Background: the rule that came into force in June 2026

Since 19 June 2026, GBCs have been subject to a new FSC bank signatory regime. In practice, every bank account held by a GBC must now include, among its authorised signatories, at least one officer of the licensed Management Company overseeing the structure, who is an approved officer under section 24 of the Financial Services Act. 

The stated objectives are straightforward:

• strengthen the substance of GBCs in Mauritius;
• discourage pure “letterbox” structures where the Management Company appears on paper but is not involved in banking operations;
• improve traceability and control in line with AML/CFT expectations and sound corporate governance.

Initially, existing GBCs had three months from 19 June 2026—i.e. until 19 September 2026—to update their bank mandates accordingly.

What circular CL20261009 of 10 September 2026 actually changes

Through circular CL20261009, issued on 10 September 2026, the FSC announced an extension of the transition period. Instead of three months, existing GBCs now have six months from the effective date of the rule (19 June 2026) to bring their bank mandates into line.

In practical terms, this pushes the compliance deadline to 19 December 2026. 

Three key points stand out:

The underlying rule has not changed. The requirement to have a Management Company officer as an authorised signatory remains in force. The circular does not amend the Guidelines; it simply allows more time to implement them.

The extension is an opportunity, not an open-ended reprieve. Existing GBCs now have additional time to make the necessary changes. The extension should therefore be used to start the process rather than delay it.

New GBCs are not covered by the extension. For GBCs incorporated after 19 June 2026, the new regime must be taken into account when setting up their bank accounts.

The MCSP angle: a model now suspended

On 8 September 2026, the FSC issued circular CL20260309, suspending with immediate effect its policy on Managed Corporate Service Providers (MCSPs) and revoking the Practice Notes that supported this framework.

New applications for Management Company licences under this model are no longer accepted or processed. Transitional arrangements apply to existing applications and MCSPs, depending on their circumstances.

For GBCs that have relied on this type of arrangement, the implications are concrete:

• Governance review: boards, committees and decision-making processes must reflect genuine involvement by the Management Company.
• Choice of Management Company: some structures may need to change provider or renegotiate the scope of services.
• Bank documentation: banks may ask for resolutions, evidence of authority and information on the Management Company’s role. 

How to use this extension without creating risk

Taking advantage of CL20261009 does not mean waiting until December to act. Here is a realistic action plan for October–November 2026:

Map all affected GBCs

List all GBCs under management, capturing for each:

• date of incorporation;
• incumbent Management Company;
• banks and account numbers;
• date of last update of signatory mandates.

Identify non-compliant accounts

For each account, check whether a Management Company officer (approved under section 24) is listed as an authorised signatory. 

Prioritise:

• GBCs with significant flows or third-party investors;
• structures in regulated or sensitive activities (funds, investment advisers, etc.);
• structures where the bank applies enhanced KYC or governance requirements.

Prepare internal documentation

Anticipate banks’ document requests:

• board resolutions authorising changes to signatories;
• up-to-date lists of directors and officers;
• evidence of the FSC approval for the relevant officer;
• cover letters explaining how the changes align with the FSC Guidelines.

Open the dialogue with banks

Contact relationship managers to:

• confirm their exact documentary requirements;
• agree a timeline for updating mandates;
• check whether they require additional items (e.g. description of the Management Company’s role, governance organigram).

How C&S Secretarial Services can help

C&S supports GBC owners and their advisers in bringing their banking arrangements into line with the new regime:

• “Bank signatories” audit: mapping of accounts, review of current mandates, gap analysis against FSC Guidelines.
• File preparation: board resolutions, letters to banks, signatory lists, up-to-date corporate documentation.
• Coordination with Management Companies and banks: to streamline exchanges and avoid unnecessary back-and-forth.

Do you have GBCs with accounts opened before June 2026? Describe your situation and we will propose a tailored plan to reach compliance before 19 December 2026. 

Editorial note: This article is intended as a practical guide for GBC owners, family offices and advisers. It does not constitute legal or tax advice, but aims to help companies discuss the steps required with their Management Company and bank. 

Sources of this article: 

• 10 September 2026 To: The Board of Directors Management Companies Dear Sir/Madam, New Authorised Bank Signatory Regime Exte
• LinkedIn – Why the end of the MCSP model and the new Global Business Company bank signatory regime deserve attention from boards, investors and fund managers
• Mauritius FSC Introduces New Authorised Bank Signatory Regime for GBCs — Effective 19 June 2026 | Zitadelle AG
• FSC Circulars    

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