FSC launches a Register of Trusts: existing trusts must be loaded by 15 January 2027

The Financial Services Commission (FSC) of Mauritius launched its Register of Trusts on 30 September 2026. Its communiqué of that date, "Launch of the Register of trusts", requires every Qualified Trustee to submit, through an online platform, basic and beneficial ownership information on the trusts it administers, and to finish the initial population of the Register by 15 January 2027. The communiqué is addressed to holders of an FS-3.1A Management Licence, holders of an FS-3.1B Management Licence (Qualified or Corporate Trustee only) and holders of a TAC-1.1 Qualified Trustee (other than a Management Company) Authorisation.

What the rules say

The FSC rests the Register on four legal bases: the Anti-Money Laundering, Combatting the Financing of Terrorism and Countering Proliferation Financing (Miscellaneous Provisions) Act 2026, the Economic and Financial Measures (Miscellaneous Provisions) Act 2026, section 26A of the Financial Services Act 2007 as amended, and section 38 of the Trusts Act 2001 as amended. In its own description the Register is a national initiative to strengthen transparency and the beneficial ownership framework for trusts, so that competent authorities have timely access to accurate information on legal arrangements.

Section 38(3A) of the Trusts Act holds the obligation itself. The FSC's consolidated text shows it as inserted by Act 3 of 2026 with effect from 18 April 2026, and it requires a trustee to keep an accurate and updated register of all trusts under its trusteeship, foreign trusts included. That register must cover, among other things:

• basic information identifying the trust, and its type and formation date;
• the original trust deed, governing documents and all amendments;
• names and current and past addresses of beneficiaries, classes of beneficiaries and objects of a power, trustees, and any other natural person exercising ultimate effective control;
• settlors, protectors and enforcers;
• the object and proper law of the trust and where it is administered;
• regulated agents and service providers such as accountants, tax advisers, lawyers, bankers and investment managers.

The Qualified Trustee must notify the Commission of that information, and of any change to it, forthwith, and in any case no later than five working days after the information is obtained or the change occurs.

The mechanics are in the FSC's Register of Trusts User Guide, published alongside the launch. Access is through the portal at ors.fscmauritius.org. A Qualified Trustee registers by writing to trustregister@fscmauritius.org, nominating a Platform Administrator and two further officers, and signing the Terms and Conditions. Records can be entered one at a time or uploaded in bulk on the FSC's template. Where relevant, trustees must supply trust deeds, bank account details and signatories, together with details of trustees, settlors, protectors, beneficiaries, other controlling persons and service providers, including the ultimate beneficial owners of any legal persons among them. Charitable trusts are to be submitted at launch and then every year.

Who is affected

Management companies acting as trustees, and other Qualified Trustees, carry the obligation directly. Under section 2 of the Trusts Act, a qualified trustee is a management company or another Mauritius resident authorised by the FSC to provide trusteeship services, and the duty reaches foreign trusts under their trusteeship as well as Mauritius trusts. Settlors, protectors and beneficiaries will feel it at one remove, as requests for identification documents and updated addresses.

The Register is not public. According to the User Guide, each Qualified Trustee can see only the trusts it administers.

Key dates

• 18 April 2026: section 38(3A) of the Trusts Act in force, according to the FSC's consolidated text.
• 30 September 2026: Register launched.
• 15 January 2027: initial population of all existing trusts due.
• Thereafter: changes within five working days.

What it means in practice

For a trustee with a large book, three and a half months is not long. Many files will need refreshed addresses, missing amendments to deeds or ownership details for corporate beneficiaries, and the portal will not accept a record until every required field is complete. The User Guide treats incorrectly completed information as a breach that may lead to sanctions, and the communiqué warns that a missed deadline may result in supervisory follow-up and regulatory action.

What we do not yet know

The communiqué does not set out specific penalties. We have not been able to review the amended text of section 26A of the Financial Services Act, because the consolidated version on the FSC website predates the amendment. The FSC refers trustees to FAQs on its website, which we have not reviewed. Neither the communiqué nor the User Guide says how trusts created after launch are to be registered, beyond the five-day rule for changes.