BVI Annual Financial Return — the new requirement.
What goes in the return, when it is due, who files, the penalty schedule, and which companies are exempt. The 2023 change brings BVI into FATF Rec 24 alignment.
The new rule, in one paragraph
From financial years beginning on or after 1 January 2023, every BVI Business Company must prepare an Annual Financial Return and file it with its registered agent within nine months of the financial year-end. The return is not lodged with the public registry — the agent retains it on file and produces it to the BVI Financial Services Commission on request. Audit is not required for non-regulated BCs. The change brings the BVI into line with FATF Recommendation 24 and EU equivalence expectations.
What the Annual Financial Return contains
The return is a single document with two parts:
- Balance sheet — assets and liabilities as at the financial year-end, in any reasonable accounting framework (BVI does not mandate IFRS, US GAAP or UK GAAP — pragmatic accounting principles consistent with the prior year suffice for non-regulated BCs).
- Income statement — revenue, expenses, profit / loss for the financial year.
The figures must be in a single currency (typically USD) and prepared on a basis consistent with the company's prior year. There is no requirement for a directors' report, an auditor's report, notes to the accounts, or a cash-flow statement. The format is deliberately accessible to non-regulated BCs without an accountancy back-office.
Deadline and filing
- 9 months from financial year-end to file with the registered agent.
- Filing is with the agent, not the BVI FSC. The agent retains the return on file for at least 5 years.
- The agent produces the return to the FSC on request — typically in connection with a compliance audit, a competent-authority information request, or a regulatory enforcement action.
- The return is not public. No filing fee. No publication.
Penalties for non-compliance
- Failure to file the return on time: USD 300 initial penalty + USD 200 per month of continued non-compliance, capped.
- Failure to file for more than two consecutive years: FSC may strike the company off the register. Restoration is possible but costly and time-consuming.
- The registered agent has a statutory obligation to report non-compliance to the FSC.
Companies exempt from the requirement
- Listed companies on a recognised stock exchange.
- Regulated entities (BVI FSC-licensed companies — banks, insurers, fund managers, VASPs) — these already file with the FSC under their respective regulatory regimes.
- Tax-resident-outside-BVI entities whose financial statements are filed with the relevant tax authority — limited carve-out, fact-specific.
What ArxSetup handles
Annual Financial Return preparation and filing is bundled into our year-2-onwards BVI maintenance retainer at USD 200 per year. The preparation typically takes 1–2 hours of our accounting team's time for a standard non-trading holding BC, and 4–6 hours for an active-business BC with material transactions. We use the company's bookkeeping records (or, if there are no formal records, we reconstruct from bank statements). We do not provide audit — audit is not required for non-regulated BCs.