Compliance calendar for BVI Approved Managers – 2025

Deadline

Requirement

Action required / notes

31 January 2025

Annual return deadline

An annual return must be filed with the FSC in the prescribed form providing details of the following, as at 31 December 2024:

• Number of persons for which the manager provides services

• Assets under management for each person for which the manager acts

• Number of investors in each person for which the manager acts

• Any significant complaints received by the manager

• Confirmation that each director and senior officer of, and shareholder holding a significant interest in, the manager is "fit and proper"

• That the manager is not in breach of the Regulations that entitle it to continue as a manager

Ogier's Legal team can assist with the preparation and filing of the annual return.

31 March 2025

Annual fee due

Annual fee of US$1,800 is payable by the fund to the FSC.

If Ogier Global is the manager's authorised representative, Ogier Global will include this fee as part of their annual bill to the manager and will make the payment to the FSC.

31 March 2025

AML / CFT return deadline

The AML / CFT Return must be filed for the period from 1 January to 31 December 2024 on the dedicated AML / CFT return portal.

If not already registered, the manager needs to register on the portal as a new user. The FSC have issued a user guide on how to file an AML / CFT return.

Access the AML / CFT return user guide.

31 May 2025

FATCA / CRS reporting deadline

The manager's FATCA authorised person is required to make the relevant FATCA/CRS filings via the International Tax Authority's reporting portal – BVIFARS.

Ogier can provide FATCA / CRS services on request.

31 March 2025

(for managers with a 30 September financial year end only)

30 June 2025

(for managers with a 31 December financial year end only)

30 September 2025

(for managers with a 31 March financial year end only)

31 December 2025

(for managers with a 30 June financial year end only)

Unaudited financial statements deadline

Unaudited financial statements for the manager must be submitted to the FSC within six months of the manager's financial year end (meaning by 30 June 2025 for funds with a 31 December 2024 year end).

The financial statements must be approved or signed by a director or the general partner of the manager and must be accompanied by a director’s certificate, a report on the affairs of the manager made in respect of the relevant financial year and any other documents that may be prescribed by the Regulations.

In limited circumstances, it is possible to request an extension to the filing deadline or an exemption from filing such accounts. The FSC will not accept late exemption / extension applications and so it is important that any such applications are made in advance of the filing deadline. The maximum extension permitted under law is six months.

Ogier's Legal team can assist with the filing of the unaudited financial statements.

30 June 2025

(for managers with a 31 December end reporting period – date will change if a different reporting period applies)

Economic substance

Economic substance annual self-certification is due within six months of the end of the applicable reporting period. Self-certifications are submitted via the manager's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS).

The statutory definition of "fund management business" does not currently require an approved manager to maintain substance in the BVI unless its activities also require an investment business licence.