Beneficial Ownership Transparency Act (2026 Revision)

Status per the Cayman Islands legislation register (legislation.gov.ky) (as at 2026-07-09)

Summary

This is the consolidated and revised text (2026 Revision) of the Cayman Islands' Beneficial Ownership Transparency Act, which merges the original 2023 Act with amendments made in 2025. It sets out the framework requiring in-scope Cayman Islands legal persons to identify their beneficial owners, disclose that information to a corporate services provider, and have it recorded on a beneficial ownership register. That register is accessible to competent authorities, the Registrar, and certain law enforcement bodies, including via information-sharing agreements with listed countries, currently only the United Kingdom.

Legal persons covered: Companies, limited liability companies, limited liability partnerships, limited partnerships, exempted limited partnerships and foundation companies (collectively 'legal persons').
Corporate services providers covered: Persons providing registered office services, or the ordinary resident company itself where no such provider is engaged.

Beneficial owner definition: A 25% ownership/control threshold or ultimate effective control.
Identification rules: Sets rules for identifying 'registrable beneficial owners' and 'reportable legal entities'.
Core duties: Imposes notice, disclosure and record-keeping duties.
Non-compliance consequences: Can trigger a restrictions notice restraining dealings with relevant interests, and separately expose parties to administrative fines or criminal penalties.
Rule-making powers: Empowers the competent authority (the Minister) and the Registrar to issue guidance and rules, and allows Cabinet to make regulations, including transitional provisions.

Because the register regime commenced from 31 July 2024 (carrying over exemptions and definitions from predecessor legislation up to that date), the substantive obligations described are already in force under this consolidated revision. The document itself is a revision/consolidation rather than a new standalone enactment, so it does not create new deadlines beyond those already operative under the Act's ongoing notice and register-maintenance provisions.

Key obligations

Legal persons falling under section 12(1)(a)-(d) must provide written confirmation of their category and required particulars to their corporate services provider.
Legal persons under section 12(1)(e) must identify every individual beneficial owner, every reportable legal entity, and relevant trustees/contact persons, and provide the required particulars in writing to their corporate services provider.
A legal person under section 12(1)(e) must inform its corporate services provider in writing as soon as required particulars have been confirmed.
Legal persons must give written notice to identified and suspected beneficial owners, reportable legal entities, and persons holding a relevant interest, requiring a response within thirty days of receipt confirming, correcting, or supplying required particulars.
Corporate services providers must review the particulars supplied to them.
Legal persons must establish and maintain a beneficial ownership register, keep it current, and notify relevant changes to it.
A corporate services provider may issue a restrictions notice where beneficial ownership is not disclosed, restricting dealings with the relevant interest, subject to rights of application to the Grand Court.
Persons must comply with requests for information from the competent authority or the Registrar, and corporate services providers must forward correspondence as required.
Failure to comply with obligations under the Act may result in administrative fines or criminal penalties.

Applies to

companies, limited liability companies, limited liability partnerships, limited partnerships, exempted limited partnerships, foundation companies, corporate services providers, licensed financial institutions, registrable beneficial owners

Deadlines

30 days after receipt of notice: A person given notice under section 8 must state whether they are a registrable beneficial owner and confirm, correct, or supply required particulars within thirty days of receiving the notice.
31st July, 2024: Transitional date up to which pre-existing definitions of 'beneficial owner' and exemptions under the superseded Companies Act, Limited Liability Companies Act, and Limited Liability Partnership Act (2023 Revisions) continued to apply, immediately preceding commencement of section 4 and sections 12(1)-(3) of the original 2023 Act.

Beneficial Ownership Transparency Act (2026 Revision)

Summary

Key obligations

Applies to

Deadlines

Related documents

Topics

Version history

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