On 1 July 2026, the BVI Financial Services Commission (FSC) issued Industry Circular 20 of 2026, updating the fee position for Economic Substance (ES) filings through VIRRGIN. This note summarises the public circulars — general information / an evergreen compliance reminder (the July circular remains relevant for November readers), not legal or tax advice.
Key point: the FSC will not implement fees for 2026 Economic Substance filings through VIRRGIN at this time. It will implement a new fee regime for ES filings through VIRRGIN for 2027; details of industry consultations will be shared later. The circulars do not publish 2027 fee amounts — do not invent figures.
What Circular 20 says
- No 2026 VIRRGIN ES filing fees for now — per Industry Circular 20 of 2026, the Commission will not implement fees for 2026 Economic Substance filings through VIRRGIN at this time.
- New regime planned for 2027 — the Commission will implement a new fee regime for ES filings through VIRRGIN for 2027, and will share details of the industry consultations referred to in its notice dated 18 February 2026 (Industry Update 6 of 2026).
- Queries — the circular directs related queries to support@bvifsc.vg.
How this relates to BOSS subscription fees
Per FSC Industry Update 6 of 2026 (18 February 2026): after the Economic Substance filing function moved to the VIRRGIN system, BOSS System subscription fees are no longer payable to the Ministry of Finance. That update also asked practitioners to watch for further communication on the fee regime and VIRRGIN ES filings. A change in fees / platform is not the same as repealing or relaxing substantive Economic Substance obligations under BVI law.
Practical compliance reminders
- Obligations remain — Circular 20 is about fees and the filing platform, not a repeal of the ES regime. Entities still need to meet applicable substance and filing requirements under BVI law.
- Platform is VIRRGIN — ES declarations moved from BOSS to VIRRGIN; confirm with your registered agent that access, permissions and filing workflows are ready.
- Do not guess 2027 fees — no official 2027 fee schedule is published in these circulars; wait for FSC consultation outcomes and later notices.
- Align with renewal / agent calendars — review ES alongside annual renewal, financial-return changes and agent arrangements.
Related background: BVI economic substance and renewal basics, BVI financial return revisions, BVI company overview.
Sources: FSC Industry Circular 20 of 2026 · Circular 20 PDF · Industry Update 6 of 2026
Related services: BVI & offshore company services · Annual examination / company renewal · Hong Kong profits tax filing
Related: BVI economic substance renewal · BVI financial return revisions · BVI company overview