Disclosable beneficial ownership information feedback paper (2025-10)

Summary

This is a feedback paper from the JFSC Registry summarising responses to its May 2025 consultation on disclosable beneficial ownership information, and setting out the Registry's response and next steps. It does not itself impose new rules; rather it confirms that proposed changes have been paused pending further work with industry.

Nineteen respondents (trust company businesses, trade bodies, banks, a virtual asset service provider, other regulated financial services businesses, designated non-financial businesses and professions, and a non-profit) commented on proposed thresholds, categories of beneficial ownership and control, whether direct/indirect ownership should be flagged, and implementation timeframes.

• Thresholds: Industry queried the proposed four bands (below 25 percent, 25-50 percent, over 50-75 percent, over 75 percent) and whether a sub-25 percent band changed existing risk-based reporting expectations; Registry confirmed no change to existing 10 percent/25 percent guidance and will workshop the thresholds with industry.
• Categories: Respondents wanted a category for controllers who are not beneficial owners and closer alignment with the AML/CFT/CPF Handbook three-tier test; Registry agreed to consider additional categories and produce guidance.
• Direct/indirect ownership flag: Most respondents agreed no specific indication of direct versus indirect ownership is needed, though some raised concerns for complex structures; Registry will consider guidance.
• Implementation timeframe: Most respondents said the proposed 1 January 2026 deadline (for existing entities via annual confirmation, and for new entities on establishment) did not give sufficient time; several suggested 1 January 2027 or a 6-12 month lead time after requirements and API schema are finalised.
• Listed company exemption: Registry confirmed the existing exemption from beneficial ownership reporting for listed companies remains unaffected by these proposals.

As a direct result of this feedback, the Registry has decided not to introduce the additional beneficial ownership data fields in the 2026 annual confirmation period. Further engagement and refinement of the categories and thresholds will continue over the coming months, so no new disclosure obligations currently apply from this document.

Applies to

trust company businesses, trust company service providers, fund services businesses, banks, virtual asset service providers, other regulated financial services businesses, designated non-financial businesses and professions, non-profit organisations, companies, foundations, incorporated limited partnerships, limited liability companies, limited liability partnerships, separate limited partnerships

Deadlines

• 1 January 2026: Originally proposed date for requiring the additional beneficial ownership data (thresholds/categories) in annual confirmations for existing entities and on establishment for new entities; the Registry has now confirmed this will not proceed in the 2026 annual confirmation period.
• 1 January 2027: Alternative implementation date suggested by three respondents as an alternative to the original 1 January 2026 proposal; not adopted or confirmed by Registry in this paper.