On 31 March 2026, the Economic Substance Amendment Act 2026 and the Economic Substance Amendment Regulations 2026 (together, the "2026 Amendments") came into force, enacting changes to the Economic Substance Act 2018 ("ES Act") and Economic Substance Regulations 2018.
Regulatory Oversight Transitions to Corporate Income Tax Agency
The 2026 Amendments transferred responsibility for the administration, monitoring and enforcement of Bermuda's economic substance regime from the Bermuda Registrar of Companies ("ROC") to the Corporate Income Tax Agency (the "CIT Agency"), with effect from 31 March 2026. The transfer of economic substance regulatory oversight to the CIT Agency is part of a broader set of recent changes to consolidate Bermuda's international tax compliance functions under a single dedicated tax regulator. Other recent changes include transition of responsibility for the automatic exchange of information to the CIT Agency by designating the CIT Agency as the Competent
