Incorporated Segregated Account Companies

A company whose segregated accounts are each incorporated separately

An incorporated segregated accounts company is a company registered under the Incorporated Segregated Accounts Companies Act 2019. Its name must include the letters ISAC. Unlike a segregated accounts company, each of its accounts is separately incorporated.

At A Glance

Governing legislationIncorporated Segregated Accounts
Companies Act 2019, sections 3 to 7
Separate legal personYes. Each of its incorporated accounts is also its own legal person
Liability of ownersAs for a company under the Companies Act 1981
Local or exempted Either
Name must contain“ISAC”
Evidence of creationCertificate of registration, section 13

Key features

An ISAC with twelve accounts is thirteen legal persons
The ISAC and each of its incorporated segregated accounts. Each has its own duties under the Beneficial Ownership Act 2025, and the obligations of the ISAC do not discharge those of its accounts.

The memorandum of an ISAC must state that it is an ISAC, failing which it will not be recognized as one.


RELATED

Incorporated segregated accounts →

Segregated accounts companies →

How to register one

  1. Check you are eligible. Insurance business, an investment fund, digital asset business, or any other company with the approval of the Minister.
  2. File a notice under section 4, including the proposed memorandum of the ISAC and of each proposed incorporated segregated account.
  3. Name the incorporated segregated account representative and the proposed directors.
  4. File and pay. Registration fees and how to pay →

Objecting to a registration

A member, creditor or prospective account owner representing at least twenty per cent in number of the relevant class may apply to the Court to annul the registration within twenty-eight days, extendable to ninety.

Records you must keep

  1. the records every company keeps, for the ISAC itself: a register of members, a register of directors and officers, a register of charges, minutes of proceedings and books of account
  2. records identifying the assets and liabilities of each incorporated segregated account
Each account keeps its own registers as well
An incorporated segregated account is a company in its own right, so it keeps the registers every company keeps. The records of the ISAC do not discharge that duty.

Account level records are held by the company and by its incorporated segregated account representative.


RELATED

Incorporated segregated accounts →

Beneficial ownership obligations

Every ISAC is subject to the Beneficial Ownership Act 2025. You must take reasonable steps to identify any individual who owns or controls twenty-five per cent or more of the interests or voting rights, or who otherwise exercises ultimate effective control; verify their identity against a reliable and independent source before entering them on your register; maintain a beneficial ownership register; file the required information with us; and update it within thirty days of being notified of a change.


RELATED

The beneficial ownership regime: an overview →

Who is a beneficial owner →

What you must record →

What information about this entity is public

A search of the register returns the registered office address, the memorandum of association, the date of registration, information on charges and previous names. We also hold the certificate of incorporation, memorandum and directors of each incorporated segregated account, and each account can be searched in its own right.

Bermuda's central register of beneficial ownership is not public.


RELATED

What information is public →

Who can access beneficial ownership information →

Incorporated segregated accounts →

Legislation

Incorporated Segregated Accounts Companies Act 2019 | 2019 : 44 · External link

Companies Act 1981 | 1981 : 59 · External link


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