The Global Forum on Transparency and Exchange of Information for Tax Purposes has published its 2026 in-depth peer review report on the Seychelles, assessing how effectively the archipelago implements the international standard on exchange of information on request (EOIR). The report was approved by the Peer Review and Monitoring Group on 10 December 2025 and adopted by the Global Forum membership on 16 January 2026.
The Seychelles is a well-known international financial centre with a large offshore sector, home to over 243,000 registered international business companies (IBCs) alone. Its performance against the EOIR standard is therefore of direct practical interest to tax authorities worldwide and to practitioners advising clients with Seychelles-registered structures.
This is the third substantive assessment of the Seychelles under the Global Forum's second round of reviews. The 2020 Second Round Report and the 2023 Supplementary Report both rated the jurisdiction as overall Partially Compliant. Significant legislative and administrative reforms since 2021 prompted the Seychelles to request an in-depth review in December 2023. The result is an overall upgrade to Largely Compliant, reflecting genuine progress while identifying areas that still fall short.
Rating changes across the ten elements
The Global Forum assesses compliance against ten elements grouped under three categories: availability of information (A), access to information (B), and exchange of information (C). The table below shows how ratings have shifted across the three reports.
| Element | 2020 | 2023 | 2026 |
|---|---|---|---|
| A.1 Ownership and identity information | Partially Compliant | Partially Compliant | Largely Compliant |
| A.2 Accounting information | Non-Compliant | Partially Compliant | Partially Compliant |
| A.3 Banking information | Largely Compliant | Largely Compliant | Compliant |
| B.1 Access to information | Partially Compliant | Largely Compliant | Largely Compliant |
| B.2 Rights and safeguards | Compliant | Compliant | Compliant |
| C.1 EOIR mechanisms | Largely Compliant | Compliant | Compliant |
| C.2 Network of EOIR mechanisms | Compliant | Compliant | Compliant |
| C.3 Confidentiality | Compliant | Compliant | Compliant |
| C.4 Rights and safeguards | Compliant | Compliant | Compliant |
| C.5 Quality and timeliness of responses | Partially Compliant | Partially Compliant | Largely Compliant |
| Overall | Partially Compliant | Partially Compliant | Largely Compliant |
The two elements that moved most significantly are A.1 (ownership and identity information) and C.5 (quality and timeliness of responses). Element A.2 (accounting information) remains Partially Compliant and is the principal drag on the overall rating.
Overview of the Seychelles as a financial centre
The Seychelles is an archipelago of 115 islands in the Indian Ocean with a population of approximately 122,000. Its economy is anchored in tourism and fisheries, but its status as an international financial centre is equally prominent. The Financial Services Authority (FSA) licenses and regulates the non-banking financial sector, including 57 international corporate service providers (ICSPs), 21 trustee service providers and 20 foundation service providers. The Central Bank of Seychelles supervises seven commercial banks and 21 bureaux de change, among others. Total banking sector assets stood at approximately SCR 38.3 billion (EUR 2.9 billion) at December 2024.
The Seychelles operates a hybrid legal system, drawing on French civil law traditions for private law and British common law for criminal and commercial matters. Taxation is governed by statute on common law principles, with a territorial approach to business tax. The standard business tax rate is 15% on the first SCR 1,000,000 of taxable income and 25% on the remainder. IBCs became subject to Seychelles tax rules from 1 January 2019 to the extent they have Seychelles-source income or carry on business through a local permanent establishment.
In September 2024, the Seychelles introduced a Virtual Assets Service Providers Regulatory Framework, requiring prior licensing of wallet, exchange, broking and investment activities. The FSA will maintain a public register of licensed virtual asset service providers. The report notes that requests for information on crypto-assets were received for the first time during the review period.
Element A.1: Legal and beneficial ownership information
This element attracted the largest share of new findings and carries the most significant practical implications for offshore practitioners.
Legal ownership and nominee arrangements. The 2023 Report found that nominee shareholding arrangements covering less than 10% of a company's shares created an information gap: nominees were recorded as ordinary shareholders with no obligation to disclose their nominee status. The Seychelles has now closed this gap for IBCs. Since December 2024, the IBC Act requires that the register of members identify any member who is a nominee and record the nominator's identity. Since July 2025, nominees must submit a declaration to the IBC within 21 days of appointment confirming their status and identifying the nominator. These obligations apply regardless of the percentage of shares held. An FSA supervision round in July 2025, covering 181 IBCs across eight registered agents, found that all registers of members were up to date, though eight nominee declarations had not yet been submitted.
The gap persists, however, for protected cell companies (PCCs), companies special licensee (CSLs) and domestic companies, where the nominator's identity is only required to be recorded if the nominee arrangement covers more than 10% of shares. The Seychelles has indicated that legislative changes to the Companies Act are under consideration. Until those changes are enacted, the report recommends that the Seychelles ensure the nominator's identity is available to PCCs, CSLs and domestic companies even where the arrangement covers less than 10% of shares.
Beneficial ownership framework. The Beneficial Ownership Act 2020 (BO Act) introduced an obligation for all relevant entities and arrangements to maintain a register of beneficial owners and to populate a central beneficial ownership database (BO database) administered by the Financial Intelligence Unit (FIU). Relevant entities include IBCs, PCCs, CSLs, domestic and overseas companies, foundations, trusts, limited partnerships and general partnerships. Since August 2025, foreign partnerships carrying on business in the Seychelles are also within scope, closing the last legislative gap identified in the 2023 Report.
The definition of beneficial owner uses a cascade approach: first, natural persons with a controlling ownership interest of 10% or more; then, natural persons exercising control through other means; and, if neither category yields a result, the senior managing official. This approach is consistent with the Global Forum standard.
Registered agents and resident agents are responsible for populating the BO database within 14 days of establishing or amending a register of beneficial owners. As at June 2025, compliance among IBCs, trusts, foundations, CSLs and PCCs was broadly satisfactory. For domestic companies, however, only 2,786 of 8,274 active entities had populated the database. The FIU responded with escalating enforcement, issuing notices of non-compliance and financial penalties totalling SCR 1,488,000 (EUR 112,350) against 274 domestic companies and 113 associations in 2024, and initiating further rounds of penalties in 2025.
FSA onsite inspections of the non-domestic sector show improving compliance. By 2024, 100% of IBCs inspected held a register of beneficial owners, and 94% held a declaration of beneficial ownership information. A 2025 inspection round found that 94% of 215 entities had complied with the new obligation to conduct annual periodic reviews of beneficial ownership information.
A recurring concern is the treatment of companies that are registered but effectively inactive. Some companies remain on the Register of Companies despite repeatedly failing to file annual returns, yet have not been struck off. The ROC launched a Company Review Project in April 2025, reviewing all registered companies; as at September 2025, the striking-off process had been initiated for 76 of those reviewed. The report warns that for these inactive entities, beneficial ownership information may be outdated, since they may not be covered by Seychelles Revenue Commission (SRC) supervision and may not have complied with update obligations.
Progress on IBCs struck off and dissolved. The Seychelles has substantially tightened the regime for struck-off and dissolved IBCs. Striking-off and dissolution are now simultaneous, reducing the maximum period before potential restoration to five years. Restoration requires demonstrated compliance with all record-keeping obligations. Since 2022, 38 of 1,040 IBCs that applied for restoration were refused because they could not prove compliance. The number of struck-off but not yet dissolved IBCs fell from over 156,000 at end-2021 to just 884 at end-2024.
In EOIR practice, legal ownership information was provided in 53 of 57 requests received. The three cases treated as failures all related to IBCs struck off before the new record-keeping requirements came into force. Beneficial ownership information was provided in 48 of 57 requests. Three failures involved IBCs struck off or dormant for extended periods before the new requirements applied. This represents a dramatic improvement: the 2023 Report recorded a 26% failure rate for legal ownership information and a 35% rate for beneficial ownership information.
Element A.2: Accounting information
Element A.2 remains Partially Compliant and is the report's principal area of concern.
The legal framework is now in place. Since 2021 amendments to the IBC Act, IBCs must maintain accounting records in the Seychelles. The problem lies in practice. During the review period (2022 to 2024), the Seychelles failed to provide accounting information in a number of cases, primarily because the companies concerned were struck off before the 2021 amendments and therefore had no obligation to keep their records onshore. Inactive entities not registered with the SRC also fall outside SRC supervision and may not maintain adequate records.
FSA onsite inspections cover accounting obligations alongside ownership requirements, but not every type of entity or legal arrangement is inspected every year. The report concludes that the supervision programme has not yet demonstrated general compliance across the population. Two recommendations follow: to continue supervisory and enforcement activity; and to ensure that accounting information is available for all entities in the Register of Companies, including inactive ones.
Element A.3: Banking information
Element A.3 is upgraded to fully Compliant. The legal framework was strengthened by specifying the frequency at which banks must update beneficial ownership information for account holders. The Central Bank supervises 33 regulated entities, including seven commercial banks. The supervision programme and the quality of information provided in response to EOIR requests are assessed as meeting the standard in full.
Element B.1: Access to information
Element B.1 remains Largely Compliant. The competent authority, the International Tax Unit of the SRC, has continued to use its access powers to obtain information from registered agents, entities and other holders. Where information holders refused to cooperate, the Seychelles initiated criminal prosecution proceedings.
In August 2025, the Seychelles introduced administrative penalties that the tax administration can impose directly on information holders who fail to produce requested material. This is a significant strengthening of the access framework. Because these powers had not yet been applied at the time of the review, the report recommends that the Seychelles monitor their implementation in practice. In some cases no enforcement measures could be applied because there was no identifiable responsible person, typically for struck-off entities with no traceable director or agent.
Element C.5: Quality and timeliness of responses
Element C.5 is upgraded to Largely Compliant, reflecting meaningful improvement in practice, though the report still identifies a significant shortcoming.
During the review period, the Seychelles received 130 EOIR requests from partner jurisdictions, covering 2022 to 2024. This is a decrease from the 204 requests received during the preceding review period, though the 2024 volume was similar to 2021. Most requests related to ownership and accounting information for IBCs. Requests concerning crypto-assets appeared for the first time in 2024.
The Seychelles failed to provide a complete response in 15% of cases, down from 55% in the previous review. The report characterises this improvement as significant but not yet satisfactory. A one-in-seven failure rate means that effective exchange of information cannot be assured in practice. The failures are attributable to the unavailability of the requested ownership and accounting information, not to procedural failures in the exchange process. Communication with partners has improved: the Seychelles now provides status updates systematically where relevant, resolving a deficiency noted in 2023. The recommendation is that the Seychelles provide complete responses to all EOIR requests in a timely manner.
The EOI network and confidentiality
Elements C.1 (EOIR mechanisms), C.2 (network coverage), C.3 (confidentiality) and C.4 (rights and safeguards) all remain Compliant and attract no new recommendations.
The Seychelles participates in the Convention on Mutual Administrative Assistance in Tax Matters, has concluded a network of double taxation conventions (DTCs) and tax information exchange agreements (TIEAs), and is a party to the Southern African Development Community's Agreement on Assistance in Tax Matters (SADCA). The full list of the Seychelles' EOI mechanisms appears at Annex 2 of the report.
Key recommendations in summary
The report makes the following recommendations, which the Seychelles is expected to address under the Global Forum's enhanced monitoring process.
1. Nominee arrangements in PCCs, CSLs and domestic companies. Ensure that the identity of the nominator is available to the company even where the nominee holds less than 10% of shares.
2. Beneficial ownership database population. Continue to monitor and enforce the obligations of all legal entities and arrangements to keep adequate, accurate and up-to-date beneficial ownership information and to populate the central BO database.
3. Inactive entities. Ensure that up-to-date beneficial ownership and accounting information is available for all entities registered in the Register of Companies, including those that are inactive.
4. Accounting records. Continue supervisory and enforcement activity to ensure that all entities and arrangements maintain accounting records and underlying documentation in line with the standard.
5. Administrative sanctions. Monitor the application of the provision enabling the tax administration to impose administrative sanctions on information holders that fail to produce requested information.
6. EOIR response rate. Provide complete responses to all EOIR requests in a timely manner.
What practitioners should note
For practitioners advising on Seychelles-registered structures, the report carries several practical implications.
The gap in nominee disclosure for PCCs, CSLs and domestic companies remains unresolved. Structures relying on nominee arrangements in those vehicles below the 10% threshold carry a transparency risk that the Seychelles acknowledges and intends to address legislatively. Practitioners should not assume that the IBC reforms extend to other entity types.
The 15% EOIR response failure rate is a real-world risk. Although the failures are concentrated in older IBCs struck off before the 2021 reforms, foreign tax authorities and their advisers cannot yet treat Seychelles as a fully reliable information partner in all cases. Where information is needed for an entity with a long dormant or struck-off history, the risk of a gap is material.
The BO database remains technically accessible only through the FIU, pending the introduction of the new BORITS IT system expected in 2026. Until then, other authorities must route database queries through the FIU, adding a procedural step that could affect response times.
Finally, the introduction of virtual asset service provider regulation in September 2024, combined with the first receipt of crypto-asset information requests in 2024, signals that EOIR in relation to digital assets is becoming an active area for the Seychelles. Practitioners with clients in this space should expect increased scrutiny.
The full report covers the complete legal framework chapter by chapter, the full EOI request statistics, the Seychelles' own response to the review, and the list of EOI mechanisms in force. Note that the document text available for this article was truncated; the full report contains further analysis beyond what is summarised here.