The Cayman Islands has enacted the Beneficial Ownership Transparency (Amendment) (No. 2) Act, 2025 (the Amendment Act), further enhancing the jurisdiction’s beneficial ownership framework. 

The amendments introduce additional disclosure requirements, clarify compliance and enforcement processes, expand information‑sharing powers and refine the administrative fines regime. The seven key developments in the Amendment Act and their practical implications for in‑scope entities are discussed below along with a summary of the Cayman Islands government’s position regarding access to Beneficial Ownership Registers in the jurisdiction.

• 1. Listed Entity Exemption – Subsidiaries

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  The Amendment Act clarifies the operation of the listed entity exemption:

  • The exemption now expressly applies to legal persons, not only companies.
  • Where a legal person is a subsidiary of a listed entity, the beneficial ownership register must include:
    • The name and jurisdiction of the relevant stock exchange; and
    • The name of the listed parent entity.

  Entities relying on the listed entity exemption, particularly subsidiary structures, should ensure their beneficial ownership filings include the additional parent‑level information.

• 2. Expanded Beneficial Ownership Particulars

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  The required particulars for registrable beneficial owners have been expanded to include the nature in which an individual owns or exercises control over the legal person. Beneficial ownership registers should be reviewed to ensure that descriptions of ownership and control are sufficiently clear and compliant with the revised requirements.

• 3. Accuracy and Currency of Beneficial Ownership Registers

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  The statutory duty to establish, maintain and deposit a beneficial ownership register has been strengthened. Registers must now expressly contain adequate, accurate and current information.

  A clarification has also been introduced where a legal person has already been informed of a relevant change and has received the required particulars, it is not required to issue a further confirmation notice to the beneficial owner. While ongoing monitoring remains essential, the amendment reduces unnecessary duplication where updates are already known and documented.

• 4. Restrictions Notices – Enhanced Enforcement

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  The Amendment Act expands and clarifies the circumstances in which a restrictions notice must be issued by a corporate services provider, including where:

  • A legal person fails to justify or correct inaccurate information within 30 days of notice; or
  • A notice has been properly served on a beneficial owner and no response is received.

  Additional points include:

  • A copy of any restrictions notice must be provided to the competent authority within 14 days of issue.
  • Restrictions will not take effect where the relevant interest is subject to a pre‑existing security interest granted to an unaffiliated third party.

  Failure to respond to beneficial ownership notices may result in statutory restrictions affecting share transfers, voting rights and distributions.

• 5. Expanded Access and Information Sharing

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  The competent authority’s powers to disclose beneficial ownership information have been broadened. Information may now be shared with:

  • Foreign beneficial ownership authorities;
  • Foreign AML/CFT authorities; and
  • Governments or public authorities where information is sought in connection with a potential or actual business relationship or transaction.

  Registrable beneficial owners may also be provided with access to their own information on the search platform. Clients should be aware of the increased potential for cross‑border regulatory cooperation and information exchange.

• 6. Administrative Fines – Clarification of Maximum Penalties

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  The administrative fines regime has been clarified as follows:

  • CI$5,000 maximum fine for an initial prescribed breach.
  • CI$1,000 per month for continuing breaches, capped at CI$25,000 in total.
  • The Registrar must take into account prescribed rules, including aggravating and mitigating factors, when determining the final amount of any fine.

  The clarification provides greater certainty but underscores the importance of timely compliance and remediation.

• 7. Legitimate Interest

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  The Cayman Islands Government has reaffirmed that access to beneficial ownership information will continue to be provided on a legitimate interest basis, reflecting a balanced approach that supports transparency, international cooperation, and the protection of individual rights, and is consistent with the absence of any global standard requiring fully public registers. 

  In addition, on 18^th March 2026, the Cayman Islands Government issued the Beneficial Ownership Transparency (Legitimate Interest Access) (Amendment) Regulations, 2026, which amend the fee structure relating to applications for access to beneficial ownership information from US$30 to US$75 and introduce a new US$250 annual administrative fee for applicants seeking to make multiple access applications within a 12‑month period across any number of legal persons.

Next steps for clients:

There are a number of steps that can be taken if you are impacted by the new regulations:

• Review reliance on the listed entity exemption, particularly for subsidiary structures;
• Ensure beneficial ownership registers clearly describe the nature of ownership or control;
• Confirm procedures are in place to maintain accurate and current beneficial ownership information;