Crypto Law Profile

Bermuda Digital Asset Issuance Act 2020

Bermuda’s Digital Asset Issuance Act 2020 places public digital asset issuances in or from Bermuda under BMA oversight, with authorisation, disclosure, risk-warning, AML/ATF, custody, and acquirer-protection rules.

Bermuda Effective Act May 6, 2020

At a glance

Status In force since May 6, 2020; BMA remains the supervisory authority for digital asset issuances.
Regulator Bermuda Monetary Authority authorises and supervises covered digital asset issuances.
Scope Public digital asset offers conducted in or from Bermuda, subject to rule-based exemptions.
Core duties Authorisation, issuance-document, risk-warning, acquirer-identification, custody, and reporting controls.

Overview

Status: In force. Bermuda’s Digital Asset Issuance Act 2020 is the jurisdiction’s core statute for public offers of digital assets conducted in or from Bermuda. The Act received assent on March 19, 2020 and became operative on May 6, 2020. It places digital asset issuances under the supervisory remit of the Bermuda Monetary Authority (BMA), with supporting rules and supervisory principles published by the BMA.

What the Bermuda Digital Asset Issuance Act regulates

The Act focuses on offerings of digital assets rather than the full range of digital asset business activities. It defines a digital asset issuance as an offer to the public to acquire digital assets, or to enter into an agreement to acquire digital assets at a future date. Bermuda-incorporated or Bermuda-formed undertakings are captured when they conduct an issuance in or from Bermuda, and foreign-formed undertakings may also be captured when they conduct an issuance in or from within Bermuda.

The BMA describes the regime as applying to digital asset issuances unless the relevant activity is being carried on as a business, which may bring the activity into Bermuda’s separate digital asset business framework. For CryptoSlate taxonomy purposes, this profile treats the Act as a token issuance, authorization, disclosure, AML/ATF, and acquirer-protection statute.

Key provisions of the Digital Asset Issuance Act 2020

BMA authorisation

Subject to exemptions under the rules, a person may not conduct a digital asset issuance in or from Bermuda unless the person is an authorised undertaking. An application to the BMA must include a business plan, the proposed issuance document, details of management arrangements for the offering, any other information reasonably required by the Authority, and the applicable application fee. The BMA may grant or refuse an authorisation and must be satisfied that the statutory minimum criteria are met.

Issuance document, platform, and updates

The regime uses an issuance document as the main disclosure instrument for digital asset acquirers. The BMA’s 2020 Rules require the document to include a non-technical summary of key information and minimum details about the issuer, the project, the digital asset, the offer structure, risks, custody arrangements, and relevant participants. If particulars in a published issuance document become materially inaccurate, the undertaking must publish supplementary particulars and file them with the BMA.

Acquirer-protection measures

The Act requires a communication facility for messages, questions, and responses while an offer is open or suspended. It also provides a three-business-day withdrawal right for an application made in relation to an offering. Promoters must include risk warnings in the issuance document and on the platform, including information about substantial project risks, rights if the project does not go forward, the rights attached to the digital assets, and any disclaimers relating to guarantees or warranties.

Compliance, custody, and liability

Authorised undertakings must apply appropriate measures for identification and verification of persons participating in a digital asset issuance, and must maintain appropriate mechanisms for digital asset security, confidentiality, and disclosure matters. The Rules further address AML/ATF-style identification and verification, enhanced due diligence, sanctions compliance, recordkeeping, custody reconciliation, and qualified custodian expectations. The Act also creates civil liability for certain untrue statements in issuance documents where a purchaser proves reliance and resulting loss.

Status and timeline

The Act replaced Bermuda’s earlier company and limited liability company initial coin offering provisions, subject to transitional savings for pre-commencement ICO applications. The Digital Asset Issuance Rules 2020 became operative on December 7, 2020, and the BMA’s Statement of Principles explains how the Authority approaches authorisation, restriction, revocation, information gathering, and enforcement powers under the Act. As of July 10, 2026, the official BMA digital asset issuance page continues to list the Act and Rules as the core documents for the DAI regime.

Key provisions

BMA authorisation required

Covered issuers generally may not conduct a digital asset issuance in or from Bermuda unless authorised by the BMA or within a rule-based exemption.

Licensing & Registration May 6, 2020 Source

Issuance document regime

Applicants must provide an issuance document and related business-plan materials; published particulars must be supplemented if materially inaccurate.

Disclosure & Marketing May 6, 2020 Source

Risk warnings and cooling-off

Promoters must display risk warnings, operate a communication facility, and provide a three-business-day application withdrawal right.

Consumer protection May 6, 2020 Source

Identification and AML/ATF measures

Authorised undertakings and rules require acquirer identification, verification, sanctions compliance, and enhanced due diligence where needed.

AML/CFT Dec 7, 2020 Source

Custody and liability controls

Rules address custody reconciliation and qualified custodians; the Act creates liability for certain untrue statements in issuance documents.

Custody Dec 7, 2020 Source

Timeline

  1. Assent

    Act 2020:18 received assent.

    Enacted Source
  2. Operative

    Act came into operation; earlier ICO provisions were superseded subject to savings.

    In force Source
  3. BMA Statement of Principles

    BMA published supervisory principles for authorisation, restrictions, revocation, information, and enforcement powers.

    Enacted Source
  4. DAI Rules operative

    BMA Rules 2020 became operative, adding issuance-document, compliance, custody, and exemption detail.

    In force Source

Who it affects

Actors

Bermuda Monetary Authority, Minister of Finance

Asset classes

Digital assets, Tokens

Official sources

Editorial note

Non-U.S. operative statute mapped to In force. Profile covers the Act and notes the Digital Asset Issuance Rules 2020 and BMA Statement of Principles as official implementation materials.