Bermuda’s New Beneficial Ownership Regime: Key Takeaways From the Captive Education Summit

Jan 2026

Jennifer Panchaud, Director and Head of Conyers’ Bermuda Regulatory and Risk Advisory Team, and Associate Jacari Brimmer-Landy recently spoke at the Bermuda Captive Network’s 2026 Captive Education Summit on The Beneficial Ownership Act 2025 (the “Act”) and Bermuda’s new Beneficial Ownership Regime.

Here are six key takeaways from their talk:

1. Bermuda’s Beneficial Ownership Regime has been enhanced in accordance with increased international standards related to beneficial ownership and transparency. The new regime is applicable to all legal persons (including companies, limited liability companies and all forms of partnerships), with the only exception being for publicly listed entities on the Bermuda Stock Exchange or an appointed stock exchange, and any subsidiaries of such legal persons. Other exemptions found under the previous framework, including for financial institutions (such as insurance companies), have been removed.
2. The Central Register of Beneficial Ownership has now been moved from the Bermuda Monetary Authority (BMA) to the Bermuda Registrar of Companies (the “Registrar”). Entities which are otherwise not regulated by the BMA will have no touchpoints with the BMA.
3. The previous “gatekeeper functions” which were found under the Exchange Control Regulations 1973 and required the prior consent of the Exchange Controller for the issuance and transfer of securities have been repealed. The prior consent required for taking a charge over the shares of a Bermuda entity have also been repealed.
4. The Act sets out requirements to not only identify and verify the identity of beneficial owners and relevant legal entities, but also the importance of documenting and evidencing the steps taken to identify and verify such persons.
5. Pursuant to the Act, the Registrar may disclose information from the Central Register of Beneficial Ownership to certain “obliged entities”, for the purposes of enabling or assisting their statutory functions. Information disclosed by the Registrar to such obliged entities cannot be further disclosed (i) except in connection with statutory function of such person or (ii) with the consent of the Registrar.
6. The Registrar has stated that enforcement of the Beneficial Ownership Regime will begin on 1 June 2026. All legal persons should ensure they are in compliance before such date, including maintaining their Beneficial Ownership Register and ensuring that the necessary information has been filed with the Registrar. As part of complying with the Act, legal persons should also ensure that they and their Corporate Service Provider, as applicable, have the required documentation on relevant legal entities and beneficial owners to complete their Beneficial Ownership Register.

The Registrar has also published draft Regulations and Guidance Notes to be issued pursuant to the Act, which have been released to industry for comment. Comments on the draft Regulations and Guidance Notes are due by 30 January 2026.

If you have any questions regarding the new Beneficial Ownership Regime, please reach out to your usual Conyers contact or a member of the Conyers Regulatory and Risk Advisory Team.