AIIM | 22 Sep 2026 Back
The regulatory landscape in Barbados continues to evolve with the implementation of the Beneficial Ownership Transparency and Register Act, 2026 (BOTR Act). The legislation introduces enhanced requirements for legal entities to identify, verify, maintain, and report information relating to the individuals who ultimately own or control them.
For captive insurers, these requirements represent an important governance and compliance priority. Captive owners and boards should ensure that ownership structures are fully documented, shareholder information remains accurate, and procedures are in place to identify and report changes in ownership or control on a timely basis.
Why It Matters
Beneficial ownership transparency requirements are intended to enable competent authorities to identify the natural persons who ultimately own or control legal entities. Maintaining accurate ownership records supports regulatory compliance, strengthens governance frameworks, and reinforces confidence in Barbados as a well-regulated international financial centre.
Actions for Captive Owners and Directors
Captive boards should consider:
- Reviewing current ownership and control structures.
- Confirming the accuracy of shareholder and beneficial ownership records.
- Reviewing governance and company secretarial procedures relating to ownership changes.
- Ensuring directors understand their reporting obligations.
- Maintaining supporting documentation and due diligence records.
Operational Impact
Captives with multinational ownership arrangements, trusts, foundations, holding company structures, or complex ownership chains may experience increased compliance and documentation requirements. AIIM is conducting ownership verification reviews and working with clients to ensure readiness for implementation.
AIIM Perspective
While the new requirements introduce additional compliance obligations, they also provide an opportunity for captive owners to strengthen governance, improve documentation standards, and enhance transparency across their organizations. AIIM will continue to support clients through the implementation process and provide guidance on emerging regulatory developments.