A concise walkthrough of the latest FSC regulatory changes — and the practical steps investment managers operating in Mauritius should take before the next reporting cycle.
The regulatory landscape in Mauritius shifted materially in 2025 and carries significant implications into 2026. For fund managers, GBC operators, and investment managers using Mauritius as a structuring or administration hub, several developments require active attention — not deferred review. This article sets out the principal changes and their operational consequences.
1. The Two Resident Director Requirement for GBCs
Among the most consequential amendments introduced through the 2025 Finance Act is the strengthening of the resident director requirement for Global Business Companies. GBCs are now required to have at least two resident directors in Mauritius at all times — and those directors must be of sufficient calibre to exercise independent judgement.
This is not a new concept, but the language has been tightened. 'At all times' removes any ambiguity about interim gaps during transitions. For fund managers whose GBC boards are nominally constituted but not actively supervised by locally present, substantively qualified directors, this requires immediate review.
Separately, the FSC must now be notified within seven days of any statutory filing or director change lodged with the Registrar of Companies or the CBRD. Simultaneous filings with the FSC and the Registrar are now the required standard, not a best practice.
2. Beneficial Ownership: Stricter UBO Requirements
The 2025 Finance Act introduced enhanced beneficial ownership obligations under the Companies Act. Regulated entities — including funds and their GBC holding structures — must now apply more rigorous standards for identifying, verifying, and maintaining records of ultimate beneficial owners (UBOs).
For companies incorporated before 30 June 2025, compliance with the new UBO declaration requirements is required by 30 June 2026. Fund managers should audit their full entity chain — including layered holding structures where GBCs sit above or below offshore vehicles — to confirm UBO analysis is current and meets the expanded definition of control now applicable under the amended framework.
3. AMLA 2026: Proliferation Financing as a Formal Compliance Pillar
The Anti-Money Laundering Act 2026 (AMLA 2026) represents the most significant overhaul of Mauritius's AML/CFT framework in recent years. Its key addition for operational compliance purposes is the formalisation of Countering Proliferation Financing (CPF) as a mandatory third pillar alongside AML and CFT.
This means FSC-licensed entities must now maintain a distinct CPF risk assessment and implement dedicated screening against proliferation-related sanctions lists. An AML/CFT programme that does not address CPF explicitly will have a material gap when inspected against AMLA 2026 expectations. The FSC has signalled through its enforcement activity — over 25 licence revocations and 13 suspensions in early 2025 — that it treats documentation gaps, not just active violations, as enforcement triggers.
4. Tiered Administrative Penalties Under GN 112/2025
Government Notice No. 112 of 2025 introduced a tiered penalty framework for KYC and reporting failures, effective from November 2025. Administrative fines now reach up to MUR 250,000 for a single breach, with recurrence attracting compounding penalties. Compliance calendars, KYC remediation timelines, and reporting schedules must now be treated with the same operational rigour as NAV deadlines.
5. FSC Licence Renewals: The July 2026 Deadline
The FSC's annual licence renewal process — now conducted via the FSC One platform — carries a hard deadline of 1 July 2026 for the 2025/2026 cycle. Entities that miss this deadline face immediate licence suspension. There is no grace period. For fund managers with multiple entities under administration in Mauritius, coordinating renewal submissions across the full entity stack requires advance planning.
What to Do Now
The common thread across these changes is that Mauritius is consolidating its position as a substance-based jurisdiction. The regulatory cost of operating a nominal structure without genuine governance, active compliance, and current reporting is now higher than it has ever been.
For fund managers reviewing their Mauritius footprint in light of these changes, Grammont's team is available to assist with governance reviews, UBO audits, compliance framework assessments, and the day-to-day administration that keeps your entities current and inspection-ready.
This article is for informational purposes only and does not constitute legal or regulatory advice. Managers should seek qualified advice specific to their structures and circumstances.