Executive summary
This report presents the Global Forum’s analysis of Vanuatu’s compliance with the standard on transparency and exchange of information on request (the standard) and concludes that Vanuatu is to be rated as overall Largely Compliant with the standard. This conclusion is based on an assessment of Vanuatu’s legal and regulatory framework in force as at 16 February 2026 and its practical implementation, including in respect of exchange of information (EOI) requests sent and received during the review period from 1 July 2021 to 30 June 2024. Vanuatu was previously assessed in 2019 and rated as overall Partially Compliant.
Progress made since previous review
The 2019 Report identified key deficiencies in the legal and regulatory framework that prevented Vanuatu from ensuring timely availability of legal and beneficial ownership and accounting information. Further, there were gaps in the supervision, oversight and enforcement of the relevant obligations, to support the availability of such information.
Vanuatu has addressed some of the deficiencies identified through amendments to its legal and regulatory framework, while other deficiencies are partly addressed or remain unaddressed.
Regarding the availability of legal and beneficial ownership information, the recommendation regarding the absence of a requirement for local (private, public and community) and overseas companies to provide beneficial ownership information and report changes in beneficial owners is addressed. All companies are now obliged to submit an annual return with up-to-date legal and beneficial ownership information to the Vanuatu Financial Services Commission (VFSC). This is complemented by the Tax Administration Act (TAA), which requires all legal entities and arrangements to maintain up-to-date legal and beneficial ownership information.
Regarding the availability of accounting information, the recommendation for ensuring the availability of accounting records for a minimum of five years, including where an entity or arrangement ceases to exist, is addressed. The TAA introduced obligations for keeping accounting records for all legal entities and arrangements for at least five years from the period to which they relate, including in cases where they cease to exist, and assigns responsibility with dissuasive sanctions.
Regarding confidentiality, the recommendation to ensure that the confidentiality clauses in Vanuatu’s EOI agreements are respected in all cases is addressed through an amendment to the Right to Information Act, which exempts its application to information exchanged under tax treaties. In addition, the new provisions in the TAA overrides the confidentiality provisions of any other laws.
Despite the progress made, key deficiencies and related recommendations on the availability and exchange of legal and beneficial ownership and accounting information persist.
Comparison of ratings for the initial and supplementary Second Round Report
| Element | Initial Report (2019) | Supplementary Report (2026) | |
| A.1 | Availability of ownership and identity information | Partially Compliant | Partially Compliant |
| A.2 | Availability of accounting information | Non-Compliant | Partially Compliant |
| A.3 | Availability of banking information | Largely Compliant | Largely Compliant |
| B.1 | Access to information | Compliant | Compliant |
| B.2 | Rights and Safeguards | Compliant | Compliant |
| C.1 | EOIR Mechanisms | Compliant | Compliant |
| C.2 | Network of EOIR Mechanisms | Compliant | Compliant |
| C.3 | Confidentiality | Largely Compliant | Compliant |
| C.4 | Rights and safeguards | Compliant | Compliant |
| C.5 | Quality and timeliness of responses | Largely Compliant | Compliant |
| Overall rating | Partially Compliant | Largely Compliant |
Note: the four-scale ratings are Compliant, Largely Compliant, Partially Compliant and Non-Compliant.
Key recommendations
Regarding identity and beneficial ownership information (Element A.1) and banking information (Element A.3), the gaps in the anti-money laundering (AML) framework definition of beneficial owners of partnerships, trusts and foundations remain unaddressed. While these gaps are mitigated by the TAA under Element A.1, banks are not obligated to follow its definition and methodology for the identification of beneficial owners, therefore the gap remains with respect to Element A.3, thus affecting the availability of full banking information. In addition, the legal framework still does not ensure the availability of banking information when a bank ceases to exist.
The legal and regulatory framework needs more changes to ensure the availability of legal ownership information on all relevant entities. Vanuatu legislation authorises the use of nominee shareholders, which can obstruct transparency on the legal ownership of companies, and requires companies to keep information on their nominee shareholders and the nominators of nominee shareholders. However, it does not impose a corresponding obligation on nominees (whether acting in either a professional or non-professional capacity) to disclose their nominee status and information on their nominator to the companies; thus, companies may not be able to comply with their obligation. In addition, there are no clear guidelines for determining the beneficial owners of protected cell companies and there are no clear record retention requirements for societies.
Regarding the practical implementation of the standard, Vanuatu has taken steps to supervise the effective implementation of the legal and regulatory framework, mainly through monitoring obligations to file annual returns with updated legal and beneficial ownership information. However, the supervisory measures do not yet ensure full availability of ownership and identity information for partnerships, trusts, foundations and societies. Whereas beneficial ownership information is required to be maintained and/or filed with regulatory authorities and updated annually, no checks are undertaken to ensure that the beneficial owners have been identified in line with the standard. In addition, the number of inspections undertaken with respect to registered agents who act for all international and overseas companies, foundations and a majority of local (private, public and community) companies, is not sufficient and does not ensure full availability of legal and beneficial ownership information. Finally, while the tax law requires all relevant entities and arrangements to maintain legal and beneficial ownership information, supervision by the tax administration has been limited to persons registered for tax purposes, but there is no requirement for all relevant entities and arrangements to register, thus the scope of the tax administration’s supervision is limited and notably excludes international companies. Vanuatu is recommended to strengthen its supervisory measures to ensure the availability of adequate, accurate and up to date beneficial ownership information.
Regarding accounting information (Element A.2), a new issue is identified in the legal framework regarding the availability of accounting records when a registered agent has been struck off. In addition, the supervision of the practical implementation of the legal framework is not yet sufficient to ensure full availability of accounting information in line with the standard, therefore the 2019 recommendation remains unaddressed. Supervision has mainly relied on the requirement to file annual returns. While the average annual filing rate is high (88% across all company types and 100% for foundations), this does not ensure the availability of underlying documents which are not filed with the annual returns. Vanuatu authorities have inspected only a few registered agents who have the obligation to maintain accounting records and underlying documentation for international and overseas companies, approximately 64% of local companies who engaged a registered agent during the review period and all foundations. No inspections have been undertaken on the legal entities and arrangements themselves regarding compliance with obligations for maintaining accounting records and underlying documentation. While the tax administration has conducted supervisory activities, these were limited to persons registered for value-added tax purposes and did not cover international companies and foundations that are not required to register for tax.
Exchange of information in practice
Vanuatu does not send out requests for EOI as it does not have an Income Tax system. Vanuatu also receives a limited number of EOI requests. During the current review period, Vanuatu received three requests that mainly sought legal and beneficial ownership and accounting information, compared with two requests received during the review period for the 2019 Report. Vanuatu still has limited experience in Exchange of Information on Request (EOIR), but the Vanuatu Competent Authority Office (Exchange of Information Unit) was created on 1 January 2020.
In preparation for this review, peers provided positive input regarding their limited experience in exchanging information with Vanuatu. Vanuatu is now rated Compliant with all the elements of the standard related to access to and exchange of information.
Overall rating
Vanuatu has been assigned a rating for each of the ten essential elements as well as an overall rating. The ratings for the essential elements are based on the analysis in the text of the report, considering any recommendations made in respect of Vanuatu’s legal and regulatory framework and the effectiveness of its exchange of information in practice. On this basis, Vanuatu has been assigned the following ratings: Compliant for Elements B.1, B.2, C.1, C.2, C.3, C.4 and C.5, Largely Compliant for Element A.3, and Partially Compliant for Elements A.1 and A.2. In view of the ratings for each of the essential elements taken in their entirety, the overall rating for Vanuatu is Largely Compliant.
This report was approved at the Peer Review and Monitoring Group (PRMG) of the Global Forum on 27 March 2026 and was adopted by the Global Forum on 23 April 2026. A self-assessment report on the steps undertaken by Vanuatu to address the recommendations made in this report should be provided to the PRMG in accordance with the methodology for Enhanced Monitoring.
