Channel Islands funds update: April 2026

Newsletter

21 April 2026

Guernsey, Jersey

14 min read

Pan-island developments

Financial services strategy updates in Jersey and Guernsey

Jersey’s action plan for financial services

On 16 March 2026, the Government of Jersey published an action plan to safeguard and grow Jersey’s financial and related professional services (FRPS) sector. The plan – titled “Time to Win” – follows the most comprehensive review of the FRPS sector in more than a decade and sets out Jersey's strategy for growth:

protect Jersey's brand as a simple, stable and certain tax regime with tax neutrality at its core
reduce costs of doing business for all FRPS firms and their clients
renew Jersey's appetite for growth, optimising promotion in priority markets and providing a welcoming front door for new business
innovate processes and products, embracing digitalisation and taking a lead on tokenisation
enhance Jersey's infrastructure, investing in connectivity and international finance centre (IFC) infrastructure

There are four areas in particular of focus for growth including funds, private wealth and family offices, banking and digital.

Read the Government of Jersey’s plan: Time to Win.

Guernsey’s Finance Sector Strategy 2035

The Committee for Economic Development has released the Finance Sector Strategy 2035, a long-term plan to support sustainable growth in Guernsey's finance sector. Developed with industry input and consultancy support, the strategy, titled “Driving growth for Guernsey”, outlines over 40 work streams grouped under six strategic initiatives which aim to:

boost productivity through digitalisation and AI adoption, harmonising legal frameworks and enhancing ease of doing business
capture a larger share of existing markets by positioning Guernsey as a “private wealth super hub” and advancing fund and insurance sector growth
expand into adjacent and fast-growing areas, including tokenised securities, alternatives for high net worth individuals and pensions and respond to trends in asset classes like infrastructure and defence
mobilise private sector investment and encourage innovation, including support for start-ups and capital deployment aligned with growth objectives
emphasise Guernsey’s value proposition in the global international finance centre landscape, prioritising brand clarity and international compliance standards
tackle key structural constraints, including talent shortages, housing, air connectivity, digital infrastructure and legislative agility

Read the Government of Guernsey’s plan: Driving growth for Guernsey.

Jersey developments

COBO framework amendments – changes to the Control of Borrowing Order to streamline regulation

On 13 April 2026, the Control of Borrowing (Jersey) Amendment Order 2026 (Amendment Order) came into effect. The Amendment Order represents the first phase of changes as Jersey moves toward the full repeal in 2027 of:

the Control of Borrowing (Jersey) Law 1947
the Control of Borrowing (Jersey) Order 1958

Read the Jersey Financial Sevices Commision (JFSC) industry update: Changes to Control of Borrowing Order to streamline regulation.

To learn more about the recent COBO framework amendments, read our earlier briefing: Jersey's simplification agenda: new Control of Borrowing Order and Registry changes.

Beneficial ownership: aligning with global standards

With effect from 31 March 2026, the JFSC changed the beneficial ownership threshold collected at company incorporation from 10% to 25%, bringing Jersey in line with other international finance centres.

For further information on the recent COBO and beneficial ownership changes, read our earlier briefing: Jersey's simplification agenda: new Control of Borrowing Order and Registry changes.

AIF Code of Practice updated to reflect AIFMD II

On 8 April 2026, the JFSC published updates to the AIF Code of Practice and amended its guidance and frequently asked questions page.

These changes ensure that Jersey is aligned with the European Union’s updated Alternative Investment Fund Managers Directive II (EU AIFMD II), which came into effect on 16 April, so that Jersey maintains market access in Europe.

There are now two versions of the AIF Code of Practice:

the EU / EEA-focused code, effective from 16 April 2026, updated to reflect EU AIFMD II
the existing AIF Code, which will only apply to the UK AIF / AIFM regime from 16 April 2026

The JFSC will introduce a UK-focused code once the UK’s new approach to AIFs and AIFMs is fully developed. A new EU Annex IV reporting template is expected to be available in 2027.

The impact on Jersey business is minimal as most of the changes apply to full passport alternative investment funds (AIFs) and alternative investment fund managers (AIFMs) and have no impact on the national private placement regime, through which Jersey retains its market access as a third country.

Limited Partnerships (Jersey) Amendment Law 202-

The Limited Partnerships (Jersey) Amendment Law 202- (LP Amendment Law) was adopted by the States of Jersey on 22 January 2026.

In summary, the purpose of this amendment law is to put on to a statutory footing the framework for enabling eligible foreign limited partnerships to continue as limited partnerships in Jersey. As a result, the Limited Partnerships (Continuance) (Jersey) Regulations 2023 will be repealed.

The LP Amendment Law will incorporate certain provisions of the Limited Partnerships (Continuance) (Jersey) Regulations 2023 (temporary Regulations) into the Limited Partnerships (Jersey) Law 1994. The temporary Regulations were made by the States of Jersey for a period of three years to enable eligible foreign limited partnerships to continue in Jersey as limited partnerships and are due to expire on 17 July 2026.

There are no changes of substance to the process by which the continuance of eligible foreign limited partnerships as limited partnerships in Jersey is permitted, or to the effect of continuance.

Companies (Jersey) Amendment Law 2026

The Companies (Jersey) Amendment Law 2026 (Companies Amendment Law) was adopted by the States of Jersey on 20 January 2026 and will be brought into force on 1 June 2026.

This Law, when in force, makes amendments to the Companies (Jersey) Law 1991.

For more information, read our earlier briefing: Amendments to the Jersey Companies Law: where do you stand to benefit?.

Companies (General Provisions) (Jersey) Amendment Order 2026 and Collective Investment Funds (Certified Funds – Prospectuses) (Jersey) Amendment Order 2026

The Companies (General Provisions) (Jersey) Amendment Order 2026 (CGPO Amendment) which came into force on 6 March 2026, narrows the circumstances in which documents are treated as “prospectuses” for company law purposes. The CGPO Amendment excludes invitations relating to admissions to trading in regulated or recognised markets (within defined parameters). Where a securities offering is already subject to listing, market or overseas regulatory requirements, it is not pulled back into the Jersey company law prospectus regime (for example, in relation to certain secondary issues). This avoids overlap with market specific disclosure frameworks and aligns Jersey more closely with UK and international practice.

The Collective Investment Funds (Certified Funds – Prospectuses) (Jersey) Amendment Order 2026 was also introduced in parallel to mirror these changes and preserve consistency across regimes.

Financial Services Commission (Financial Penalties) (Jersey) Amendment Order 2026

The Financial Services Commission (Financial Penalties) (Jersey) Amendment Order 2026 came into effect on 12 March 2026 and amends the Schedule (maximum level of penalties) to the Financial Services Commission (Financial Penalties) (Jersey) Order 2015 which apply to penalties imposed by the JFSC on registered persons (firms).

The Schedule to the 2015 Order has been updated only for registered persons.

Revised maximum penalties for registered persons (firms)

Under the updated regime, the maximum financial penalties that may be imposed on firms have been recalibrated by reference to both turnover‑based thresholds and absolute monetary caps (except for band 3).

By way of comparison, prior to 12 March 2026 the maximum penalties applicable to firms were expressed solely as a percentage of turnover, without any monetary cap. The maximum penalties applicable to individuals (including principals, key persons and those performing senior management functions) are unchanged.

Draft Director Disqualification Sanctions (Jersey) Amendment Law 202-

The Draft Director Disqualification Sanctions (Jersey) Amendment Law 202- was lodged on 5 February 2026 and was adopted on 25 March 2026. This Law will amend the Companies (Jersey) Law 1991 and the Limited Liability Companies (Jersey) Law 2018 to provide that a person may not be appointed as a company director or limited liability company manager if they are subject to director disqualification sanctions.

JFSC consultations

Feedback on changes to the alternative investment fund code to transpose the EU’s Alternative Investment Fund Managers Directive II

JFSC feedback was published on 9 March following a recent consultation about changes to the JFSC's code of practice for AIFs and alternative investment fund services business, to align Jersey’s framework with AIMFD II.

The consultation also proposed splitting the code of practice into an EU‑focused code and a future UK‑focused code once the UK’s new approach to AIFMD is fully developed, recognising the regimes are diverging.

The JFSC received one response to the consultation, which confirmed the impact of these changes on Jersey businesses are not considered material.

Read the JFSC’s feedback: Feedback on changes to the alternative investment fund code to transpose the EU’s Alternative Investment Fund Managers Directive II.

AML / CFT / CPF Handbook update on complex structures and criminal background check

In November 2025, the JFSC published a follow-on consultation asking for industry feedback on proposals to split complex structures guidance in the AML / CFT / CPF Handbook into two parts.

In response to industry feedback, the JFSC have:

kept simple baseline indicators and clarified they are non-prescriptive
adjusted wording to reflect common Jersey structures
confirmed that complexity alone does not trigger high-risk classification or enhanced due diligence (EDD)
removed measures from the EDD section that were considered standard customer due diligence

Read the JFSC’s feedback: AML / CFT / CPF Handbook enhancements to complex structures.

Consultation on Article 36 guideline updates – Proceeds of Crime (Jersey) Law 1999

On 9 April 2026, the JFSC confirmed that they are reviewing the Schedule 2 framework alongside the Government of Jersey as part of its ongoing efforts to reduce regulatory burdens while maintaining high standards in combatting financial crime. For more detail, read our Channel Islands funds update: January 2026 edition.

To enable the JFSC to respond to this feedback, the JFSC will not be implementing the revised guidelines in April as originally planned. The Government of Jersey and the JFSC will consult on the proposed package of reforms after the upcoming election period.

Read the JFSC’s feedback statement: Feedback statement: Schedule 2 Guidelines

Consultation on amendments to the JFSC’s civil financial penalty methodology for registered persons

In connection with the coming into force of the Financial Services Commission (Financial Penalties) (Jersey) Amendment Order 2026, the JFSC are proposing consequential amendments to the registered persons methodology so that it reflects the amended legislative framework.

The JFSC are also taking this opportunity to make targeted updates to certain parts of the methodology in light of experience of applying the regime in practice.

The proposed updates include amendments that would:

provide clearer guidance on how voluntary reporting, and steps taken to rectify a contravention and prevent its recurrence, are considered, including when they may justify mitigation and reduce a penalty
address certain matters more expressly through dedicated steps within the methodology
include express reference to the guiding principle of having regard to the best economic interests of Jersey, by explaining how that principle may be engaged, where relevant, through the potential financial consequences step
provide more detailed guidance on settlement discounts

Responses must be submitted by 16:00 on 23 April 2026.

Read the JFSC’s full consultation on amendments to their civil financial penalty methodology for registered persons.

Government consultations

Civil financial penalties regime and natural persons

A consultation was issued by the Department for the Economy on 16 March 2026 and closed on 10 April 2026.

The Department for the Economy sought views on proposed changes to the maximum penalties that may be imposed on a natural person performing a regulated role under the Financial Services Commission (Financial Penalties) (Jersey) Order 2015, such as when acting either as a key person, principal person or within a senior management function.

It requested feedback on two alternative proposals, either to:

reduce the caps for band 1, 2, 2A and 3 contraventions
adopt a threshold linked to a percentage of the individual’s income, overlaid with maximum penalty caps as above

These proposals aim to:

make the system fairer
ensure Jersey complies with the Financial Action Task Force (FATF) recommendations, which require effective, dissuasive and proportionate sanctions

Read the Department for Economy’s consultation paper: Consultation document on civil financial penalties regime and natural persons.

Money Laundering Compliance Officer role

The Government of Jersey issued a consultation paper in January 2026 on proposed changes to the Money Laundering (Jersey) Order 2008, in respect of the Money Laundering Compliance Officer (MLCO) role.

The paper asks for views on four proposals:

make sure the MLCO is appointed at management level
separate the MLCO’s “responsibility” from their “function”
use a risk-based approach when appointing an MLCO
allow corporate MLCO appointments, with limits

The consultation closed on 13 March 2026.

Read the Government of Jersey’s consultation paper on the role of the MCLO.

Reform of Jersey’s reliance framework

The Government of Jersey also issued a consultation paper in January 2026 on proposed changes to the Money Laundering (Jersey) Order 2008 (MLO) in respect of the reliance regime.

The proposals are to:

allow firms to rely on a third party if that party is regulated by the JFSC (and "an equivalent jurisdiction" – to be defined) and gives written assurances
allow reliance on information about the purpose and nature of a business relationship
add clear rules that require firms to manage higher-risk countries with strong group-wide controls
extend the definition of "financial group" to include Designated Non-Financial Businesses and Professions (DNFBPs)
update the MLO to better match FATF standards

The consultation closed on 13 March 2026.

Read the government’s reform of Jersey's reliance framework consultation paper.

Countries and territories in AML / CFT / CPF Handbook appendices updated

On 13 February 2026, the JFSC updated appendix D1 of the JFSC’s AML / CFT / CPF Handbook in response to the latest FATF statements of 13 February 2026.

To see what has changed in respect of appendix D1, go to Appendix D1 – Countries and territories for which a FATF call for action applies.

On 10 April 2026, The JFSC updated appendix D2 of the JFSC’s AML / CFT / CPF Handbook to support industry when identifying any countries, territories and areas linked with higher risks of money laundering, financing of terrorism, financing of proliferation of weapons of mass destruction and sanctions.

To see what has changed, read the JFSC's amendments log.

New JFSC FAQs published to support firms with common authorisations queries

On 30 March 2026, the JFSC published a set of frequently asked questions to help regulated firms find clear answers to common questions the Central Authorisations team receive.

Read the new FAQs.

JFSC sustainable finance guidance

On 9 April 2026, the JFSC published its sustainable finance guidance note which will support firms in meeting their obligations under the codes of practice in relation to sustainability-related risks and sustainability-related claims.

The guidance sets a clear and consistent baseline on:

identifying, assessing and managing sustainability related risks, with a particular focus on climate change risks
ensuring that sustainability-related claims are fair, clear and not misleading

This guidance applies to all registered persons governed by the codes of practice.

Read the JFSC’s full sustainable finance guidance note.

This guidance, together with the change related to Principle 7 in the codes of practice, will take effect in Q1 2027, giving firms a sufficient transition period to prepare.

JFSC thematic review

On 20 January 2026, the JFSC announced that it will be conducting thematic reviews in two areas – customer exemptions from CDD requirements and customer complaints.

The CDD exemption review is said to have been driven partly by comments made during the Moneyval inspection regarding the inappropriate use of Articles 17B-D and 18 of the Money Laundering (Jersey) Order 2008 and the complaints review by the competitiveness agenda.

Read the JFSC's examination programme 2026.

JFSC reports

To support planning, the JFSC is now publishing quarterly updates which look ahead to important upcoming publications and updates, including consultations and feedback, examinations, data collections and legislative and policy updates.

Read the JFSC quarterly update – Q2 2026.

Over the last quarter, the JFSC has also published the following reports:

New strategy and business plan focused on economic growth

The JFSC's new 2026 – 2030 strategy and 2026 – 2027 business plan, launched 23 March 2026, is designed to enable growth through proportionate, risk-based regulation and improved service, while maintaining high standards. The JFSC will continue to regulate independently in the public interest to protect consumers and safeguard Jersey’s reputation.

The JFSC's vision is to be a trusted regulator and registry enabling Jersey’s economic growth vision through four priorities:

support growth, by collaborating with government and industry, modernising Jersey’s regulatory framework and registry service, and promoting innovation
be risk-based and proportionate, through improved systems, intelligence and targeted interventions
combat financial crime, by maintaining international standards and enhancing fraud prevention
deliver excellent service, by improving digital and in-person experiences, operational efficiency and service culture

The JFSC's business plan shares the actions it will take to implement the first two years of its strategy, including:

simplifying and modernising its regulatory framework
progressing delivery of the registry of the future
a data and intelligence-led approach to supervision
investment in its digital channels and user experiences

Read the JFSC’s 2026-2030 strategy.

Read the JFSC’s 2026-2027 business plan.

JFSC’s 2025 end of year service report

In 2025, the JFSC introduced several improvements across its registry and regulatory services that make it easier for industry to work with them. Their focus has been on reducing delays, improving accuracy and providing a smoother overall experience.

Read the JFSC’s service report Q4 2025.

JFSC's aggregated supervisory risk data reports

The JFSC has published annual supervisory risk data reports showing aggregated data for trust company business, investment business, banking, legal and funds sectors to:

provide a general overview on each sector
improve the understanding of money laundering and terrorist financing risks across different sectors

Read the JFSC's aggregated supervisory risk data.

Guernsey developments

Guernsey investment statistics

The Guernsey Financial Services Commission (GFSC) has published its investment statistics for the fourth quarter of 2025.

The total net asset value (NAV) of Guernsey funds has remained unchanged from the previous quarter and stands at £272.8 billion.

Within this total, Guernsey-domiciled open-ended funds increased over the quarter by £1.6 billion (+3.4%) to £48.4 billion, whereas Guernsey closed-ended funds decreased over the quarter by £1.6 billion (-0.7%) to £224.4 billion. The NAV of Guernsey sustainable funds remains unchanged at £4.5 billion.

See the statistics in full: Investment Statistics Summary — Fourth Quarter 2025 — GFSC

Guernsey Court of Appeal judgment: GFSC v Weighbridge Trust Limited

On 19 March 2026, the Guernsey Court of Appeal handed down a judgement in GFSC v Weighbridge Trust Limited [2026] GCA016 relating to the GFSC's powers to issue public statements regarding contraventions by licensees and certain other persons pursuant to section 38 of the Financial Services Business (Enforcement Powers) (Bailiwick of Guernsey) Law, 2020.

The Court of Appeal set aside the Royal Court of Guernsey’s first instance decision, reinstating the GFSC’s public statement. In doing so, the Court of Appeal addressed issues of wider significance as to:

the proper approach of the Royal Court in exercising its appellate function in relation to decisions made by the the GFSC
the basis on which the GFSC may exercise its power to issue a public statement following findings of regulatory breaches by a licensee

The Court of Appeal found that:

the GFSC’s public statement was lawful and reasonable
the correct appellate test is whether the regulator’s decision was outside the range of reasonable decisions open to the regulator, not whether the court itself would have decided differently
the Royal Court has no power to substitute its own evaluation for that of the GFSC's unless a statutory ground for appeal is clearly met

The judgment confirms the primacy of the regulator’s expert evaluative decision-making within its statutory discretion and the limits of the Royal Court’s appellate function in financial services regulatory matters.

This is the third Court of Appeal case in the last two years dealing with appeals from the Royal Court arising from decisions of the GFSC, after GFSC v Domaille and others [2024] GCA003 and GFSC v Fuller and others [2025] GCA071.

Read the full judgment:

Guernsey Financial Services Commission V Weighbridge Trust Limited

Citywealth Powerwoman recognition for GFSC Deputy Director General

The GFSC's Deputy Director General (Policy and Supervision), Gillian Browning, has won a top Citywealth Powerwoman Award: the 2026 Global Standard Bearer for Women in Wealth.

Gillian played a key role in driving last year's improvements to the GFSC's innovative Private Investment Fund (PIF) regime and was instrumental in establishing its Digital Forum which promotes broad industry engagement with the policy elements of the GFSC's Digital Finance Initiative.

Insurance industry fee reduction for 2027

The GFSC has announced its intention to discount insurance industry fees for 2027 by 15-20%, following the imposition of a record £1.96 million fine on an insurance licensee.

This decision is in accordance with legislative requirements to use surplus fine income to reduce future industry fees. Around 40% of the fine income, exceeding the GFSC's enforcement costs, will be allocated to discount these fees.

All insurance licencees can expect this reduction in their 2027 fees and new insurance licensees authorised after 15 March 2026 will also benefit from a 15% discount on their pro-rata annual fee.

The exact discount rate to be applied will depend on factors such as the number and size of insurance firms as at Q3 2026 when an annual fee consultation will take place.

Updates to the AML / CFT / CPF Handbook

On 4 March 2026, the GFSC updated the Handbook to add Kuwait and amend Papua New Guinea’s entry on the Appendix I list of higher risk jurisdictions following the Financial Action Task Force’s (FATF) decision to include them in its list of jurisdictions under increased monitoring.

The GFSC advises licensees that the presence of a jurisdiction on Appendix I does not automatically classify all related business relationships as high risk. Licensees should assess the nature and significance of the jurisdictional link, considering its overall impact alongside other risk factors such as customer profile, activities and the source of wealth or funds.

The clean and tracked versions of the Handbook can be accessed via the Handbook page and Appendix I is available on the Notices, Instructions and Warnings page.

More about the FATF’s list of jurisdictions under increased monitoring: High-risk and other monitored jurisdictions.

Registration of Guernsey's first Natural Capital Fund

In February 2026, the GFSC registered the island’s first Natural Capital Fund, marking a key step in Guernsey’s support for nature-focused sustainable finance.

The Natural Capital Fund regime provides a regulated designation for funds investing in initiatives that benefit the natural environment or reduce harm to it. This sits within the broader Guernsey Sustainable Funds framework, alongside the established Guernsey Green Fund regime.

The newly registered fund will invest in large-scale habitat creation and ecological restoration projects known as “habitat banks” which help organisations comply with England’s 2024 biodiversity net gain regulations and support the restoration of biodiversity on a significant scale.

The development responds to increasing demand for nature-focused investments.

For more information on Natural Capital Funds, read our guide: At a glance guide to Guernsey Natural Capital Funds.

GFSC Policy Statement on the use of artificial intelligence

In January 2026, the GFSC published a policy statement confirming its position on the role of AI in the Guernsey financial services sector.

The GFSC has made clear that it supports the adoption and use of various AI tools by firms to improve services, provided they take into account the principles of the Finance Sector Code of Corporate Governance.

In particular, the GFSC asks firms to consider the principles relating to accountability and risk management and the Minimum Criteria for Licensing as set out in the relevant regulatory laws.

The GFSC does not propose on introducing specific rules or guidance in relation to the use of AI nor is it prescribing accreditation or certification to any particular standard. However, where firms are uncertain as to how best implement these emerging technologies, it may be helpful to consider existing AI frameworks and guidance such as the IST AI Risk Management Framework, ISO / IEC 42001, or the NCSC Guidelines.

Read the GFSC’s Policy Statement – Use of Artificial Intelligence.

GFSC Digital Forum roundtable on stablecoins

The GFSC's next Digital Forum roundtable session to be held on 12 May 2026 will focus on stablecoins.

Aiming to build on industry feedback received through the GFSC's Digital Finance Initiative consultation earlier this year and previous Digital Forum roundtables, this roundtable will explore issues such as:

the economic and regulatory implications of different stablecoin models, including fiat-backed and commodity-backed stablecoins
if and how yield-bearing structures might operate
how these models interact with existing financial and regulatory frameworks

The session will be hosted on Tuesday 12 May at 09:30 at the GFSC's office in Regency Court. Those wishing to attend can register for a place via the GFSC's Engagement Hub: Digital Forum to host roundtable on stablecoins — GFSC

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