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Cayman trust vs Bermuda trust: side by side
Cayman trust vs Bermuda trust: both are common-law island trusts, but they differ in special regimes and time limits. This page lines them up with sources and dates, so you can see where each fits, and your lawyer confirms how each applies to your deed.
Reviewed by a senior trust administrator, updated
Key facts
- Governing law
- Trustee Act 1975; Amendment Act 2025 in force 10 October 2025[3]
- Perpetuity period
- Perpetuities and Accumulations Act 2009: no perpetuity period for new trusts[4]
- Protector
- STAR trust: a beneficiary cannot enforce it; the enforcer can (s.100)[1]
- Reserved settlor powers
- Trusts (Special Provisions) Act 1989: reserved powers added by 2014 amendment[5]
Numbers in brackets point to the Sources list at the end of this page.
What to compare first
Start with what you want the trust to do. A trust for a family business, a trust for a large family with several branches and a trust for a stated purpose each point to different tools.
Then compare four things: the trust forms the law allows, who may act as trustee, the reporting that follows, and the steps to set up.
We do not rank the two places. The right one depends on your assets, your home country and the people involved.
Write your goal in one sentence before you read on. A reader who knows the goal can skip to the rows that matter and ignore the rest.
Your lawyer confirms where a settlor must live for either place. The differences below come from the law and the tools, not from the size of the market.
Each place has its own page with sources: Bermuda and the Cayman Islands.
Trustee rules side by side
Both places rely on trustee companies. Your lawyer confirms whether either requires a trustee of a particular type.
| Point | Cayman | Bermuda |
|---|---|---|
| Main statute | Trusts Act (2021 Revision) | Trustee Act 1975 and Trusts (Special Provisions) Act 1989 |
| Latest change | Perpetuity change in August 2024 | Amendment Act 2025, in force 10 October 2025 |
| Special form | STAR trust, with an enforcer (s.100) | Purpose trust, under the 1989 Act |
Basis: Walkers (2024), Ogier (2025), and Carey Olsen via Legal 500 (2025); the Bermuda statute titles come from Bermuda Laws Online, Trusts (Special Provisions) Act (1989), accessed 2026-11-05. Your lawyer confirms the Bermuda reserved-powers point for your case.
A private trust company is a company a family sets up to act as trustee. Which rules apply to such a company in Bermuda and in Cayman is a point your lawyer confirms.
On settlor powers, the 1989 Act allows reserved powers, added by a 2014 amendment (source: Bermuda Laws Online). Your lawyer confirms how that compares with Cayman.
Reporting side by side
Reporting does not separate the two places. Which international duties apply to a trust is a point your lawyer confirms.
| Point | Cayman | Bermuda |
|---|---|---|
| What you file at home | Set by your home country | Set by your home country |
Banks usually ask for self-certification forms for the trust at the start. Your own tax adviser tells you what you file, so give the adviser the draft deed and the asset list, whichever place you choose.
Set-up side by side
The steps are the same in both places: enquiry, identity checks, structure design, drafting, signing and funding. What changes is the law firm and the trustee company involved.
| Point | Cayman | Bermuda |
|---|---|---|
| Time limit on a trust | Ordinary trusts made after August 2024 may disapply the rule; STAR trusts sit outside it | No perpetuity period for new trusts, under the 2009 Act |
Basis: Ogier (2025), Walkers (2024) and Bermuda Laws Online, Perpetuities and Accumulations Act (2009); accessed 2026-11-05. Your lawyer confirms the Bermuda time-limit point for your case.
The Bermuda steps and documents list what the trustee asks for. The papers are close to the same for Cayman.
When another place may fit better
If you hold a family company and want the trustee to leave management to the family, another place with a special regime for company shares may suit you better. Our BVI page covers that regime.
If you want a base closer to your home or your language, a nearer place may be easier to run. Hong Kong is one example, and its page sets out its rules with sources.
The first review may also show that a trust is not the right tool. Tell us your goal and your country, and we say early if another route fits better.
For the Bermuda rules in detail, read the law and features page. The jurisdictions hub lists the other places we cover.
Frequently asked questions
How does a trust in Bermuda differ from other places?
Cayman has the STAR regime with an enforcer; Bermuda has purpose trusts under its 1989 Act, and your lawyer confirms whether one fits your aim. The differences that matter are the trust forms allowed, the trustee choices and the reporting that follows, and your lawyer weighs them for you.
How do I compare Bermuda with other places?
List your assets, your country and the roles you want, then compare Cayman and Bermuda on the trust forms, the trustee choices, the reporting and the steps. Use pages with sources and dates, and ask your lawyer to check the result. We can walk through the list with you.
Sources
- Walkers: Cayman Islands STAR Trusts, Reinforcing the Role of Enforcers (2024), read 2026-11-05.
- Ogier: Adapting to Cayman Islands perpetuities changes (2025), read 2026-11-05.
- Carey Olsen via Legal 500: The Trustee Amendment Act 2025, Bermuda (2025), read 2026-11-05.
- Bermuda Laws Online: Perpetuities and Accumulations Act (2009), read 2026-11-05.
- Bermuda Laws Online: Trusts (Special Provisions) Act (1989), read 2026-11-05.