced investment providers with standard licences and certain Class A Registered Persons⁴ must file quarterly returns within 21 days of the end of each quarter.

30 April

New Bermuda Reporting Financial Institutions (RFIs) that qualify as FFIs must register and submit their CRS notification via the Bermuda Tax Information Reporting Portal by 30 April following the calendar year they became an RFI.

30 April

Insurers' Statutory Financial Return, Capital and Solvency Return and Audited Financial Statements for Class 3A, 3B, 4, C, D and E insurers are due to the BMA for insurers with a 31 December financial year end (“FYE”).⁵

31 May

FFIs annual CRS return filings for the previous calendar year are due to the Bermuda Corporate Income Tax Agency via the Tax Information Reporting Portal. Nil return filings are mandatory for all Bermuda Financial Institutions that maintained no Reportable Accounts during the year.

31 May

Insurance groups and Class 3A, 3B, 4, C, D and E insurers' Quarterly Financial Returns are due to the BMA.

31 May

Insurance groups’ Group Statutory Financial Return, Group Capital and Solvency Return and Audited Group Financial Statements are due to the BMA with a 31 December FYE.⁶

30 June

Insurers' Electronic Statutory Financial Returns are due to the BMA for Class 1, 2, 3, A and B insurers with a 31 December FYE.⁷

30 June

Special purpose insurers' Statutory Financial Return are due to the BMA for those with a 31 December FYE.⁸

30 June

Registered and authorised investment funds must file audited financial statements and annual certifications of compliance to the BMA for funds with a 31 December FYE.⁹

30 June

Overseas Funds must file annual declaration to the BMA for funds with a 31 December FYE.¹⁰

30 June

DABA licenced digital asset businesses annual returns (including audited financial statements and certificate of compliance) are due to the BMA for entities with a 31 December FYE.¹¹

30 June

All Bermuda regulated entities economic substance declaration forms are due to the Registrar for in scope entities¹² with a 31 December FYE¹³. Evidence of tax residency to be filed for non-resident entities.

21 July

IBA licenced investment providers with standard licences and certain Class A Registered Persons must file quarterly returns within 21 days of the end of each quarter.

31 July

IBA licenced investment providers' audited financial statements and certificates of compliance due to the BMA for those with a 31 March FYE.¹⁴

31 July

Fund administration providers' audited financial statements and certificates of compliance are due to the BMA for those with a 31 March FYE.¹⁵

31 August

Insurance groups and Class 3A, 3B, 4, C, D and E insurers' Quarterly Financial Returns are due to the BMA.

30 September

FFIs annual CRS Compliance Certification Form for the previous calendar year is due to the Bermuda Corporate Income Tax Agency via the Tax Information Reporting Portal.

30 November

Insurance groups and Class 3A, 3B, 4, C, D and E insurers' Quarterly Financial Returns are due to the BMA.

31 December

Constituent Entities of MNE Groups must meet the CbCR filing deadline for those with a Reporting Fiscal Year ending 31 December.¹⁶

31 December

Constituent Entities of MNE Groups must meet the CbCR notification deadline for tax purposes in Bermuda confirming where they are the Ultimate Parent Entity or the Surrogate Parent Entity to the Minister of Finance no later than the last day of the Reporting Fiscal Year.

Stay Current with Our Latest Regulatory and Risk Advisory Insights. Subscribe Today.

¹Any capitalised terms not otherwise defined shall have the meanings ascribed to them in the applicable Bermuda legislation.

²As defined in the Investment Business Act 2003.

³The declaration includes confirmation of the company’s economic substance status, its financial year end date, whether it is Bermuda Constituent Entity (corporate income tax purposes), and compliance with its beneficial ownership obligations.

⁴As defined in the Investment Business Act 2003.

⁵Filing dates vary depending on the FYE. Due within 4 months of the FYE.

⁶Filing dates vary depending on the FYE. Due within 5 months of the FYE.

⁷Filing dates vary depending on the FYE. Due within 6 months of the FYE.

⁸Filing dates vary depending on the FYE. Due within 6 months of the FYE.

⁹Filing dates vary depending on the FYE. Due within 6 months of the FYE.

¹⁰Filing dates vary depending on the FYE. Due within 6 months of the FYE.

¹¹Filing dates vary depending on the FYE. Due within 6 months of the FYE.

¹²Nil declaration filings are also due.

¹³Filing dates vary depending on the FYE. Due within 6 months of the FYE.

¹⁴Filing dates vary depending on the FYE. Due within 4 months of the FYE.

¹⁵Filing dates vary depending on the FYE. Due within 4 months of the FYE.

¹⁶Country-by-Country Reports must be filed no later than 12 months after the last day of the Reporting Fiscal Year of the MNE Group.

Key filing deadlines and compliance insights for Bermuda domiciled entities.1

Bermuda Regulatory Filing Dates

Key Annual Dates / Filing Deadlines

Ongoing Annual Requirements

Key Annual Dates/Filing Deadlines

Key filing deadlines and compliance insights for Bermuda domiciled entities.¹