Understanding The Updates In Bermuda's New Licensing Regime For Digital Identity Service Providers

Key Takeaways

• Bermuda's proposed new licensing regime for digital identity service providers (DISPs) has been further refined and updated, with five licensable activities reduced to two.
• The development of the DISP regime commenced with public consultation issued in November 2024, which sought stakeholder input on the concept and potential direction of the framework. This was followed by the publication of a stakeholder letter in April 2025 that summarised the feedback received during the initial consultation and presented key insights gained from stakeholders.
• The regime will be brought into effect by the Digital Identity Service Provider Business Act. The provision of digital identity services in or from within Bermuda will require a licence, with a prohibition on those activities being conducted by unlicensed persons.