Bermuda · BMA · DABA · IBA · Insurance Act

Bermuda financial licences and regulator dossier

The Bermuda Monetary Authority is the integrated financial regulator for banks, deposit companies, investment businesses, funds, fund administrators, insurers, digital-asset businesses, money-service businesses, trusts and corporate-service providers. Each sector has a separate Act, licence or registration class and prudential method. A company registration or innovation-hub admission is not a substitute for the required operating permission.

Sealed licence document in an open folder before a columned building

Route facts

Jurisdiction facts

Integrated supervisor

BMA licenses and supervises the principal financial-service sectors

Digital-asset classes

DABA provides Class T testing, Class M modified and Class F full licences

Investment status

Standard or test licence, Class A registration and Class B registration have different scope

Insurance centre

Commercial, captive, special-purpose, long-term and intermediary classes use separate requirements

Fiduciary routes

Trust-business and corporate-service-provider permissions are distinct

Capital basis

Sector, class, activities and risk determine capital, solvency and liquidity

Territorial reach

A Bermuda permission covers the approved Bermuda business and creates no automatic foreign right

Review date

Regulatory position reviewed as of 11 July 2026

Regulatory perimeter

One regulator, separate statutory gateways

Bermuda's integrated regulator does not create a single financial licence. The Banks and Deposit Companies Act, Investment Business Act, Investment Funds Act, Insurance Act, Digital Asset Business Act, Digital Asset Issuance Act, Money Service Business Act, Trusts Regulation Act and Corporate Service Provider Business Act each control a different reserved perimeter. A mixed model can therefore require more than one BMA status, with separate capital, client- asset, cyber and reporting duties.

The DABA label needs particular care. Class T is a testing licence, Class M is a modified and time-limited route, and Class F is the full class for approved digital-asset activities. The licence records the actual activities, which can include issuance or redemption, digital-asset payments, exchange, trust services, custody, derivatives exchange, service vending and lending or repurchase transactions. An Innovation Hub participant outside the captured perimeter is not a DAB licensee, and a digital-asset issuance-company registration is not an exchange or custody permission.

Permission map

Bermuda licence and registration families

Permission family Regulator and instrument Activities and exclusions Eligibility, capital and control
Permission family Banking and deposit taking Regulator and instrument BMA licence under the Banks and Deposit Companies Act in the applicable bank or deposit-company category Activities and exclusions Accept deposits and provide approved banking or deposit-company services within the licence; investment, insurance and digital-asset functions may require additional status Eligibility, capital and control Bermuda vehicle or permitted branch, suitable controllers and management, real head-office direction, business viability, governance and Basel-aligned capital and liquidity
Permission family Traditional payments and money services Regulator and instrument BMA money-service-business licence for in-scope transmission, cashing, payment-instrument or foreign-exchange services; banks operate within approved banking powers Activities and exclusions Provide the licensed money service only; the status does not permit deposit taking, investment dealing or digital-asset activity by implication Eligibility, capital and control Bermuda company, fit-and-proper controllers and officers, physical presence, AML/CFT, safeguarding and operational controls, with financial resources under the current MSB rules
Permission family Digital-asset testing Regulator and instrument BMA Class T licence under the Digital Asset Business Act 2018 Activities and exclusions Conduct only the approved proof-of-concept activity, limits and customer test; Class T is not an unrestricted production permission Eligibility, capital and control Bermuda entity, credible test plan, governance, at least the responsible people expected by BMA, risk controls, customer protection, funding and an exit or progression plan
Permission family Modified digital-asset business Regulator and instrument BMA Class M licence under DABA for expanding operations during the licence period and subject to BMA conditions Activities and exclusions Carry on only the listed DAB activities and conditions; expiry, limits and progression requirements distinguish it from Class F Eligibility, capital and control Bermuda entity, controllers and management reviewed, developing governance and risk framework, cyber, custody, AML/CFT and capital proportionate to the licensed activity
Permission family Full digital-asset business Regulator and instrument BMA Class F licence under DABA for one or more approved statutory digital-asset activities Activities and exclusions Approved issuance, digital-asset payment, exchange, trust, custody, derivatives venue, vendor, lending or repurchase activity as stated on the licence Eligibility, capital and control Mature Bermuda operation, suitable controllers and board, governance, risk, cyber, client-asset, AML/CFT, audit and financial-resource evidence under DABA and applicable rules
Permission family Digital-asset issuance Regulator and instrument BMA digital-asset issuance authorisation under the Digital Asset Issuance Act for an in-scope issuance company and offer Activities and exclusions Conduct the approved digital-asset issuance and disclosure process; it does not authorise exchange, custody, payments or investment business Eligibility, capital and control Eligible Bermuda issuer, offer document, governance, technology, risks, custody and proceeds controls, responsible persons and resources appropriate to the issuance
Permission family Investment dealing, advice and management Regulator and instrument BMA standard or test licence under the Investment Business Act; Class A and Class B registered-person routes apply only where the statutory criteria are met Activities and exclusions Deal, arrange, manage, safeguard or advise only within the approved activity; registration and licensing have different eligibility and supervisory intensity Eligibility, capital and control Bermuda nexus, approved controllers and officers, conduct and conflicts framework, client-asset protection, audit and class-specific net assets, liquidity or insurance
Permission family Investment funds and fund administration Regulator and instrument BMA authorisation, registration, designation or exemption for the fund class under the Investment Funds Act; fund-administrator licensing is separate Activities and exclusions Operate, administer or service the relevant institutional, professional, private, standard or other statutory fund route; the fund status does not authorise its manager's unrelated business Eligibility, capital and control Bermuda structure and eligible service providers, offering and valuation documents, custody and audit, governance and class-specific minimum assets or continuing conditions
Permission family Insurance, reinsurance and captives Regulator and instrument BMA registration under the Insurance Act in the applicable commercial, captive, special-purpose, long-term or innovative class Activities and exclusions Underwrite only the approved class and business plan; a captive or special-purpose vehicle cannot assume unrestricted third-party risk Eligibility, capital and control Bermuda company, controllers and key functions approved, actuarial and risk capability, local principal office, solvency and liquidity under the class-specific prudential rules
Permission family Insurance management and intermediation Regulator and instrument BMA registration for insurance manager, broker, agent, marketplace provider or other intermediary category under the Insurance Act Activities and exclusions Manage or intermediate insurance within the recorded role; no underwriting authority unless the entity separately holds an insurer class Eligibility, capital and control Competent Bermuda operation, fit-and-proper owners and officers, professional indemnity where required, client-money controls, governance and current fee and reporting duties
Permission family Trust business Regulator and instrument BMA unlimited or limited trust licence under the Trusts Regulation Act 2001 Activities and exclusions Provide trust business within the class and any licence limits; an ordinary company or private arrangement does not create public trust-business permission Eligibility, capital and control Bermuda company or permitted partnership, suitable controllers and officers, resident substance, fiduciary systems, client-asset controls and class-specific capital and insurance
Permission family Corporate service providers Regulator and instrument BMA unlimited or limited corporate-service-provider licence under the Corporate Service Provider Business Act 2012 Activities and exclusions Formation, registered office, nominee and corporate administration services within the class; it does not confer trust, investment or custody powers Eligibility, capital and control Bermuda undertaking, fit-and-proper ownership and management, compliance and record systems, local presence, financial resources and professional indemnity as required
Permission family Consumer credit, mortgages, leasing, factoring and crowdfunding Regulator and instrument No single cross-sector retail-finance licence replaces the banking, money-service, investment-business and other activity-specific regimes; the exact product and funding model determine whether BMA status is required Activities and exclusions A lender may not accept deposits, transmit money, arrange or deal in investments, hold client assets or operate a securities crowdfunding venue unless the corresponding statutory permission or exemption applies Eligibility, capital and control Document the borrower, funding and investor perimeter; test consumer-protection, AML/CFT, credit, security and disclosure duties; and obtain the relevant BMA status where the model enters a regulated activity
Permission family Credit unions and pensions Regulator and instrument BMA supervises credit unions under their statute; occupational pension plans and administrators use the National Pension Scheme framework and Pension Commission oversight Activities and exclusions Member-focused cooperative finance or pension administration only within the relevant approval; neither status is a commercial bank licence Eligibility, capital and control Eligible local structure, governance and responsible people, member or beneficiary protections, funding, audit and prudential or plan requirements set by the competent authority
Permission family Gambling and gaming Regulator and instrument Separate approval under Bermuda gaming legislation and the competent gaming authority, outside BMA financial licensing Activities and exclusions Only the approved gaming activity; a BMA financial or digital-asset permission does not authorise gambling Eligibility, capital and control Local eligibility, ownership suitability, technical and responsible-gaming controls, AML/CFT and financial resources under the live gaming framework

Entry file

Minimum criteria, substance and financial resources

Each BMA Act contains minimum licensing criteria, but the recurring questions are consistent: who owns and controls the applicant, whether controllers and senior people are fit and proper, whether the business will be conducted prudently, and whether governance, risk management, systems, records and group supervision are adequate. Applicants should expect a Bermuda nexus, suitably experienced directors and executives, a clear delegation matrix and evidence that outsourced functions remain under board control. Digital-asset files add technology, cyber, custody, transaction-monitoring and token or protocol analysis.

Financial resources are class-specific. Banks use prudential capital and liquidity; investment businesses use licence-class net-asset and liquidity rules; funds use their classification and provider requirements; insurers use the Insurance Act class and enhanced capital calculations; DAB applicants use proportional resources and the applicable accounts rules; trust and CSP applicants use their own capital and professional-indemnity framework. Client money, custody assets, insurance reserves and digital assets are not interchangeable safeguarding pools. The current BMA legislation, rules and fee schedules must be used for the final calculation.

Application process

From BMA perimeter to activation

  • 1. Fix the Act, class and activities

    Map every service to the controlling Act, identify exemptions or registered-person routes, and record the exact activities requested.

  • 2. Engage and document the ownership case

    Prepare beneficial ownership, controllers, source of funds, group structure, directors, executives and Bermuda substance before filing.

  • 3. Build the class-specific dossier

    Add business plan, governance, financial-resource method, AML/CFT, cyber, client assets, outsourcing, audit, recovery and wind-down evidence.

  • 4. Submit the official application

    Use the current BMA form, supporting schedules and charge, then answer questions and proposed conditions without assuming a favourable outcome.

  • 5. Complete operational readiness

    Fund required resources, appoint accepted people, implement returns and controls, and launch only after the final licence or registration is effective.

Continuing supervision

Returns, material changes and acquisitions

BMA-supervised entities maintain prudential resources, audited accounts, statutory or regulatory returns, AML/CFT and sanctions controls, governance, conduct, cybersecurity, incident response, outsourcing oversight and client-asset records appropriate to the sector. Material changes to activities, business plan, custody arrangements or technology can require prior approval or notification. Class T and Class M DAB businesses must also observe the limits, milestones and expiry recorded for the test or modified phase.

Direct or indirect changes in control, qualifying ownership, controllers and senior management follow the relevant BMA approval or notification route. An acquisition leaves the statutory permission with the licensed undertaking but exposes the incoming owner to fitness, financial- soundness and group-supervision review. Due diligence should reconcile the public register, licence activities, conditions, prudential filings, client assets, cyber incidents and open remediation. Bermuda continues to update digital-asset, insurance and investment rules, so the live position must be checked at signing and completion.

Verify it yourself

Primary sources

  • Bermuda Monetary Authority regulated sectors

    BMA's official sector pages and regulated-entities register identify every licence or registration class and current holder.

  • Digital Asset Business material

    DABA, the Class T, M and F forms, guidance, custody rules and accounts rules control digital-asset applications and supervision.

  • Investment, funds and insurance legislation

    BMA's official document centre contains the Investment Business Act, Investment Funds Act, Insurance Act and current prudential rules.

  • Trust, CSP and money-service legislation

    Official BMA Acts, codes, forms and fee instruments govern fiduciary, corporate and money-service providers.

FAQ

Bermuda licensing questions

01 Is Class M a full DAB licence?

No. Class M is a modified, time-limited class with activities and conditions set by BMA. Class F is the full class, but it also covers only the activities recorded on the licence.

02 Does Innovation Hub participation authorise business?

No. The Hub can support models outside or approaching the regulatory perimeter. A captured business still needs the statutory licence or registration before operating.

03 Can one BMA status cover investments and digital assets?

Only if the relevant Acts and recorded activities support the whole model. Securities, derivatives, custody and DAB functions can require cumulative permissions.

04 What capital is required?

The answer depends on sector, licence class, activities and risk. Use the current BMA prudential rules and calculation for the exact applicant.

05 What happens on a share acquisition?

The licensed entity retains its permission, while the incoming controller and relevant managers complete BMA review and inherit the entity's regulatory history and conditions.

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Scope the Bermuda permission family

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