Bermuda’s Beneficial Ownership Exemption Order 2026

On 14 September 2026, the Beneficial Ownership Amendment Act (the “Amendment Act”) was enacted, introducing changes to Bermuda’s Beneficial Ownership Act 2025 (the “BO Act”). The BO Act established a comprehensive beneficial ownership transparency framework for Bermuda legal persons, including the requirement to establish and maintain a beneficial ownership register and, subject to any exemption order made by the Minister of Finance (the “MoF”), to file prescribed beneficial ownership information in a central register maintained by the Registrar of Companies (the “RoC”).

In furtherance of the amended BO Act, the MoF issued the Beneficial Ownership Exemption Order 2026 (the “Exemption Order”) and the Beneficial Ownership Regulations 2026 (the “Regulations”), both of which came into effect on 25 September 2026.