On 2 November 2026, the BVI Financial Services Commission (FSC) issued Industry Circular 29 of 2026, publishing the BVI Business Companies (Financial Return) (Amendment) Order, 2026 and the Limited Partnership (Financial Return) (Amendment) Order, 2026 (together, the Amendment Orders). On 6 November 2026, it followed with Industry Circular 31 of 2026 and the guidance titled Guidance on Completing Annual Financial Returns Pursuant to Section 98A of the BVI Business Companies Act, Revised Edition 2020 and Section 54A of the Limited Partnership Act, Revised Edition 2020. This note summarises the two public circulars — general information / a compliance reminder only, not legal or tax advice.
Key point: The Amendment Orders take effect from 2 November 2026, with implementation and compliance applying to returns that must be filed/submitted from 2027 onwards. Business companies must report additional information on assets, revenue and expenses; limited partnerships must report additional information on assets, income and expenses. Form-level detail follows Circular 31’s Guidance and the Orders — this article does not invent field lists or figures.
Circular 29: what the Amendment Orders cover
- They revise the form of filing and the information that annual financial returns must contain under section 98A of the BVI Business Companies Act and section 54A of the Limited Partnership Act.
- BCs: additional information on assets, revenue and expenses. LPs: additional information on assets, income and expenses.
- Effective 2 November 2026; compliance applies to returns due from 2027 onwards.
- The FSC hosted a sensitisation webinar on 8 October 2026; Circular 29 notes that the webinar slides and FAQs remain available on the FSC website.
Circular 31: completion guidance is live
Circular 31 confirms that, further to Circular 29, the Commission issued the Guidance on 6 November 2026 to help BVI business companies and limited partnerships understand and comply with annual financial return obligations using the revised forms. Queries may be directed to externalrelations@bvifsc.vg.
How this relates to our earlier note
We previously summarised the October webinar / FAQ outlook in BVI financial return revisions — stronger disclosure ahead. This article covers the published Amendment Orders and the issued Guidance — rely on Circulars 29 and 31 and the Guidance text, not webinar memory alone.
Practical tips for Hong Kong owners / company secretaries
- 2026 filings ≠ immediate universal use of the new form — per Circular 29, compliance targets returns that must be filed from 2027; confirm your entity’s next cycle and form version with the registered agent.
- Ready the books early — extra disclosure on assets, revenue/income and expenses usually needs reconcilable ledgers, bank statements and classifications; do not wait for the agent’s chase letter.
- Keep ES separate — section 98A / 54A financial returns are distinct from Economic Substance filings via VIRRGIN (see our VIRRGIN ES fee circular note).
- Align agent / renewal plans — if you are changing registered agent or handling renewals, ask whether the agent can support the 2027 revised-return workflow.
Sources: FSC Industry Circular 29 of 2026 · FSC Industry Circular 31 of 2026 · BVI FSC Industry Updates
Related services: BVI & offshore company services · Annual examination / company renewal · Accounting · Hong Kong profits tax filing
Related: Earlier financial-return revisions note · BVI ES / VIRRGIN fees · BVI economic substance renewal · BVI company overview