Stakeholder Letter - Consultation Paper - Corporate Service Provider (CSP) Business Rules 2025 (2025-10-16)

Summary

This is a stakeholder letter from the Bermuda Monetary Authority (BMA) responding to industry feedback received during the consultation on the new Corporate Service Provider (CSP) Business Rules 2025. It does not itself impose new rules but clarifies how the BMA will address several issues raised by stakeholders and previews what will follow before the revised regime takes effect.

• Reporting forms: Financial reporting forms will not contain requirements beyond what was already outlined in the consultation papers or discussed in outreach meetings, and will be published on the BMA website before implementation.
• Consolidated reporting: Entities that are part of a group or hold multiple licences may submit consolidated reporting, but only if the parent company is also regulated by the BMA under the Banks and Deposit Companies Act 1999, Investment Business Act 2003, Trusts (Regulation of Trust Business) Act 2001, Fund Administration Provider Business Act 2019, and/or Corporate Service Provider Business Act 2012.
• CSP licensing scope: There will be no change to the current scope of licensable CSP activities; any business or individual carrying out one or more licensable CSP activity must hold a valid CSP licence unless exempted.
• Further guidance: A guidance document clarifying calculation of minimum net assets and the definition of Client Money will be issued before the revised regime is implemented.

The letter confirms that supplementary materials, including the reporting forms and the guidance document, will be published on the BMA website ahead of implementation, but no specific implementation date or filing deadline is given in this letter.

Key obligations

• Any business or individual undertaking one or more licensable CSP activity must hold a valid CSP licence, unless otherwise exempted.
• Consolidated reporting by group entities or multi-licence holders is permitted only where the parent company is also regulated by the BMA under one of the specified Acts.

Applies to

Corporate Service Providers (CSPs), entities holding multiple licences or forming part of a regulated group, banks and deposit companies, investment business licensees, trust businesses, fund administration providers