Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2025

Bahrain

Bahrain joined the Global Forum on 1 September 2009. Bahrain underwent its Second Round of EOIR Peer Review in 2018 (Bahrain’s 2018 Report),1 which assessed its legal and regulatory framework in force as at July 2018 and its practical implementation, including in respect of EOI requests received and sent, during the review period from 1 July 2014 to 30 June 2017. Bahrain received an overall rating of Compliant and the individual Elements were rated as follows:

 

	A.1	A.2	A.3	B.1	B.2	C.1	C.2	C.3	C.4	C.5	Overall
Determinations	i.p.b.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	n.a.	C
Ratings	LC	C	C	C	C	C	C	C	C	C

Status of implementation of recommendations

Bahrain received one in‑box recommendation on Element A.1, which was rated Largely Compliant while the other nine Elements were rated Compliant. Bahrain also received nine in‑text recommendations in relation to Elements A.1, A.2, B.1, C.1, C.2 and C.5.

This monitoring report assesses the actions taken by Bahrain to address the recommendations issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.

The report concludes that the in‑box recommendation and the in‑text recommendations are “considered addressed in the context of the monitoring process (subject to a peer review)”. The report advises on actions required.

Element A.1: Availability of ownership information

1. Availability of beneficial ownership information for partnerships

 

Recommendation (A.1, framework)	Bahrain should ensure that beneficial ownership information for all relevant entities, including partnerships, is available and up to date.
Underlying factor	Beneficial ownership information for partnerships may not be available in all cases because the commercial register does not necessarily capture the exercise of control through means other than shareholding. For all other legal entities and arrangements this gap is remedied by the requirement to have a local bank account, ensuring that AML-compliant CDD [customer due diligence] is conducted; but there is no requirement for partnerships to maintain a local bank account that would ensure up-to-date beneficial ownership information is captured through CDD [customer due diligence]. (see paragraphs 93 et seq. of the Bahrain’s 2018 Report for more information).
Summary of actions reported	Since April 2019, all partnerships are required to provide a bank deposit certificate from a Bahrain bank to the commercial registrar as part of the requirements to renew their commercial registration and to undertake any transactions at the commercial registry. All registered partnerships have since submitted information indicating a bank account held in a Bahraini bank. Further, Bahrain issued a Ministerial Order no 23 of 2024 on 13 June 2024 requiring all commercial entities (including partnerships) to have a bank account with a Bahraini licensed bank and to make any payments only through such bank accounts. Banks are required to conduct customer due diligence and identify the beneficial owners of bank accounts and to report any dormancy on the accounts, to the authorities. Additionally, since 2020, all registered entities and arrangements must identify their beneficial owners and submit such information to a central beneficial ownership register (which is part of the commercial registry) maintained by the Ministry of Industry and Commerce. Pursuant to the Ministerial Order No. 83 of 2020 (Criteria, Conditions and Rules Governing the Disclosure of Ultimate Beneficial Owner), all entities are required to submit their beneficial ownership information upon registration, and thereafter within three days of any change and annually, as part of the process for their annual re-licensing. Bahrain has confirmed that the central beneficial ownership register is now the main source of beneficial ownership information. Since 2021, Bahrain has conducted various supervisory activities to ensure that the reported beneficial ownership information is accurate, adequate and up to date. The activities started with sensitisation of all entities on their beneficial ownership obligations and progressed to desk‑based reviews and onsite inspections. Where non-compliance was detected, corrections were required or sanctions have been applied, including fines, closure of business and dissolution of entities. Bahrain has reported that as of April 2025, all the commercially active registered companies and partnerships have submitted their beneficial ownership information to the central register.
Conclusion	Bahrain has taken comprehensive actions to address the legal issue, and the recommendation is “considered addressed in the context of the monitoring process (subject to a peer review)”. Bahrain has strengthened its legal and regulatory framework by requiring all commercial entities (including partnerships) to identify and submit their beneficial ownership information to a central beneficial ownership register. All the registered companies and partnerships have submitted beneficial ownership information to the central beneficial ownership register. The register is now the preferred source of beneficial ownership information for the Competent Authority. The definition and methodology to identify beneficial owners, including aspects of control through means other than ownership, are well elaborated and are in line with the standard. Moreover, all commercial entities (including partnerships) are required to maintain a bank account with a local bank in Bahrain, which must gather beneficial ownership information through performing customer due diligence pursuant to anti-money laundering obligations. Bahrain has reported that all the partnerships registered in Bahrain maintain a bank account with a bank in Bahrain and accordingly the AML framework is also a comprehensive source of beneficial ownership information. Bahrain has taken comprehensive actions to ensure the implementation in practice of the new obligations. The enforcement of AML obligations was considered appropriate in the 2018 Report, and the new obligations related to the central beneficial ownership register have been extensively monitored since 2021, with appropriate sanctions imposed where non-compliance was detected.
Status determined	Considered addressed in the context of the monitoring process (subject to a peer review).
Actions required	No immediate action required.

EOIR experience

Over the monitoring period 2023-2024, Bahrain received 10 requests but did not send any requests. The Netherlands, India and Tunisia were the top three partners from which Bahrain received these requests. Bahrain reported providing full and final responses in all the received cases.

Bahrain received peer input from four of its peers. Whereas three of them stated that they had no exchanges of information with Bahrain under the monitored period, one peer reported to have received all the requested information within 90 days and that the responses were satisfactory.

Status of in-text recommendations

Bahrain has taken necessary steps to address the nine in-text recommendations made in its 2018 Report. Since the issuance of the Report, none of the issues pertaining to these in-text recommendations have had more than a negligible impact on EOIR in practice. Based on the actions taken by Bahrain to address these in-text recommendations and the absence of change in the materiality of the identified issues, all the nine in-text recommendations are “considered addressed in the context of the monitoring process (subject to a peer review)”.

New developments having a bearing on the EOIR standard

No recent developments that have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Bahrain or have otherwise come to light.

Next steps

The in-box recommendation and the in‑text recommendations made in the 2018 Report of Bahrain are “considered addressed in the context of the monitoring process (subject to a peer review)’’. The following next steps are expected from Bahrain:

• Bahrain is exempted from reporting on these recommendations in its next self-assessment in 2028.

• Bahrain must, nevertheless, continue submitting a self-assessment report under the enhanced monitoring process to

  • report any new domestic developments (legal, administrative or any judicial pronouncement) that may have a bearing on the implementation of the EOIR standard in the self-assessment report

  • report statistical information on its EOIR experience during the monitoring period

  • provide a response on any other matter having a bearing on the EOIR standard when specifically requested.

• Further, Bahrain’s response on any issues with broader implications on compliance with the standard, raised in peer input, will continue to be sought under the enhanced monitoring process.

• Bahrain must report actions to address any future recommendations pertaining to the EOIR standard that may be issued to it under the Global Forum’s monitoring and review processes.

Views/response of the monitored jurisdiction

The Enhanced Monitoring review has been an important opportunity for the Kingdom of Bahrain to present its commitment in addressing the recommendations and compliance with the Exchange of Information on Request (EOIR) Standard.

The Kingdom of Bahrain remains fully committed to the EOIR Standard and will continue to work closely with the Global Forum and its exchange partners.

We would like to thank the Assessment Panel for their hard work, continued engagement, constructive dialogue, and support through this process. Also, we would like to thank the Peer Review & Monitoring Group for their valuable feedback and work.

Note

← 1.  OECD (2018), Global Forum on Transparency and Exchange of Information for Tax Purposes: Bahrain 2018 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/9789264306080-en.