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Legislative Alert: Vanuatu Parliament October 2026 Sitting
A significant package of 21 Bills has been announced for the next sitting of the Vanuatu Parliament this month. Many of the Bills aim to close the remaining gaps in Vanuatu's compliance with FATF standards on money laundering, terrorist financing and proliferation financing. They are accompanied by a new Trust Act and a new National Music Authority.
Parliament will sit on 19 October 2026, in what will be the First Extraordinary Session of 2026. It is yet to be seen whether Parliament will be able to review and vote on all pieces of legislation before it.
We have prepared a short list of the legislation that will likely have the biggest impact on businesses operating in Vanuatu. We will provide more substantive information as and when updates become available. In the meantime, here is what you need to know:
Bill for the Trust Act (new Act)
For the first time since independence, Vanuatu will have its own single, modern and comprehensive domestic trust law replacing the inherited UK framework. It sets out how express trusts are created, the powers and duties of trustees, the appointment and removal of trustees and protectors, and the Supreme Court's supervisory powers. The rule against perpetuities will no longer apply to express trusts.
Transparency is a central feature of the Act. Trustees, including non-professional trustees, must obtain, verify and maintain beneficial ownership information, update it within 30 days of any change and keep records for at least 7 years. Trusts and foreign legal arrangements with “sufficient links to Vanuatu” must register with the Vanuatu Financial Services Commission (VFSC). Examples of such links include a Vanuatu-resident trustee, assets located in Vanuatu or a Vanuatu bank account. Registered trusts must also lodge annual returns. Existing trusts will have 12 months from commencement to register.
Licensing of trust service providers moves into the new Act. There will be three classes of licence: Trust Service Provider, Director’s Trust and Special Trust, the last of which covers the administration of customary land. Supervision will be risk-based. The penalty for failing to keep records is a fine of up to VT10 million or 5 years' imprisonment for individuals, and up to VT50 million for bodies corporate.
Bill for the International Banking (Amendment) Act
Responsibility for administering the International Banking Act [CAP 280] moves from the Reserve Bank to the VFSC. The VFSC will have stronger powers to supervise licensed international banks, obtain and share information, and cooperate with other authorities.
Supervision will be risk-based, taking into account ownership, governance, products, customer profiles and geographic exposure. The Bill introduces specific supervision of targeted financial sanctions under the United Nations Financial Sanctions Act No 6 of 2017, with fines of up to VT25 million. It also requires group-wide AML/CTF programs and VFSC approval for ownership changes of 10% or more.
Enforcement tools will include warnings, compliance directions, remediation plans, removal of management, additional licence conditions, and revocation. A new penalty notice process will let the VFSC deal with non-compliance without going to court, with fines of up to VT75 million for false or delayed information.
Bill for the Vanuatu National Music Authority Act (new Act)
This Bill sets up the Vanuatu National Music Authority to formalise, protect and develop the music industry, with the aim of turning music from cultural heritage into a sustainable economic sector. All commercial music actors, including musicians, songwriters, producers and promoters, will need an annual music permit. Operating without a permit can attract a fine of up to VT20 million or 2 years' imprisonment. Existing commercial music actors will have 6 months from commencement to apply.
Bill for the Anti-Money Laundering and Counter-Terrorism Financing (Amendment) Act
Reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act No 13 of 2014 (AML/CTF Act) will have to renew their registration every year. Before appointing a key person, they will need to obtain a fit and proper assessment and advisory opinion from the Financial Intelligence Unit (FIU) Director. They will also have to obtain satisfactory evidence of the source of cash and take reasonable steps to verify each beneficial owner. The Director will gain power to direct entities to provide due diligence information. The FIU's independence from outside direction will be guaranteed by law.
Bill for the Companies (Amendment) Act
Each domestic company registered under the Companies Act No 25 of 2012 will be limited to one business activity, which must be specified in its rules. Nominee shareholders and directors must disclose their nominee status and the identity of their nominator. A conviction under the AML/CTF Act becomes a ground for removing a company from the register. Maximum penalties increase to VT25 million for individuals and VT125 million for bodies corporate.
Bill for the International Companies (Amendment) Act
International companies registered under the International Companies Act [CAP 222] will be limited to one business activity, which must be stated in their constitution. Nominees must disclose their status and the identity of their nominator. The VFSC will keep a central register of beneficial owners, and companies must provide and update this information. A conviction under the AML/CTF Act becomes a ground for striking a company off the register. Penalties are the same as under the new Companies Bill: up to VT25 million for individuals and VT125 million for bodies corporate.
Bill for the Financial Dealers Licensing (Amendment) Act
Potential reforms to the Financial Dealers Licensing Act [CAP 70] will see the “exempted dealer” category removed. New fees will apply to changes of key persons: VT300,000 for a change of beneficial owner and VT150,000 for any other key person. Licensees must keep institutional risk assessments up to date and apply risk-based internal controls. They must also file quarterly financial reports with the Commissioner. Late filing will cost VT2,000 per day.
Bill for the Financial Institutions (Amendment) Act
Under the proposed changes to the Financial Institutions Act [CAP 254], the Reserve Bank's powers to supervise licensed financial institutions are strengthened, including its powers to obtain and share information, cooperate with other authorities, and enforce the law. Supervision of ownership, management and targeted financial sanctions will be risk-based. A new penalty notice process gives the Reserve Bank an alternative to court proceedings.
Bill for the Mutual Assistance in Criminal Matters (Amendment) Act
Under the proposed amendments, the Public Prosecutor must keep a case-management system for all mutual legal assistance requests, so that each request is registered, monitored and kept up to date from receipt to completion. Authorities that execute requests must give the Public Prosecutor timely information. The system will allow aggregated or anonymised statistics to be prepared for authorised purposes while protecting confidential information.
Bill for the Tax Administration (Amendment) Act
The Lotteries Act, Interactive Gaming Act, Gaming Control Act and Casino Control Act become “tax laws” under Schedule 2 of the Tax Administration Act No 37 of 2018. As a result, the Act will govern the administration and enforcement of taxes, licence fees, levies and penalties payable under gambling legislation. The licensing and regulatory requirements of the gambling legislation are not changed.
Bill for the Virtual Assets Services Providers (Amendment) Act
The Bill sets new “travel rule” requirements for virtual asset transfers. Originating, intermediary and beneficiary VASPs must obtain, verify and pass on originator and beneficiary information. Additional requirements apply to transfers above USD/EUR 1,000. VASPs must screen transfers against targeted financial sanctions and freeze and report sanctioned assets. They must also keep records for at least 6 years. Penalties are up to VT50 million and/or 20 years' imprisonment for individuals, and up to VT250 million for corporations.
Other notable proposed amendments:
Bill for the Charitable Associations (Incorporation) (Amendment) Act: This Bill narrows the Charitable Associations (Incorporation) Act so that it regulates only a risk-targeted category of charitable associations aligned with the FATF definition, and requires the Registrar to identify higher-risk associations and place them under enhanced supervision and monitoring.
Bill for the Company and Trust Services Providers (Amendment) Act: This Bill removes all references to trusts and trust service providers from the Act, because trusts will now be regulated under the new Trust Act, so that the Act deals only with the licensing and regulation of company service providers.
Bill for the Foundation (Amendment) Act: This Bill expands the definition of beneficial owner to include foundation beneficiaries and anyone exercising ultimate effective control, and requires foundations to file an annual governance report and keep specified records for 6 years after dissolution.
Bill for the Incorporated Cell Companies (Amendment) Act: This Bill defines “beneficial owner”, requires beneficial ownership information and documents to be provided when applying to incorporate an incorporated cell company, and requires a Register of beneficial owners to be established and maintained.
Bill for the Mutual Funds (Amendment) Act: This Bill requires mutual funds to disclose their beneficiaries and keep a register of beneficial owners and beneficiaries, and introduces risk-based and consolidated group supervision together with new proliferation financing controls.
Bill for the Offshore Limited Partnerships (Amendment) Act: This Bill introduces a statutory definition of “beneficial owner”, requires offshore limited partnerships to give accurate and up-to-date beneficial ownership information to the Registrar, and requires disclosure of any nominator acting behind a nominee arrangement.
Bill for the Partnership (Amendment) Act: This Bill requires disclosure of any nominator behind a nominee arrangement, limits each partnership to one business activity, makes a contravention of the AML/CTF Act a ground for cancelling a certificate, and increases the renewal fee from VT1,000 to VT20,000.
Bill for the Protected Cell Companies (Amendment) Act: This Bill defines “beneficial owner”, requires a Register of beneficial owners to be established and maintained, and imposes penalties for failing to give the Commissioner required information or for giving false or misleading information.
Bill for the Unit Trusts (Amendment) Act: This Bill expands the definition of beneficial owner to include the beneficiary of a unit trust, requires the Registrar to adjust supervision according to each fund's risk profile, and requires unit trusts to assess proliferation financing risks and implement risk-based internal controls.
Bill for the Vanuatu Interactive Gaming (Amendment) Act: This Bill introduces an initial 2-year interactive gaming licence, followed by a further licence of up to 10 years if the licensee's compliance is satisfactory, and requires licensees to maintain genuine business operations in Vanuatu.
If passed, each Bill will commence on publication in the Gazette. Businesses, licensees, trustees and service providers should start reviewing their compliance frameworks now.
Copies of each Bill are available at the Vanuatu Parliament Website: https://parliament.gov.vu/index.php/parliamentary-business/bills
More information to follow.
