BVI Approved Manager (Approved Investment Manager) Application and Compliance Guide

Approved Manager is a specific investment management/advisory approval route supervised by the FSC, not an unrestricted financial licence. First determine whether the clients and activities qualify, then check governance and assets under management.

No uniform minimum paid-up capital does not mean that operations can be conducted without any funds.

Application Package: Seven Document Groups Must Be Consistent

Organise the application package into seven groups: entity, controllers, business, execution, contracts, declarations and fees. Include the constitutional documents of the BVI company or limited partnership; details and CVs of directors/general partners, officers and significant-interest holders; fit and proper declarations; for each proposed service recipient, its name, address, place of incorporation, assets or proposed amount to be raised, and service status; investment management or advisory agreements; details of persons performing day-to-day investment functions; outsourced functions, service providers and delegation agreements; confirmation of consent from local counsel; and a completeness declaration from an authorised representative or lawyer. An application may be treated as incomplete if required attachments or prescribed fees are missing.

• An Approved Manager is not a qualification that comes with ordinary company registration. The eligible entities are limited to a BVI Business Company or a limited partnership registered under the Partnership Act. Once approved, the applicant may act only as an investment manager or investment adviser within the limits of Regulations Article 9.
• A corporate Approved Manager must continuously have two directors, at least one of whom is a natural person, and one authorised representative certified by the FSC under SIBA Section 64; a limited partnership must continuously have at least one general partner. Source: Regulations Sections 3, 13; Guidelines paragraph 6.1.1.
• The current publicly available official fee basis is S.I. No. 5 of 2023: application US$1,200, approval US$1,800, and annual renewal US$1,800. This amendment took effect on 2023-04-01. A review of official FSC and BVI Laws materials on 2026-11-02 did not identify a later public amendment replacing these three Approved Manager fees. Before payment, the authorised representative or registered agent should nevertheless verify the fee schedule in force on that date.
• No uniform minimum paid-up capital, minimum net assets or BVI-based full-time employee threshold applicable to all Approved Managers was found in the Regulations or Guidelines reviewed for this purpose. US$400m, US$1bn or US$100,000 must not be presented as minimum capital requirements for the manager itself.
• US$400m is the aggregate AUM cap relevant to private/professional funds; US$1bn is the AUM cap for one or more qualifying closed-ended funds. They are calculated separately. US$100,000 is the initial investment threshold for each non-exempt investor in a structure with professional fund characteristics; it is not the manager’s capital.
• An Approved Manager must submit financial statements, generally within six months after the financial year-end. Paragraph 6.2.3 of the official Guidelines states that it is not required to appoint an auditor. This does not mean automatic exemption from audit, financial statements or books and records; an exemption from financial statements must be applied for in writing and is subject to the FSC’s decision.
• Regulations section 15 provides specific exemptions from the compliance officer and compliance procedures manual requirements in section 34 of the FSC Act. This does not amount to an exemption from AML/CFT laws, KYC, sanctions screening, reporting or any MLRO/compliance arrangements that are actually required.
• For an ordinary BVI BC, US$550/US$1,350 are examples in the company registration fee schedule associated with the number of authorised shares and other company-class conditions. They are not Approved Manager fees and cannot be applied to limited partnerships. For a common ordinary share company that is applicable and authorised to issue no more than 50,000 shares, the lower annual government-fee baseline may be shown as US$2,350 = Approved Manager annual renewal fee US$1,800 + company annual government fee US$550. This excludes registered agent, authorised representative and all professional service fees.

First separate the application stage, annual government fees, professional services and operating resources. The government amounts below reflect the verified basis; actual payments should be checked against the current fee schedule and entity category.

• Do not guarantee FSC approval, a fixed processing time, an unconditional right to continue operating after application, a bank account, tax exemption, or access to any foreign market. The Guidelines state only that the FSC will endeavour to process applications within the statutory determination period or any valid extension.
• Do not treat the US$1,000 still shown at item 8 of the public IB-A1 template as the current application fee. The verified conclusion for this review is US$1,200 as listed in the fee regulations for 2023; recheck the official fee schedule in force on the payment date before paying.
• Do not apply the US$550 / US$1,350 company fees for an ordinary BVI BC to a limited partnership, or describe them as manager capital, Approved Manager fees or registered-agent service fees.
• Do not describe a CO's specific exemption as a blanket exemption from AML/CFT, MLRO, KYC, sanctions screening, record-keeping or reporting obligations.
• Do not state that an audit is “always exempt” or that financial statements are “automatically exempt”. Official guidance only states that there is no requirement to appoint an auditor; financial statements generally still need to be filed within six months after year-end, and any exemption is subject to a written FSC decision.
• Do not describe US$400m, US$1bn or US$100,000 as the manager’s minimum paid-up capital. State at the same time that each is an AUM limit or an initial investment threshold for professional fund investors.
• This page is limited to Approved Manager application conditions, capital concepts, and ongoing cost maintenance. Tax, economic substance, CRS/FATCA, regulation of the fund itself, overseas marketing, and any other licence should be addressed separately through qualified legal, tax, or regulatory advice based on the actual activities.
• An Approved Manager is generally not required to appoint an auditor, but this does not mean that financial statements or books and records are automatically exempt, or that the FSC cannot make case-specific requirements.

An Approved Manager is an FSC approval regime established for specified fund management/advisory activities of a lower degree of risk, nature and complexity. A qualifying person need not obtain a separate standard SIBA investment manager or investment adviser licence for the relevant business permitted by the Regulations; this does not mean that it is unregulated. Once approved, the entity remains a regulated person under the FSC Act and is subject to the FSC’s supervision, information requirements and enforcement powers.

The advantage of this regime is a relatively streamlined approval framework for eligible businesses, not permission to conduct every kind of investment, payment, insurance or other financial product business after approval. The FSC may approve only if the information is complete, fees have been paid, the applicant is fit and proper and is expected to comply, and the FSC considers approval not contrary to the public interest. Marketing must not describe an application, provisional ability to operate or an adviser’s preliminary review as a guarantee of approval.

• The regulator is the BVI FSC, and the principal framework for investment business is SIBA and the Approved Manager Regulations.
• The permitted scope is limited to the relevant business specified in section 9 of the Ordinance; a standard licensing route may still be applied for separately.
• The FSC may, in the public interest, require an Approved Manager to apply for a standard licence or cease some or all of the relevant business.

The Regulations apply to a BVI Business Company or a limited partnership registered in the BVI. Application documents must be signed by a director or general partner. If a company incorporated outside the BVI, an individual, a trust itself or an unregistered structure is proposed as the direct applicant, do not assume that it inherently qualifies for Approved Manager status; first have BVI counsel and the registered agent verify the legal vehicle and registration status.

Incorporation under company law and Approved Manager approval are two parallel matters. A BVI company must maintain a registered agent and registered office; amendments to company law in 2024 also introduced a requirement to file company information directly with the Registrar. To avoid inconsistencies among incorporation, director appointments, the register of members, beneficial ownership information and the regulatory application, the structure and signing authority should in practice be checked before submitting IB-A1.

• A BVI company must continuously have at least two directors, at least one of whom must be a natural person.
• An approved manager of a limited partnership must continuously have at least one general partner.
• The application form must specify the entity type, date of incorporation/registration, number, address, and proposed commencement date.

An Approved Manager may act as investment manager or investment adviser to BVI private funds, professional funds and qualifying closed-ended funds with private or professional fund characteristics. It may also serve qualifying affiliates of those fund structures. The Regulations also allow other persons approved in writing by the FSC on a case-by-case basis, as well as certain foreign structures meeting statutory equivalence and investment-association conditions.

Determining the scope of business is not simply a matter of checking whether the customer’s name includes the word “fund.” The type and place of establishment of the fund, investor restrictions, investment relationship and the actual services provided by the applicant as a manager, adviser or both should all be checked. For structures outside recognised jurisdictions, the regulations impose limits on their equivalence and on the extent of investment in qualifying fund structures; an ordinary offshore company or ordinary customer account cannot be used as a blanket substitute.

• Investment management, investment advice, or both may be provided, but the scope should be consistent with the application form and agreements.
• A qualifying affiliate will generally have been established or directed by the fund or its functionaries, and will hold or make investments for the fund or its investors.
• For clients, business or funds outside the scope of the regulations, obtain appropriate written regulatory advice or convert to a standard licence before commencing.

For structures with private fund characteristics, the guidance provides two basic routes: the fund is not authorised to have more than 50 investors, or invitations to subscribe for or purchase fund interests are made on a private basis. A private basis generally involves offering an opportunity to specified persons or making an invitation on the basis of a private or business connection; it is not synonymous with broad public marketing.

For a structure with professional-fund characteristics, fund interests should be offered only to professional investors or equivalent qualified investors in recognised jurisdictions. Except for exempt investors, each investor’s initial investment must be at least US$100,000 or the equivalent in another currency. A closed-ended fund must also satisfy the definition of a collective investment vehicle that is not a SIBA mutual fund, or receive written, case-specific recognition from the FSC.

• In the application form, list each proposed service recipient, their location, whether the relationship is existing or new, the assets or proposed fundraising amount, and the capacity in which the services will be provided.
• A foreign fund cannot be presumed equivalent merely from its name or place of registration; a documented assessment of its characteristics and investment relationships is required.
• Fund documents, subscription materials and investment management/advisory agreements should be consistent with one another.

The Approved Manager Regulations expressly provide that, except for the relevant investment business specified in section 9 of the Regulations, an approved manager must not carry on other business unless another licence applies or the FSC gives written approval. Accordingly, it cannot use the Approved Manager status to conduct general currency exchange, money transfers, currency conversion, financing, insurance underwriting, insurance management or insurance intermediary business.

Money services and financing businesses are subject to a separate licensing regime under the Financing and Money Services Act, 2009; insurance business and insurance managers/intermediaries are subject to separate licensing under the Insurance Act, 2008. A portfolio may include financial institutions, insurance-related securities, or investments in funds; this does not authorise the investment adviser itself to conduct money services or insurance business.

• Do not describe Approved Manager as a money services licence, payment licence, banking licence or insurance licence.
• Where multiple regulated activities are involved, obtain a licence or written regulatory confirmation separately for each actual activity.
• If new business falls outside the relevant business described at the time of application, assess first whether this triggers loss of eligibility and a notification obligation.

The combined assets under management of an Approved Manager’s private and professional funds must not exceed US$400 million or its equivalent in another currency; the assets under management of one or more closed-ended funds must not exceed US$1 billion. These two thresholds must be treated separately. US$1bn must not be misrepresented as a universal cap for all funds, and US$400m must not be mistaken for the applicant’s minimum capital.

For an open-ended fund, AUM is calculated as the net asset value of outstanding assets on the valuation date less liabilities. For a closed-ended fund, it is the total capital committed by investors. Where the same manager serves multiple structures and the assets of one structure include interests in another managed structure, that overlapping interest may be excluded from the aggregate where the conditions in the guidance are met; amounts outside the structures must still be included.

• After exceeding the applicable limit, written notice must be given to the FSC within 7 days.
• Once the threshold is exceeded, in principle, there are 3 months to return below the threshold, apply for a standard SIBA licence, or obtain written FSC approval to continue operating.
• The regulations do not impose a general cap on the number of funds; however, each relationship must still fall within the permitted scope and be truthfully disclosed.

The application must disclose information on each director or general partner, officer and person owning or holding a significant interest, and include fit-and-proper declarations. The information identified in guidance IB-A1 includes the principal persons, natural persons representing corporate shareholders, ultimate beneficial owners, ownership percentages, director/officer biographies and persons actually performing day-to-day investment business functions. Prepare the information based on the true control chain and actual responsibilities.

The FSC’s approval assessment includes whether the applicant and related persons are fit and proper and whether the applicant will comply after approval. Fitness and propriety do not arise automatically from completing a self-declaration form. Incomplete, inconsistent or unexplained information on ownership, biographies, sanctions, integrity or business arrangements may lead to requests for further information, delay or refusal. Applicants and registered agents should maintain an updatable register of ownership and control.

• Application materials should allow tracing from the direct shareholders to the ultimate individual beneficial owners or to an applicable basis for exemption.
• Significant interest, BO and the threshold for access based on legitimate interest are not the same concepts across different regimes; their percentages should not be conflated.
• Changes to control, shareholding, directors or senior officers trigger a review of both regulatory application materials and company registration materials.

A corporate Approved Manager must maintain at least two directors at all times, one of whom must be a natural person. It must also continuously appoint an Authorised Representative certified by the FSC under section 64 of SIBA. The Authorised Representative is a continuing position expressly required by the Regulations and is not necessarily the same as the company’s registered agent, a director or an ordinary business contact.

The Approved Managers Regulations expressly exempt an Approved Manager from the compliance officer and compliance procedures manual requirements under section 34 of the FSC Act referred to in those Regulations. Accordingly, a CO should not be described as a position that every Approved Manager must, without exception, separately appoint under those Regulations. By contrast, the FSC’s AML/CFT annual return notice expressly lists Approved Managers among the reporting entities. Whether an MLRO, a compliance function and AML arrangements are required must be determined case by case, based on actual activities, AML laws and current FSC directions; the CO exemption alone cannot support a conclusion that AML requirements do not apply.

• An authorised representative must remain in place at all times; any change or eligibility issue should be assessed first for its regulatory impact.
• The director/general partner should take actual responsibility for signing the application and financial statements, and for ongoing governance.
• The CO, MLRO, registered agent, and authorised representative may be different persons or qualified service providers, provided that each appointment complies with the applicable regulations.

As of the verification date, neither the Approved Managers Regulations cited in this article nor the official Approved Investment Managers Guidelines specifies a uniform minimum paid-up share capital, minimum net assets or number of local full-time employees. Accordingly, any claim that US$400m, US$1bn or US$100,000 is the Approved Manager’s own minimum capital is inaccurate; these figures respectively relate to AUM limits or characteristics of professional funds.

The absence of a published uniform capital figure does not mean that operating resources may be absent. The application should explain which individual will conduct day-to-day investment business, whether any functions will be delegated, to whom, and under what agreements. The FSC also reviews the credibility of the organisation, personnel, business and information when assessing fitness and expected compliance. Capital, staffing and budget should be proportionate to the scale of the business, investor protection, risks and outsourcing arrangements.

• Statutory minimums: a company must have two directors, at least one of whom is a natural person; a limited partnership must have at least one general partner; an authorised representative is also required.
• The application form must identify the individual responsible for day-to-day investment business functions.
• Evidence should be retained of operating budgets, allocation of responsibilities, service contracts, delegation oversight, and the ability to prepare financial statements.

A BVI company must maintain a registered agent and registered office under company law, but a registered address alone does not establish the place of actual management, day-to-day investment decision-making or economic substance. An Approved Manager application should also identify who performs the day-to-day investment business and whether any functions are outsourced. Actual arrangements for board resolutions, investment decisions, oversight of delegates, recordkeeping and service locations should be consistent with the representations in the application.

The Economic Substance Act defines fund management business as activities requiring an investment business licence in Category 3 under section 4 and Schedule 3 of SIBA. Approved Manager is an approval route under the regulations; an entity does not hold that standard licence merely by virtue of being an Approved Manager. Therefore, it cannot be classified automatically as a fund-management relevant activity solely because it has been approved. Conversely, it cannot be represented as automatically exempt from all economic substance obligations: if the entity separately carries on holding, financing and leasing, or another relevant activity, each must still be assessed by reference to the actual activity.

• A registered office is a different concept from actual operations, tax residence, and economic substance tests.
• Where an activity is relevant to economic substance, statutory requirements include being directed and managed in the BVI, and having appropriate employees, expenditure, premises and core income-generating activities, depending on the nature and scale of the activity.
• Any economic substance conclusion should be based on all of the entity’s actual business activities, not merely its Approved Manager certificate.

BVI 2024／2025 company law reforms have made compliance for registering members’ registers, director information and beneficial ownership information an important part of incorporation and ongoing maintenance. Directors’ names fall within the director-register information that may be publicly searched or inspected; they should not be promoted as absolutely non-public. This does not mean that every item of a director’s personal information is available to anyone without restriction. The investment business register can also provide information about an Approved Manager, including its registered address, service address, approval type, status, whether fees are up to date and the name of its authorized representative.

Beneficial ownership is not an unconditional public database accessible to everyone. Under the FSC’s 2026 BO guidance, from 2026 4 1, a natural or legal person able to demonstrate a legitimate interest may apply for access in relation to a specified legal entity. The purpose must relate to the prevention, investigation or detection of money laundering, terrorist financing or proliferation financing, or the applicant must be an obliged entity performing BVI CDD obligations. Accessible information concerns BOs meeting the specified control/25% threshold and includes name, month and year of birth, nationality, and the nature of the interest/control.

For legal entities incorporated, registered or continued into the BVI on or after 1 July 2025, BO information or exemption information generally must be filed within 30 days; after a change in filed BO information, the legal entity must update it within 30 days after becoming aware of the change. The zero-fee filing grace period previously available to older entities expired on 31 March 2026. As of the verification date, it should not be claimed that all existing companies can file late at no charge.

• The company should maintain a unified register of changes to shareholders, directors, BOs, contact details, and control, and have the registered agent handle statutory filings.
• A legitimate-interest access application is based on the entity’s name, not an unrestricted public search by an individual’s name; the entity has notification, objection and related procedural rights.
• The scope of information and access rules differs for BO, the register of members, director information, the public register of investment business, and AML KYC.

The annual financial return under section 96A of the BVI Business Companies Act is a company-law annual financial return submitted by a company to its registered agent. It is not the regulatory annual return that an Approved Manager submits to the FSC each year in January. An FSC notice issued in 2025 explains that ordinary companies submit this annual return to their registered agent; if it is late, the registered agent must notify the Registrar as required by law. The two returns are not interchangeable.

The notice also lists exempt categories, including companies regulated under financial services legislation and required to report financial statements. The Approved Manager Regulations require an Approved Manager to prepare and submit financial statements; accordingly, a company may fall within that exemption based on its specific regulatory status. The registered agent should still confirm this by reference to the filing period and the entity’s facts. The exemption should not be misunderstood as releasing the Approved Manager from the 1 month 31 day regulatory annual return, financial statements, or other compliance obligations.

• Companies Act annual financial return: usually submitted to the registered agent, not automatically to the FSC.
• Approved Manager annual return: file with the FSC by 1 31 each year.
• Approved Manager financial statements: generally filed with the FSC within 6 months after financial year-end, with a mechanism to apply for a written exemption in limited circumstances.

The application uses the FSC’s IB-A1 form and must be signed by a director or general partner. Statutory basic materials include constitutional documents; information about directors/general partners/senior officers and persons with significant interests; fit-and-proper declarations; the number and details of funds proposed to be served; the proposed commencement date; an investment-advisory or investment-management agreement with each proposed client; confirmation of the person performing day-to-day investment functions; confirmation of delegation arrangements; and a lawyer’s confirmation letter and a completeness declaration from the authorized representative or lawyer.

If a relevant business function has been or is intended to be outsourced, the outsourced function and service provider must be identified, and the outsourcing agreement submitted. The FSC may request clarification or further information. Missing attachments, unpaid application fees, improper execution or inconsistencies in client information may cause an application to be treated as incomplete and may lead to refusal. First cross-check KYC, the ownership chart, CVs, fund eligibility and the versions of the agreements.

• Use the forms and electronic submission procedures published by the FSC as of the submission date.
• Each proposed service recipient should provide its name, address, place of incorporation, relationship status, assets/proposed fundraising amount, and service capacity.
• The lawyer, authorised representative, registered agent and applicant should first align on control, business scope and document versions.

A complete application must in principle be submitted at least 7 days before the proposed start of the relevant business, unless the FSC accepts a shorter period in writing. If correctly submitted within that period, the applicant may conduct the relevant business from the date of submission of the application for up to 30 days; the FSC may, on its own initiative or on application, extend this by up to 30 additional days. The statutory wording starts the period on the submission date, not the preparation date, and does not allow business to begin before 7 days.

The FSC guidance states that it will endeavour to process the application and communicate its decision within that 30-day period or any extended period. This is a regulatory target, not a promise of approval. If the FSC refuses the application, an applicant operating under the interim mechanism must immediately cease the relevant business. If the period expires without approval and no valid extension is in place, the applicant must also cease. Document preparation, KYC, further information requests, customer structure and registration status all affect actual progress.

• Completeness and the application fee are prerequisites for the interim operating mechanism; business cannot commence first and documents be supplied later.
• The expected document preparation period can be estimated as a project based on complexity, but it is not a statutory commitment by the FSC.
• In the absence of a written short-term exception, work backwards from the intended opening date and submit at least 7 days in advance.

When reviewing an application, the FSC will confirm whether the required information and fees are complete, whether the applicant is fit and proper, whether it can comply with the Regulations after approval, and whether approval would be in the public interest. If these conditions are met, the FSC may approve the application, enter the entity in the Approved Managers register and issue an approval certificate. The certificate and registration status are the formal evidence of final approval.

The FSC may refuse an application on grounds including unsuitability, anticipated non-compliance, material incompleteness or the public interest, and must give the applicant reasons. Complete information does not guarantee a particular outcome. This also means that a service provider’s preliminary assessment, filing receipt or temporary permission to operate should not be described externally as approval.

• Even after final approval, only the relevant business activities within the scope of Article 9 of the Regulations may be conducted.
• Keep the approval certificate, registration information, payment records and submitted versions.
• If the application is refused and the business has been conducted under a temporary mechanism, the relevant business must cease immediately.

Acquiring shares, changing the ultimate controller, changes to directors or senior officers, changes to the funds proposed to be served, changes to the person performing day-to-day functions, and changes to outsourcing arrangements will generally alter information submitted at the time of application under section 5 of the Regulations. An Approved Manager must notify the FSC in writing within 14 days after such information changes, provide details of the changes and a declaration in the prescribed form stating whether, after the changes, it continues to comply with the Regulations. The FSC must also be notified of matters that have or may have a material regulatory impact.

A change-of-control transaction should not be handled merely as a company-secretarial change. In addition to notifying the FSC within 14 days, changes to beneficial ownership information generally must be updated with the registry within 30 days after the entity becomes aware of them. The register of members, director information, authorised representative, fund contracts, signing authorities, KYC and sanctions screening should also be reviewed concurrently. The provisions cited in this text do not state that every acquisition of control is uniformly subject to automatic prior approval; that does not justify skipping an assessment of continuing eligibility and written-notification requirements.

• Before signing, first identify whether the transaction changes any significant beneficial owner, BO, director, senior officer or business scope.
• Transaction documents should allocate responsibility and evidence requirements for information, KYC, register updates, FSC notifications and BO updates.
• If the transaction would cause the entity to cease to qualify, stop accepting new related business and assess conversion to a standard licence.

An Approved Manager must submit a prescribed annual return to the FSC no later than 1 31 each year. The return must confirm that there has been no breach of the requirements for maintaining eligibility and that directors, senior officers and shareholders holding significant interests are fit and proper. It must also report, as at 12 31 of the preceding year, information such as clients, each client's AUM, the number of investors for each client and material complaints. Year-end data, complaints records and AUM calculations should be incorporated into the annual calendar in advance.

The FSC’s AML/CFT return notice expressly includes Approved Managers among the entities required to file. However, 3 month 31 day in the notice for 2024 is the specific deadline for that year’s reporting period; it must not be treated as a date that remains unchanged permanently for 2026 and subsequent years. For every reporting year, the entity should verify the VIRRGIN portal, current notice, AML/CFT classification, responsible personnel, and consequences of late filing, and retain the relevant KYC, due-diligence, risk-assessment, and filing evidence.

• The fixed statutory deadline for the Approved Manager annual return is 1 31 each year.
• The reporting data is as of 12 31 of the previous year; unverified marketing AUM cannot be substituted for the statutory basis.
• AML/CFT forms, fields, deadlines and responsible persons should be determined by reference to the current FSC instructions.

An Approved Manager must prepare and submit financial statements to the FSC, generally within 6 months after the relevant financial year-end, and in accordance with the prescribed accounting standards. The statements must be signed by the directors; for a limited partnership, they must be signed by the general partner. They must be accompanied by a directors' certificate or corresponding general partner certificate, a business report for that financial year and the prescribed documents. The FSC may require incomplete, inaccurate or non-compliant documents to be resubmitted or replaced.

Official guidance states that an Approved Manager is not required to appoint an auditor, but this does not mean that it has no financial-statement obligations or may fail to keep accounting records. An entity that conducted no business during the year may apply in writing for a financial-statement exemption by the filing due date or within an extended period. An entity that conducted business but considers that it has sufficient grounds generally must apply in writing at least 3 months before the due date. The FSC decides whether to grant the application.

• The absence of a mandatory auditor appointment does not mean there is a default exemption from audits, financial statements, or record-keeping.
• An exemption must be applied for in writing; non-filing cannot be based solely on dormancy or the absence of fees.
• Manage annual financial returns under company law, Approved Manager financial statements, and tax/economic substance materials separately.

The FSC's Financial Services (Fees) (Amendment) Regulations, 2023, list the following fees for an Approved Manager: application for approval, US$1,200; approval as an Approved Manager, US$1,800; and annual renewal of approval, US$1,800. These fees have different triggers. It is not sufficient to state only US$1,200/US$1,800 while omitting the US$1,800 payable upon approval, nor should the application fee be described as covering final approval or all costs of maintaining the status for a full year.

Government fees for BVI company formation, annual company fees, and filing registers of members, directors, and BO are part of the company-registration regime and are not the same fee schedule as Approved Manager FSC fees. Amounts vary according to authorised shares, company status, formation date, transitional fee notices, and the filings involved. A zero-fee grace period for certain filings by existing companies in 2025 year ran only until 2026 year 3 month 31 day; as of the verification date, it should not be presented as a current, generally available concession.

• The above US$1,200 / US$1,800 / US$1,800 are government fee amounts as stated in the regulatory fee schedule.
• Costs for registered agents, registered offices, authorised representatives, lawyers, accountants, auditors, KYC, translation, courier services, and banking are charged separately by third parties.
• Before payment or quotation, ask the registered agent to confirm the company registration government fee based on the entity’s authorised shares, incorporation date and current fee schedule.

Ongoing maintenance should cover directors and authorized representatives in office; fund eligibility; AUM; shareholdings and BO; business agreements; delegation arrangements; complaints; annual returns; financial statements; fees; and AML/CFT filings. Authorized representatives, lawyers or registered agents may assist with submissions, but cannot replace the directors’/general partners’ responsibility for the accuracy of information, business scope and compliance judgments. For outsourced investment, operational, compliance or administrative functions, there should be clear agreements, oversight records and rights to obtain information.

If an entity ceases to meet the Approved Manager conditions, it must notify the FSC immediately and stop accepting any new related business. In general, it has 3 months from the date it ceases to qualify to stop existing related business; subject to applicable conditions, it may regain qualification, apply for a standard SIBA licence, or obtain the FSC's written permission to continue operating. If the FSC requires a standard licence or cessation of business in the public interest, corresponding rules also apply for conversion within 3 months or immediate cessation.

• Review the scope and AUM quarterly or whenever a new fund is onboarded, to avoid discovering an excess only at year-end.
• Record in the compliance calendar the deadlines for notifying an AUM limit breach within 7 days, notifying changes to application information within 14 days, updating BO information within 30 days, and filing annual returns.
• Before liquidation, ceasing operations, converting a licence or selling a business, plan for matters involving the FSC, Registrar, registered agent, customers, contracts and record retention together.

The links below facilitate verification of laws, application guidance, and fees. Older documents may remain in official repositories; confirm the latest applicable version before submission.

1. BVI FSC｜Investment Business (Approved Managers) Regulations, Revised Edition 2020 ↗
2. BVI FSC｜Approved Investment Managers Guidelines, consolidated 25 February 2014 ↗
3. BVI FSC｜Financial Services (Fees) (Amendment) Regulations, 2023, S.I. No. 5 of 2023 ↗
4. BVI FSC｜Economic Substance (Companies and Limited Partnerships) Act ↗
5. BVI FSC｜Revised Beneficial Ownership Guidelines, January 2026 ↗
6. BVI FSC｜Industry Circular 11 of 2026: Legitimate Interest Transactions and Request to Inspect BO Register ↗
7. BVI FSC｜Industry Circular 26 of 2025: Filing Initial Annual Returns ↗
8. BVI FSC｜Industry Circular 46 of 2025: Extension of Dates for Filing Fees ↗
9. BVI FSC｜Industry Circular 2 of 2024: Filing of AML Returns ↗
10. BVI FSC｜BVI Business Companies (Amendment) Act, 2024 ↗
11. BVI FSC｜BVI Business Companies (Amendment of Schedule 1) Order, 2024 ↗
12. BVI FSC｜Financing and Money Services regulatory overview ↗
13. BVI FSC｜Expanded Search Functions Available for Investment Business Registers ↗
14. BVI FSC｜IB-A1 Approved Investment Manager Application Form ↗
15. BVI Laws｜BVI Business Companies (Amendment of Schedule 1) (No. 2) Order, 2022, S.I. No. 89 of 2022 ↗
16. BVI Laws｜BVI Business Companies Act ↗

Tang Shangyong (Mr Tang)Business Manager · Professional Guidance

Proposed by Rengangyongsheng (Hong Kong) Limited / Update 2026-11-02

About the author