Channel Islands funds update: January 2026

In our latest Channel Islands funds update, we round up recent legal and regulatory developments in Jersey and Guernsey.

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Pan-island developments 

Jersey investment statistics 

In September 2025, the Jersey Financial Services Commission (JFSC) announced that it will transition from a quarterly to an annual reporting cycle for fund statistics. Therefore, no fund statistics will be reported this quarter. The JFSC will confirm the reporting date for the new annual cycle in due course, as part of the JFSC's supervisory risk data collection update. 

Read the JFSC‘s statement.

Guernsey investment statistics 

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

While the total net asset value (NAV) of Guernsey funds has decreased over the past year, the third quarter marked an increase of £1.9 billion (+0.7%) to a total NAV of £272.8 billion. 

Within this total, Guernsey-domiciled open-ended funds increased over the quarter by £2.5 billion (+5.6%) to £46.8 billion, whereas Guernsey closed-ended funds decreased over the quarter by £0.6 billion (-0.2%) to £226 billion. The NAV of Guernsey green funds remains unchanged at £4.5 billion. 

See the statistics in full:

Investment Statistics Summary —Third Quarter 2025 — GFSC

Jersey developments 

Government of Jersey launches new Innovation Council

The Government of Jersey (the government) has launched a new Innovation Council, a forum designed to help Jersey’s financial services industry remain at the forefront of emerging technologies and drive opportunities in the digital assets market. 

The Innovation Council will include technology and financial industry experts, as well as JFSC representatives, who will explore how Jersey can encourage innovation while maintaining its reputation for robust regulation.  

This initiative forms part of Jersey’s government-led Competitiveness Programme, which is aimed at strengthening Jersey’s financial services sector. 

Industry participants and technology specialists interested in joining the Innovation Council should email growthfs@gov.je by Friday 30 January 2026.

COBO Framework Consultation Feedback Paper published 

The government published a Consultation Feedback Paper in November 2025 regarding the public consultation on the Control of Borrowing framework (COBO Framework). 

The paper confirmed that the consultation responses supported the repeal of the COBO Framework. It also confirmed that replacement mechanisms are needed in some areas. 

The feedback received is summarised within the publication together with the government policy position in relation to the various areas of the framework that need to be reviewed. 

Read the feedback paper in full: 

Consultation Feedback Paper: repeal of the control of borrowing framework 

Implementation date for AML / CFT / CPF Handbook enhancements 

On 12 November 2025, the JFSC announced that the implementation date for the proposed enhancements to the AML / CFT /CPF Handbook, including requirements for enhanced criminal background checks, has been deferred to 31 May 2026. 

This extension provides additional time for industry to prepare for the updates. 

Feedback on enhancements to criminal background checks and feedback on enhancements to the AML / CFT / CPF Handbook were published at the end of November.

For criminal background checks, following industry feedback, the JFSC removed the three-year rolling refresh requirement and confirmed that supervised persons are now responsible for collecting and maintaining records. 

In a follow-up consultation paper, the JFSC is also seeking feedback on proposals to split complex structures guidance into two parts within the Handbook. Comments must be submitted by Thursday 12 February 2026.

A drop-in session is scheduled at Town Hall, St Helier at 12:00 on 20 January 2026. Register now via Eventbrite to secure your place. 

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

On 8 December 2025, the JFSC published a consultation detailing proposed updates to guidelines on interpretation of Article 36 of the Proceeds of Crime (Jersey) Law 1999. The updated guidelines address areas of improvement highlighted by industry feedback. 

The updates aim to: 

• enhance clarity and usability
• promote consistent interpretation across industry
• maintain Jersey’s alignment with international standards while ensuring the guidelines are proportionate and practical 

Read the full consultation.

Feedback must be submitted online by 17:00 on Friday 30 January 2026. 

Civil financial penalties regime – consultation and interim approach

On 16 December 2025, the government issued a consultation on the civil financial penalties regime in respect of proposed changes that may be imposed on a registered person in Jersey under a Financial Services Commission (Financial Penalties) (Jersey) Order 2015.

Feedback is sought on three proposals:

• to increase the cap of £100,000 for Band 1 contraventions
• to restore a cap of £4 million for Band 2 and 2A contraventions
• to retain current position of there being no cap for the most serious contraventions, which fall under Band 3 

The proposals are intended to ensure that Jersey maintains compliance with Financial Action Task Force recommendations.  

The consultation closes on 30 January 2026.  

To ensure fairness for parties currently undergoing a sanction process where civil financial penalties are being considered, the JFSC will pause progressing these cases until there is clarity on any proposed changes.

The JFSC will also consult on updates to its published methodology, reflecting its experience of applying the current approach over the past three years.

Further details on the consultation process will be shared by the JFSC in due course. 

Sound Business Policy – updated registry forms now available 

On 1 November 2025, the JFSC launched the new Sound Business Policy (SBP) in collaboration with the government and industry stakeholders to improve clarity, usability and efficiency. 

Registry forms have been updated to align with the new SBP and are available on myRegistry. 

Read our briefing summarising the key changes to the policy: 

Snapshot: New Sound Business Policy in Jersey

Companies (Jersey) Amendment Law 202-

On 21 November 2025, the Companies (Jersey) Amendment Law 202- was lodged with the office of the Greffier and the earliest date for debate is 20 January 2026.

This draft law makes amendments to the Companies (Jersey) Law 1991 (the CJL). Rather than a wholesale restatement or significant policy change, the proposed amendments are largely technical or clarificatory in nature and are aimed at maintaining the flexibility of the CJL in an appropriate and legitimate framework.

There are seven principal themes: flexibility, clarification, simplification, digital enhancements, enhancing competitiveness, ensuring compliance with the sanctions regime and looking at certain clarifications to the insolvency provisions. The proposals respond to case law and other legal developments, and developing industry practice, both domestically and internationally. 

Read the draft law in full: 

Draft Companies (Jersey) Amendment Law 202-

JFSC 2025 industry survey report  

On 13 November 2025, the JFSC published the 2025 industry survey report which shares the results of its 2025 industry survey, the JFSC's progress in responding to the 2024 survey, and the JFSC’s next steps.

While the JFSC has made progress through its previous industry survey action plans, it is clear that a strategic response is required to address recurring themes of competitiveness and engagement.

Read the the full 2025 industry survey report.

JFSC feedback – conflict of interest thematic examination

On 28 November 2026, the JFSC published feedback from its conflicts of interest thematic examination. The thematic examination focused on compliance with obligations in relation to the: 

• adequacy of policies and procedures for identifying and managing conflicts of interest
• accuracy of the records maintained
• firm’s understanding of conflict risk in their business
• board’s oversight of the compliance function and the effectiveness of managing conflict risk
• independence of key persons
• staff awareness of their responsibilities to disclose and manage conflicts of interest

Read the 2025 conflicts of interest examination feedback.

Updated Travel Rule guidance for virtual asset service providers

On 14 November 2025, the JFSC updated its Travel Rule guidance note to reflect maturing global standards and insights from the JFSC’s 2024 Travel Rule examinations with Jersey virtual asset service providers (VASPs).

By way of background, the Financial Action Task Force has called on jurisdictions to swiftly implement its ‘Travel Rule’, which requires transfers of virtual assets to be accompanied by accurate originator and beneficiary information. The European Union (EU) Legislation (Information Accompanying Transfer of Funds) (Jersey) Regulations 2017 (Wire Transfer Regulations) were amended on 1 September 2023 to include Virtual Asset Service Providers (VASPs) and the Wire Transfer Regulations apply EU Regulation 2015/847 in Jersey. This regulation sets out rules for including payer and payee information with fund transfers. 

Updates to the JFSC’s guidance include additional detail for intermediary VASPs to provide clarity under different service models and reinforce expectations, so that Jersey remains among the most advanced jurisdictions for Travel Rule implementation.

The updated guidance helps VASPs stay aligned with international best practices. 

Access to beneficial ownership information by persons with legitimate interest 

On 31 October 2025, the Department for the Economy issued a consultation on the proposal to extend access to the central register of beneficial ownership to persons who can demonstrate a legitimate interest in accessing beneficial owner information for the purpose of preventing, detecting or investigating money laundering, terrorist financing and proliferation financing. The deadline for comments is close of business on 30 January 2026. 

Draft Taxation (Implementation) (International Tax Compliance) (Common Reporting Standard) (Jersey) Amendment Regulations 202- 

On 29 December 2025, the Draft Taxation (Implementation) (International Tax Compliance) (Common Reporting Standard) (Jersey) Amendment Regulations 202- was lodged with the office of the Greffier and the earliest date for debate is 20 January 2026. 

The regulations, if approved, will amend the Taxation (Implementation) (International Tax Compliance) (Common Reporting Standard) (Jersey) Regulations 2015 to refer to the amended Organisation for Economic Co-operation and Development (OECD) Common Reporting Standard. The proposed regulations also aim to avoid duplicative reporting of information in respect of gross proceeds from the sale or redemption of a financial asset that a financial institution has reported under the Taxation (International Tax Compliance) (Crypto-Asset Reporting Framework) (Jersey) Regulations 202-. 

Jersey to adopt OECD CARF 

The Draft Taxation (International Tax Compliance) (Crypto-Asset Reporting Framework) (Jersey) Regulations 202- was lodged with the office of the Greffier on 29 October 2025 and the earliest date for debate is 20 January 2026. 

The Crypto-Asset Reporting Framework (CARF) introduces new requirements for Reporting Crypto-Asset Service Providers including additional due diligence and the reporting of certain crypto-asset transactions to Revenue Jersey. 

These regulations, if approved, will allow for the implementation of the Organisation for Economic Co-operation and Development’s Crypto-Asset Reporting Framework into Jersey law. 

UK moves to a single sanctions list on 28 January 2026 

From 28 January 2026, the current UK Sanctions List (UKSL) will serve as the sole authoritative source for all UK sanctions designations. The Office of Financial Sanctions Implementation (OFSI) Consolidated List will be retired along with its search tool. 

UK asset-freeze designations are effective immediately in Jersey. Supervised persons should therefore update their systems and controls to adapt to these changes to ensure continued compliance with sanctions obligations. 

For more guidance, please refer to the Government of Jersey’s Sanctions Update and the UK Guidance on Moving to a Single List. 

Guernsey developments 

Consultation on supporting growth with digital finance 

As part of the Digital Finance Initiative (covered in our previous update), the GFSC has published a consultation paper on its proposed amendments to the regulatory framework aiming to support the growth of the digital finance sector. This includes tokenisation, stablecoins, digital custody and insurance, and the use of technology more broadly within the finance sector. The objective is to provide a greater degree of regulatory flexibility as well as certainty, by applying consistent regulation to activities which present equivalent risks.

The existing framework already lends itself to a pragmatic and holistic regulatory approach, as there are no separate legal definitions for the different types of virtual assets and therefore no distinction between asset, investment or security tokens or coins. Instead, regulation could be based on how tokens or coins are used, rather than how they are described or textually referred to. 

Key areas to watch include: 

VASP reform 

• Removal of the blanket requirement for existing licensees to have to apply for an additional VASP licence. Going forward, there may be instances where an exemption from dual licensing may be appropriate, a notable example being custody, which is explained below 
• Lifting the restriction which currently prevents VASPs from offering services to retail customers. This proposal paves the way for a potential parallel between the regulation of VASP activity and cryptocurrency funds, given that last year the GFSC opened the doors for retail investors to be able invest in cryptocurrency funds 
• Clarity on when certain support services may be subject to VASP regulation, such as blockchain, distributed ledger technology, mining, node validation and providing advice in relation to digital assets 
• Possibility for prospective VASP licensees to move straight to a standard licensing process without the expectation to initiate a dialogue with the GFSC prior to submitting an application 

Custody of digital assets 

• Licensed custodians under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 (as amended) (the POI Law) would be able to provide custody of digital assets without needing a separate VASP licence, although the custodian may be required to comply with certain VASP rules on safekeeping of customer virtual assets 
• Safekeeping only of digital assets which do not constitute category one or two controlled investments under the POI Law is a licensable activity under the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022 (as amended) (the LCF Law)
• Trustees licensed under the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 (as amended) are responsible for safeguarding digital trust assets in the same way as any other trust property and do not require any additional VASP or POI Law licences 

Bailiwick licensed stablecoins 

• Introduction of "licensed stablecoins" issued in the Bailiwick of Guernsey by persons licensed by the GFSC, with specific requirements for both the issuer and the rights in respect of the coins themselves 
• Distinction between digital assets which are used as a means of payment and those used for investment purposes, with "licensed stablecoins" being those used as a means of payment and fully backed by sufficiently liquid assets in the currency against which they are pegged. The treatment of alternative stablecoins, such as commodity backed stablecoins, would depend on the nature of the underlying asset or commodity, meaning they may be considered to be either tokenised securities (see below) or virtual assets in their own right 
• Persons conducting regulated activities under the LCF Law in relation to "licensed stablecoins" would not be required to hold VASP licences, but may be considered to be acting as financial firm businesses within the meaning of the LCF Law 

Tokenised securities reform 

• Where a token conveys ownership or rights consistent with the definition of a category 2 controlled investment (general securities or derivatives) under the POI Law, it would be treated as such and regulated in accordance with the POI Law. As mentioned above, commodity backed stablecoins would be regulated as tokenised securities if they constitute a category 2 controlled investment 
• Where a token does not meet the definition of a controlled investment under the POI Law and is not issued by an intermediating entity holding a real world asset, it would likely meet the definition of a virtual asset and therefore fall within scope of the LCF Law and VASP licensing 
• Revision of the GFSC's policy statement on fund tokenisation to allow the use of a public blockchain as the register of fund unitholders in a Guernsey registered or authorised collective investment scheme. The use of private blockchain is already permitted under the current position 
• Revision of the Handbook to provide clarity around the acceptability of using certain technologies as part of a firm's compliance processes, such as electronic verification, AI, distributed ledger technology and blockchain analytical tools 

The proposals reflect stakeholder engagement received at the GFSC's Digital Forum roundtables and are designed to complement the new Innovation Sandbox and Concierge service. 

The consultation on the above proposals closes on 6 March 2026. Responses can be submitted via the GFSC's Engagement Hub, by email to dfi@gfsc.gg or, if helpful, by discussion in person. 

Updated GFSC fees for 2026

Following its consultation last year, the GFSC has confirmed an overall fee increase of 3.9%, aligned with Guernsey mid-year RPI, from 1 January 2026 under the Financial Services Commission (Fees and Administrative Penalties) Regulations, 2025. Notably, the following changes are now in effect: 

• the fees for VASP private investment fund applications have been reduced 
• designated administrator fees have been increased and a higher maximum band for private investment funds has been created 
• a banded fee system has been implemented for prescribed businesses 
• fiduciary licence fee bands have been adjusted 
• new fees have been introduced for certain requests requiring GFSC approval, however not all the fees initially proposed during the consultation have been implemented 

Also with effect from 1 January 2026, the fee payable to the GFSC under the Limited Partnerships (Guernsey) Law, 1995 (as amended) (the LP Law) in relation to an application to obtain the GFSC's consent for a supervised limited partnership to be removed from the Guernsey Register of Companies has been increased to £3,065. 

The GFSC will be distributing 2026 annual fee invoices via email to each licensee and registrant. Read more information on the invoices and related timings: Distribution of Annual Fee Invoices and Generic Email Addresses — GFSC.

Updated Guernsey Registry fees 2026

Companies

The Companies (Registrar) (Fees and Penalties) (Amendment) Regulations, 2025 came into force on 1 December 2025, resulting in the following increased fees: 

• company annual validation fees (increased based on RPI as at 31 December 2024) 
• migration out, amalgamation and restoration fees 
• rapid (two hour) and special (15 minute) company incorporation fees 
• standard and certified documents orders and enquiries 

There are no changes to the standard 24-hour company incorporation fee or the migration in fee. 

Limited partnerships 

The Limited Partnerships (Fees) (Amendment) Regulations, 2025 also came into force on 1 December 2025, resulting in the following increased fees: 

• limited partnership annual validation fees 
• migration out fees 
• rapid (two hour) limited partnership registration fee 
• standard and certified documents orders and enquiries 
• filing of a notice of change of the registered particulars or general partners, with different fees applicable for different particulars. For a change in more than one registered particular of the limited partnership, the total fee payable is the sum of each of the applicable fees specified in the regulations. 

There are no changes to the standard 24-hour registration or the migration in fees. 

Limited liability partnerships 

For limited liability partnerships, the following fees have been increased from 1 December 2025 under the LLPs (Fees) (Amendment) Regulations, 2025 and the LLPs (Registrar) (Fees and Penalties (Amendment) Regulations, 2025:

• limited liability partnership annual validation fee 
• rapid (two hour) incorporation fee 
• restoration fee 
• application fee for removal from the Guernsey Register on migration out of Guernsey 
• fees for a change of the registered particulars, with different fees applicable for different particulars 
• standard and certified documents orders and enquiries 

There are no changes to the standard 24-hour incorporation, conversion to a limited liability partnership or migration in fees. 

His Majesty's Procureur fees 

Under the Companies (Registrar) (Fees for Migrations) (Amendment) Regulations, 2025, the fee payable to His Majesty's Procureur for the migration of supervised and non-supervised companies out of Guernsey has also been increased from 1 January 2026. 

TISE fees 

The International Stock Exchange (TISE) has updated its fees with effect from 1 January 2026 for both Equity Market Listings (see the full fees and charges schedule) and Qualified Investor Bond Market Listings (see the full fees and charges schedule). Trading fees remain unchanged. 

ODPA fees 

Persons and entities that process personal data within the meaning of the Data Protection (Bailiwick of Guernsey) Law, 2017 must register or renew their registration by the end of February 2026. 

From 1 January 2026, the annual registration fees payable to the ODPA have been increased by 3.7% in line with Guernsey mid-year RPI: 

• £62.22 for organisations with fewer than 50 employees 
• £2,488.80 for organisations with 50 or more employees 

New regime for equity release in effect 

The new regulatory regime for equity release came into effect on 1 January 2026. 

Equity release is a financial product suitable for homeowners wishing to obtain a lump sum, drawdown or an income using the value tied up in their residential property, while continuing to live in the property. 

Under the new regime, firms can now apply for a licence, via the GFSC's Applications & Authorisations Portal, as an equity release provider or provider of services ancillary to equity release under Part II of the LCF Law. Those which already hold licences under the LCF Law do not need to make a full licence application but can instead apply to add equity release activity to their existing licence. 

Aiming to encourage entrants to the Guernsey market, the GFSC has announced that:

• application and annual fees for equity release providers will be discounted by 50% for the first three years of the regime 
• UK equity release providers authorised by the Financial Conduct Authority may, subject to a notification to the GFSC, be able to provide equity release to Guernsey customers without a licence, provided the customer is advised by a locally licensed adviser 

GFSC report on correspondent and intermediary relationships in the investment sector 

The GFSC has published its report following a thematic review on the effectiveness of investment firms’ monitoring of, and compliance with, the requirements in respect of intermediary relationships (section 9.8) and correspondent relationships (section 8.6) in the Handbook on Countering Financial Crime (Anti-Money Laundering / Countering the Financing of Terrorism / Countering the Financing of Proliferation of Weapons of Mass Destruction) (the Handbook).

In summary, the GFSC found that most firms had a good risk understanding of these types of relationships and appropriate controls, although risk mitigation programmes were imposed on some firms. 

Moreover, the GFSC identified six areas for improvement which all firms should take note of, summarised below, together with corresponding actions.

• Using the intermediary relationship provisions where this was not appropriate, such as when the regulated intermediary was not located in an Appendix C jurisdiction or not assessed as low risk 
• Risk assessments did not always specify the intended purpose and nature of the intermediary relationship, how they had discounted adverse information or why a low risk rating remained appropriate. In addition, some firms were unable to assign a low risk rating due to an internal mandate that no business relationship be rated low risk 
• Cases where no reference was made to the inherent risks associated with regulated intermediaries in the business risk assessments 
• Some written confirmations from regulated intermediaries did not contain all attestations required by Handbook rule 9.47 
• Most central securities depositories, such as Euroclear and Clearstream, are currently categorised by firms as intermediary relationships under section 9.8 of the Handbook when they are unable to provide the written confirmations required by Handbook rule 9.47 
• Instances of intermediary relationships not being tested as part of the compliance monitoring programme 

This is also an area where MONEYVAL had identified some weaknesses in the controls used by those operating in the investment sector in its mutual evaluation of the Bailiwick of Guernsey in 2024. The GFSC concluded that its findings, to some extent, support MONEYVAL's review. The GFSC will consider how firms have incorporated the findings from its report as part of its ongoing supervision and plans to conduct further outreach on this topic with the investment sector this year. 

Those operating in the investment sector are encouraged to review the full report: Correspondent & Intermediary Relationships Thematic - Dec 2025.

Anti-greenwashing guidance and updated Finance Sector Code of Corporate Governance 

The GFSC has published a feedback statement following its consultation and the feedback received on: 

• a new Guidance Note on Anti-Greenwashing, which clarifies existing obligations under the Minimum Criteria for Licensing 
  • this guidance will apply to all persons licensed under one or more of the supervisory laws 
  • the Minimum Criteria for Licensing includes a duty to act with integrity, probity, competence, experience and soundness of judgement. The GFSC has not expressly stated that this encompasses not engaging in, or otherwise knowingly facilitating, greenwashing 
• updates to the Finance Sector Code of Corporate Governance to reflect the growing importance of considering a wider range of environmental risks beyond climate change
  • companies subject to this code are broadly companies licensed under one or more of the supervisory laws or authorised or registered as collective investment schemes under the POI Law
  • boards will be required to consider broader environmental sustainability risks, including climate change and biodiversity. Notably, the objective is for boards to consider environmental matters holistically rather than focusing solely on net zero 

The new Guidance Note on Anti-Greenwashing (attached at Appendix 1 to the feedback statement) and the amended Finance Sector Code of Corporate Governance will come into force on 1 February 2026. 

Updates to the AML / CFT / CPF Handbook 

On 28 October 2025, the GFSC updated the Handbook to remove South Africa from the Appendix I list of higher risk jurisdictions, following the decision by the Financial Action Task Force (FATF) to remove it from its list of jurisdictions under increased monitoring. While the FATF has also removed Burkina Faso, Mozambique and Nigeria from its list of jurisdictions under increased monitoring, these remain on Appendix I due to being listed by other relevant external sources. 

The GFSC has advised that "a jurisdiction’s removal from Appendix I of the Handbook does not mean all business relationships connected to that jurisdiction should be assessed as having decreased in risk. Licensees should consider the nature and materiality of a jurisdictional link in their risk assessment, particularly where the change in the jurisdictional risk has little or no impact on other relevant risk factors within the business relationship, such as the type of customer, the customer or beneficial owner’s risk profile, activities, source of wealth and funds, or to the product or service offered by the licensee". 

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.

Launch of Financial Literacy Resources 

The GFSC has launched a Financial Literacy Resources webpage. It contains fact sheets and FAQs aimed at consumers and those wishing to develop an understanding of the economy, as well as financial, investment, pensions and insurance products.

The page has been created in partnership with EDUCFI, the French National Financial Literacy Strategy operated by Banque de France, the French central bank, to promote financial literacy through educational materials.