Beneficial Ownership

Beneficial Ownership Act 2017

The Beneficial Ownership Act 2017 (the 'Act') specifies the requirements for identifying, verifying and recording the beneficial ownership of legal entities to which the Act applies. Registrable beneficial ownership information is submitted electronically to the Isle of Man Database of Beneficial Ownership (the 'Database').

This page provides general information only. The Act and applicable secondary legislation should be consulted when determining legal obligations. The Isle of Man Financial Services Authority ('IOMFSA') Guidance should also be considered, and independent legal advice should be obtained where necessary.

2026 Update – Registrable Beneficial Ownership and Senior Managing Officials

The definition of Registrable Beneficial Owner ('RBO') was amended in 2026 by the Beneficial Ownership Act 2017 (Amendment) Order 2026. The registrable threshold for ownership or control including through shares or voting rights is now 25% or more. The updated framework also makes clear that no percentage threshold applies where a natural person exercises, or is entitled to exercise, control over a legal entity via other means.

Where, after taking all reasonable steps, the nominated officer determines that no natural person meets either test, the nominated officer must make a declaration of no registrable beneficial owner to the Database and submit information about the legal entity’s Senior Managing Official ('SMO'). The SMO was introduced in 2026 by the Beneficial Ownership Information Regulations 2026. An SMO is not a beneficial owner nor a registrable beneficial owner.

Isle of Man Financial Services Authority (IOMFSA) Beneficial Ownership Guidance

The IOMFSA has issued updated Beneficial Ownership Act 2017 Guidance (April 2026). The Guidance explains the amended definition of registrable beneficial ownership, the treatment of control via other means, the requirements relating to SMO’s and provides some practical examples for different legal entity structures.

The nominated officer

Every legal entity to which the Act applies must have a nominated officer, unless exempt from this requirement pursuant to an Order, made by Treasury, under section 6(5) of the Act.

A nominated officer must be either:

A natural person who is resident in the Isle of Man; or
The holder of a licence issued under section 7 of the Financial Services Act 2008 that permits the holder to carry on the regulated activity of providing corporate services
Any appointment, subsequent to the appointment of the first nominated officer, change to, or change in the particulars of a nominated officer must be notified to Companies Registry as soon as reasonably practicable and, in any event, within 21 days, using Form NO/CSP

The role of the nominated officer

Beneficial Ownership Information

The role of the nominated officer is to ensure that beneficial ownership information (referred to in the Act as the 'required details') and documentation verifying that information is maintained in the Island (or on a server that is permanently accessible from the Island) and is capable of being disclosed at any time.

The required details, specified under section 11 of the Act, are as follows:

The person’s name
Their usual residential address
A service address, where different from the residential address
Their nationality
Their date of birth
The date on which the interest in the legal entity was acquired; and
The nature and extent of the interest in the legal entity

Legal owners, beneficial and intermediate owners also have responsibilities under the Act to help ensure that the nominated officer can meet its statutory obligations. Legal owners are required to identify the beneficial owners of the interests they hold and provide the nominated officer with those required details (including any subsequent changes), verified by a reliable and independent.

Likewise, beneficial owners and intermediate owners (see section 10 of the Act) must assist legal owners and, upon request, nominated officers, in ascertaining beneficial ownership and must notify the legal owner of any relevant change. Failure to comply with these obligations may constitute an offence under the Act.

Secondly, the role of the nominated officer is to take all reasonable steps necessary to ascertain whether any beneficial ownership information is registrable on the Isle of Man Database of Beneficial Ownership. This requires understanding the complete ownership and control structure, looking through any number of persons or arrangements and considering both ownership and control in every case.

The nominated officer must submit the required details of every registrable beneficial owner to the Database. Where no registrable beneficial owner exists, the nominated officer must submit the required confirmation and SMO information.

Before committing the required details of the RBO’s or the information for an SMO to the Database, the nominated officer must have verified the information and be satisfied that it is correct. Further detail is provided below.

Legal owners and beneficial owners

A legal owner of a legal entity is the person who is recorded as directly owning or controlling shares, voting rights or another equivalent ownership interest in a legal entity. The legal owner may be a natural person or a legal person. In some cases, the legal owner holds the interest for another person, for example as a nominee or trustee.

A beneficial owner must be a natural person. Under the Act, a beneficial owner is a natural person who ultimately owns or controls a legal entity, in whole or in part, through direct or indirect ownership or control of shares, voting rights or another ownership interest, or who exercises control via other means.

The definition of beneficial ownership is intentionally broad. All beneficial owners must be identified and their interests verified, including beneficial owners whose interests are below the registrable threshold (see below). Only the required details of RBO’s are required to be submitted to the Database, unless information is submitted voluntarily in accordance with the Act. Where there is no RBO, the required confirmation and SMO information must be submitted instead.

How registrable beneficial ownership is determined

The following three-tier framework provides a practical way to assess and report registrable beneficial ownership. Tier 1 and Tier 2 must both be considered in every case. Tier 3 applies only where neither Tier 1 nor Tier 2 identifies an RBO.

Tier 1 – Ownership or control including through shares or voting rights

25% or more.

A registrable beneficial owner is any natural person who ultimately owns or controls 25% or more of the legal entity including through direct or indirect ownership of shares or voting rights.

The assessment must look through corporate shareholders, nominees and other intermediate layers until the relevant natural person or persons are identified
Joint, several and aggregated interests must be considered, as must the rights attached to different classes of shares
Where ownership and voting rights are different, separate entries may be required on the Database

The percentage threshold applies to ownership and control through shares or voting rights.

Tier 2 – Control via other means

No percentage threshold.

A natural person is also a registrable beneficial owner where that person exercises, or is entitled to exercise, control over the legal entity via other means, whether directly or indirectly.

Control via other means includes any ability, whether formal or informal and whether legally enforceable or not, to direct, determine, influence or veto a decision relating to the management, activities, assets, governance, beneficiaries, distributions or other affairs of the legal entity
Control may arise through a trust or an equivalent legal arrangement, an entity's constitutional documents, contractual or informal arrangements, the ability to appoint or remove decision-makers, de facto influence or another source of ultimate effective control
No percentage of interest applies to an RBO identified under Tier 2

Tier 2 is intentionally broad, and full consideration must be given establish whether there is an RBO.

Tier 3 – No registrable beneficial owner: Senior Managing Official

Reporting outcome only – the SMO is not a beneficial owner.

Tier 3 applies only where the nominated officer has taken all reasonable steps and has determined that no natural person is registrable under Tier 1 and no natural person exercises, or is entitled to exercise, control via other means under Tier 2.

The nominated officer must first make the statement of confirmation that the legal entity has no registrable beneficial owner to the Database
The nominated officer must then submit to the Database the required information about the person or persons occupying the position of Senior Managing Official
No percentage of interest applies to an SMO entry

The absence of a registrable beneficial owner should be an exceptional conclusion and must be supported by a full, documented assessment.

Control through trusts and other legal arrangements

Where ownership or control is exercised through a trust or other legal arrangement, the registrable beneficial owner is the natural person who ultimately exercises the ownership or control, not the legal arrangement itself or a legal person acting in a nominee, representative or fiduciary capacity. The nominated officer must consider whether any natural person has ultimate effective control over that arrangement and, through it, over the underlying legal entity. The existence of a right may be sufficient even if the right has not been exercised.

Depending on the facts and the powers granted, relevant rights may include:

The right to appoint or remove a trustee, other than through a court application or solely as a consequence of a breach of fiduciary duty
The right to direct or veto the distribution of funds or assets
The right to direct or veto investment decisions
The right to amend the trust deed; or
The right to revoke the trust

The assessment is fact specific. A settler, protector, enforcer, trustee or another natural person may be an RBO where the powers held amount to ultimate effective control. The IOMFSA Guidance should be consulted for detailed examples.

Senior Managing Official

An SMO should be identified only after the nominated officer has fully considered and documented both ownership and control, including through shares or voting rights under Tier 1 and control via other means under Tier 2.

After concluding that no registrable beneficial owner exists, the nominated officer must make the statements of confirmation required by the Beneficial Ownership Information Regulations 2026. This includes confirmation that:

The person making the statement is the nominated officer of the legal entity
The nominated officer has taken all reasonable steps necessary to ascertain whether the legal entity has one or more registrable beneficial owners
The nominated officer has complied with the regulations made under section 20 of the Act; and
Notices have or have not been issued under sections 9(2) or 10(2) of the Act, as applicable

The SMO

The identity of the SMO depends on the circumstances of the legal entity. It will be the natural person who exercises strategic decision-making powers in respect of the entity. It would not normally be a person without executive functions, such as a non-executive director.

Where more than one official has strategic decision-making powers and none is more senior than the others, each of those persons should be treated as an SMO for the purposes of the Act.

The SMO is not an RBO.

Information to be submitted for an SMO

The information to be submitted to the Database for an SMO, as introduced by the Beneficial Ownership Information Regulations 2026 is the same as the required details for a beneficial owner, namely:

The individual’s name
Usual residential address
Service address, where different from the residential address
Nationality
Date of birth
The date on which the individual became an SMO of the legal entity and
A description of the source or nature of the individual’s executive control over the legal entity

No percentage of interest is applicable to an SMO.

Supporting information

Where an SMO is submitted, Companies Registry, pursuant to its statutory powers under section 25 of the Act, may request an up-to-date structure chart showing the current ownership and control arrangements of the legal entity, together with any supporting explanation or documentation relied upon. This information assists the Registry in verifying the structure and confirming that the Database entry is accurate, adequate and up to date.

The SMO will also be subject to the same identity verification checks as applied to an RBO.

How RBO information is to be submitted

Registrable beneficial ownership information, statements confirming that there is no registrable beneficial owner, and SMO information must be submitted electronically by the nominated officer through the Isle of Man Government’s Online Services website and recorded on the Database, unless a statutory exemption applies.

How the nominated officer accesses the Isle of Man Database of Beneficial Ownership

The Database is accessed through Online Services on gov.im. Companies Registry will issue an enrolment code by post to the nominated officer for each legal entity for which the nominated officer is appointed. The code enables the nominated officer to link the entity to their Online Services account. CSPs are issued with a single activation code.

When the information has to be submitted

Legal owners must provide the nominated officer with the required details and verification information as soon as reasonably practicable but in any event within 21 days of incorporation and within as soon as reasonably practicable but in any event within 21 days of receiving a written notice from the nominated officer. A legal owner must also notify the nominated officer of a relevant change as soon as reasonably practicable but in any event within 21 days of becoming aware of the change or first having reasonable cause to believe that the change has occurred.

The nominated officer must submit the required details of all RBO’s, and information concerning changes to those details, to the Database as soon as reasonably practicable but in any event within 21 days of the relevant information being notified under the Act. Where no registrable beneficial owner exists, the nominated officer must submit the prescribed statement and the required SMO information in accordance with the Act and the Beneficial Ownership Information Regulations 2026.

Each time information is submitted or updated, the nominated officer must confirm that it is a true record of the information provided to them in that capacity.

Annual confirmation (Statement of Compliance)

The legal entity and the nominated officer must each submit an annual statement confirming compliance with their respective obligations under the Act. The statements must be made by the date on which the legal entity is due to submit its annual return.

The nominated officer’s statement is made through the Database. The legal entity’s statement is included in its annual return. Before submitting the annual statement, the nominated officer should take proactive steps to confirm that the beneficial ownership information held and recorded is accurate, current and complete.

Oversight

The IOMFSA is responsible for oversight of compliance with the Act, including the obligations of nominated officers and CSPs. Failure to comply with the Act may constitute a criminal offence.

The Guidance issued by the IOMFSA is available online.

Enquiries in relation to the Guidance or compliance with the Beneficial Ownership Act 2017 may be directed to beneficial.ownership@iomfsa.im

Who can access the Database

Obliged Entity Access

Since 31 December 2024, Obliged Entities have been able to request access to the Database.

For this purpose, an Obliged Entity is a legal entity that carries on business or activity to which:

The Anti-Money Laundering and Countering the Financing of Terrorism Code 2019 applies in accordance with paragraph 2(6) to (10) of Schedule 4 (regulated sector and supervisory authorities) to the Proceeds of Crime Act 2008; or
The Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Code 2019 applies in accordance with paragraph 2(11) of Schedule 4 to the Proceeds of Crime Act 2008

Access to the Database is permitted to an Obliged Entity only for the purpose of:

Carrying out its functions under Part 4 (customer due diligence and ongoing monitoring) of the Anti-Money Laundering and Countering the Financing of Terrorism Code 2019, as amended or replaced from time to time; or
Carrying out its functions under Part 4 (customer due diligence) of the Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Code 2019, as amended or replaced from time to time

For further information, including how to register, please see the Practice Note – Obliged Entity Access.

Information for International Law Enforcement

If you are an international law enforcement agency or a similar competent authority, please use the information below to make enquiries of the Isle of Man in relation to the beneficial ownership of companies or information relating to roles in legal arrangements, including trusts.

International Requests for Beneficial Ownership Information

The Isle of Man Financial Intelligence Unit (FIU) is the central authority for coordinating international requests for beneficial ownership information.

UK Requests

The Isle of Man and United Kingdom Governments have entered into an Exchange of Notes for the exchange of beneficial ownership information. In accordance with the technical protocol, UK agencies should contact their designated point of contact, which at the time of writing is the UK Financial Intelligence Unit (UKFIU), to obtain the relevant forms and process for submitting a request.

All Other Jurisdictions

Agencies seeking information in relation to legal persons on the Isle of Man registers should use their Egmont membership to contact the Isle of Man FIU through an Egmont request for intelligence. Where formal evidence or compulsory measures are required, the intelligence may inform a mutual legal assistance request through the Attorney General’s Chambers.

Further information is available on the Mutual Legal Assistance page.

Legal Arrangement / Trust Information

Where an investigation identifies an Isle of Man-based legal arrangement or trust, the requesting agency should use its Egmont membership to contact the Isle of Man FIU through an Egmont request for intelligence. Where formal evidence or compulsory measures are required, the intelligence may inform a formal mutual legal assistance request through the Attorney General’s Chambers.

Further information is available on the Mutual Legal Assistance page.

Financial Intelligence Unit

For urgent matters, please telephone the FIU at the same time as submitting an electronic request so that appropriate resources can be allocated promptly.

Financial Intelligence Unit
Douglas
Isle of Man
IM1 3DF

Telephone: +44 1624 686000
Email: fiu@gov.im
Egmont Secure Web: fiu.iom@egmont.org

Further information

For further information, please email BOAEnquiries.DFE@gov.im. The Companies Registry team will respond by email as soon as possible but cannot provide legal advice. Where legal advice is required, an Isle of Man Advocate should be consulted.

Copies of Acts of Tynwald can be found on the Isle of Man Legislation website, administered by HM Attorney General’s Chambers.