Bermuda's captive insurance sector faces new regulatory requirements as the Beneficial Ownership Act 2025 narrows exemptions that previously excluded regulated insurance companies from beneficial ownership reporting. The legislation, which received Royal Assent on 28 September 2025, takes effect on 3 November 2025. The change brings many captive entities under the beneficial ownership regime for the first time, though the Minister of Finance may exempt certain entities by Order in the future. Under the Act, exemptions now apply only to entities listed on a recognised stock exchange and subsidiaries of such listed companies. Previously, regulated insurance companies, including captives, were exempt. Key Changes for Captive Entities The Act introduces several compliance obligations for captive insurers:
- Lower threshold: The definition of a beneficial owner changes from "more than 25%" to "25% or more" of shares or interest, expanding the pool of individuals who must be identified and declared.
- Approval requirement: Beneficial owners must now be approved by the Registrar of Companies (RoC). Existing beneficial owners already approved before 3 November 2025 do not require re-approval.
- Expanded data collection: Entities must collect date of birth, nationalities, and details from an unexpired government-issued identity document, including identification number, country of issue, and issue and expiry dates.