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Updates to Bermuda’s Economic Substance Declaration Portal

The Bermuda Registrar of Companies (RoC) has advised that the portal provided for the submission of Economic Substance Declarations (ESDs) will undergo an update on Monday, November 30, 2020.

In an industry notice issued on 26 November, the RoC listed the impacts of the portal update as follows:

  1. Deletion of Existing Incomplete ESD Filings

Any incomplete Economic Substance Declaration on the portal WILL be deleted at the time of the update on Monday, November 30, 2020. Any entity with an incomplete ESD filing on the portal should complete the filing prior to the update.

  1. Allowance for Entities with Zero Gross Income to File a Declaration

An entity that carries on a relevant activity is required to file a declaration, whether or not it earns any gross income in respect of the relevant activity, as set out in Section 6 of the Revised Guidance Notes dated 18 September 2020 (see note below). The updated portal will feature a question on this issue in the General section. A ‘Yes’ or ‘No’ response will be required. A response of ‘No’ will allow the entity to file a ‘Nil’ declaration.

  1. Collection of Additional Data

In order to achieve greater clarity and facilitate the analysis process, additional data collection fields have been added to the ‘Managed and Directed’ and the ‘Financial Information & Employees’ sections of the declaration.

  1. Self-Reporting of Non-Compliance with Economic Substance Requirements (ESR)

An entity that responds ‘No’ to the question of compliance with ESR in the ‘Declaration’ section will be required to check the relevant box to indicate each requirement with which it failed to comply.

  1. Filing Control – Financial Period

It will be mandatory for the entity to enter its year-end date before being allowed to proceed to file and/or save its Economic Substance Declaration.


To continue reading full articles in PDF format:
Updates to Bermuda’s Economic Substance Declaration Portal


Anthony D. Whaley

Bermuda   +1 441 299 4927

Neil Henderson

Bermuda   +1 441 298 7846

Jason Piney

Bermuda   +1 441 299 4993

Sophia Greaves

Bermuda   +1 441 294 5929

Christopher W.H. Bickley
Partner, Head of Hong Kong Office

Hong Kong   +852 2842 9556
Mobile  +852 6469 3356

Preetha Pillai
Director, Head of Singapore office

Singapore   +65 6603 0707

Eric Flaye

London   +44 (0)207 562 0341


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