Emily Haithwaite
Group Partner, Ogier Legal L.P. | Legal
Jersey
Emily Haithwaite
Group Partner, Ogier Legal L.P.
Jersey
In our latest Channel Islands funds update, we round up recent legal and regulatory developments in Jersey and Guernsey.
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Figures collated by the Jersey Financial Services Commission (JFSC) for the period ending 30 June 2026 show robust growth across Jersey's funds sector. The total funds business in Jersey is valued at US$799.2 billion.
Regulated funds: the net asset value of regulated funds business administered in Jersey rose by 8.3% year on year to US$668.34 billion. Alternative asset classes make up 88% of the total. Private equity and venture capital funds account for 42% and real estate funds for a further 8.2%. The value of hedge strategies grew by 54% year on year.
Jersey Private Funds (JPFs): the JPF regime has continued to grow strongly following the enhancements made in 2025.
number of funds: the number of registered JPFs rose by 12.7%, from 754 to 850
unlimited investors: the 50 or fewer offer and investor cap was removed in August 2025, and 135 JPFs (almost 16% of all JPFs) already operate in the new “restricted offers” category
assets under management: JPF assets under management rose by 15.2%, from US$113.69 billion to US$130.91 billion
asset classes: private equity and venture capital remain the largest identifiable JPF investment strategies, at around 27% of all JPF assets. Assets under management grew particularly strongly in real estate JPFs (up 23.8%) and hedge JPFs (up 22.8%)
Emily Haithwaite, head of funds in Jersey, said: "The Jersey Private Fund continues to go from strength to strength. Within a year of the investor cap being removed, almost one in six JPFs is already using the unlimited investors category. That shows how well the 2025 enhancements have been received. With the JPF set to move onto a standalone statutory footing under the draft Financial Products and Prospectuses Law, the regime is well placed for further growth in 2027.''
For more information, read the JFSC figures – period ending 30 June 2026.
The total net asset value (NAV) of Guernsey funds was ÂŁ270.0 billion at 30 June 2026.
Open-ended funds: NAV of Guernsey-domiciled open-ended funds rose by 5.1% over the quarter to ÂŁ45.8 billion, up 3.5% year on year
Sustainable funds: Guernsey Sustainable Funds held ÂŁ4.3 billion of NAV at the end of the quarter
For further information, read the Guernsey Financial Services Commission (GFSC) investment statistics for the second quarter of 2026.
The draft Financial Products and Prospectuses (Jersey) Law 202- was lodged on 28 September 2026 for debate by the States Assembly from 10 November 2026. It will repeal the Control of Borrowing (Jersey) Law 1947 and the Control of Borrowing (Jersey) Order 1958 (COBO) and replace them with a new modernised regime for JFSC consent to relevant products, expected to come into force in mid-2027.
Key changes include:
Jersey Private Funds (JPFs): JPFs will have their own statutory footing and will expressly fall outside the Collective Investment Funds (Jersey) Law 1988. Standard JPF conditions, based on current conditions, will be set by Order. Existing JPFs and legacy (pre-JPF) private funds will be “grandfathered” into the new regime without any action being required.
digital asset issuers: the new law will also form the basis for the JFSC's licensing of digital asset issuers, with further secondary legislation in development.
prospectuses: JFSC consent will still be required to circulate an overseas prospectus to Jersey retail investors.
JFSC gatekeeping their powers: application to establish new entities will need to be made to the JFSC Registry as currently, though this requirement will be moved into the relevant “product” law (such as the Companies (Jersey) Law 1991).
activity information: legal entities will need to provide the JFSC with updated information on the nature of the activities they undertake. This information is intended to be generic rather than specific and will fall within the existing regime under the Financial Services (Disclosure and Provision of Information) (Jersey) Law 2020 (or the Limited Partnerships (Jersey) Law 1994 for limited partnerships formed under that law).
additional classes of trust company business: for practical purposes, acting as a registrar of a company, limited liability company or limited liability partnership will be expressly referred to within the definition of trust company business in the Financial Services (Jersey) Law 1998. Firms permitted to perform this function already will have their registrations automatically extended to include the new class.
Ogier has been heavily involved in the development of this modernised regime, and we will be happy to discuss any questions on its impact.
Read the Financial Products and Prospectuses (Jersey) Law 202-
Two orders came into force on 30 September 2026 that narrow when a Jersey company needs a prospectus for an offer made outside Jersey:
narrower definition of "prospectus": only people in Jersey are now counted. An offer is not a prospectus if it is made to 50 or fewer people in Jersey, not counting qualified investors or professional investors. The separate limit of 150 people outside Jersey has been removed.
no registrar consent for offers outside Jersey: a company that circulates a prospectus outside Jersey no longer has to file it with the registrar or get the registrar's consent. These requirements now apply only where a prospectus is circulated in Jersey.
These changes are welcome. They further limit when a prospectus is required and bring Jersey into line with other jurisdictions. Jersey's rules now focus on protecting retail investors in Jersey, and investors in jurisdictions outside Jersey will avail of local legislative protections.
For more information, read the Companies (General Provisions) (Jersey) Amendment Order 2026 and the Companies Law (Jersey) Amendment Order 2026.
As mentioned in our April update, two changes under the order will take effect on 31 October 2026:
Money Laundering Compliance Officer: businesses will be able to take a risk-based approach when appointing a Money Laundering Compliance Officer. This change will take effect once the AML / CFT / CPF Handbook has been updated.
reliance framework: the changes to the reliance framework, which are already set out in the Order, will also take effect.
For more information, read the Money Laundering (Jersey) Amendment Order 2026.
A Practice Direction setting out the procedure for applying for an administration order was published and took effect on 4 August 2026. For more information on Jersey's new corporate administration regime, read our client advisory: Jersey introduces new corporate administration regime.
For more information, read the full Applications for an Administration Order and Procedure for Administration Order Searches.
On 12 October 2026, the JFSC confirmed that it will update its guidance on limited liability companies (LLCs) following consultation. The aim is to make LLCs easier to use across a wider range of regulated activities. The main changes are:
LLCs will be able to act as trustees
LLCs can be used for specified financial services activities
restrictions limiting LLCs to financially sophisticated investors or customers will be removed
the guidance will be clearer and easier to apply
The updated guidance and registry arrangements took effect on 14 October 2026.
Read the JFSC feedback on limited liability companies guidance.
On 14 July 2026, the JFSC published new guidance to help Jersey financial services firms use artificial intelligence responsibly and with confidence.
For more information, read the full guidance.
On 29 July 2026, the JFSC launched a consultation on its proposed fees for 2027. It did not propose any substantive changes to its fee structures. The consultation closed on 31 August 2026. On 1 October 2026, the JFSC published its feedback paper. In response to industry feedback and greater certainty from its updated 2027 financial planning, the JFSC decided to increase most fees by 3.0% rather than 3.5%. The other proposals were confirmed:
there will be no increase to late payment, late filing or late submission fees
there will be no increase to the Government of Jersey levy payable with annual confirmation statements
a small number of lower-value registry fees that have not been reviewed for several years will increase
The 2027 fees notice will apply from 1 January 2027
On 31 July 2026, the JFSC announced changes to its “continuance in” process for companies moving to Jersey from another jurisdiction. The changes are intended to make applications simpler and to reduce delays caused by missing or incorrect documents. The main changes are:
single form: applicants now only need to complete the company incorporation form on myRegistry. The form has a new “continuance in” tab for all the required information.
single payment: a new “SLA 5-day Continuance In” fee option can be selected within the incorporation form, so there are no longer duplicate payments or refunds.
documents uploaded within the form: the separate submission uploader is no longer used. Documents are uploaded directly to the "continuance in" tab, with a separate upload field for each. Only mandatory documents are required.
clearer document guidance: the JFSC has published a new webpage and checklist setting out which documents are required. It has also confirmed that a company's current Memorandum and Articles may be certified by an appropriately authorised person in the company's current jurisdiction.
automatic certificate: once an application is approved, the applicant will automatically receive the continuance in certificate and Control of Borrowing Order consent. The certificate will also be available on the Register straight away.
Read more on how the JFSC has streamlined the "continuance in" process.
On 24 September 2026, the JFSC published an industry update confirming the two themes for its 2027 thematic examination programme:
customer risk assessments: onsite examinations will take place in the first half of 2027. The JFSC will review how firms assess customer risk, with the aim of identifying trends, highlighting good practice and sharing observations to help firms improve their approach.
beneficial ownership and control: onsite examinations will take place in the second half of 2027. The focus will be on how firms understand complex structures and identify individuals who exercise control by other means.
The JFSC has noted that transparency of beneficial ownership is central to Jersey's framework for anti-money laundering (AML), countering the financing of terrorism (CFT) and countering proliferation financing (CPF). The 2024 MONEYVAL Mutual Evaluation Report identified complex structures and control by other means as areas needing further supervisory focus.
Read more about the JFSC’s 2027 thematic examination programme.
On 30 July 2026, the JFSC published a feedback paper on its 2025 thematic examination of outsourcing. The examination looked at whether firms had adequate systems and controls, including policies and procedures, to meet the requirements of the JFSC's outsourcing policy.
Overall, the JFSC found that compliance was generally acceptable. However, it found the following issues at some firms:
activities not notified: some outsourced activities fell within the outsourcing policy but had not been notified to the JFSC.
contingency plans: some contingency plans were inadequate or had no evidence of regular testing.
policies and procedures: some firms relied on group outsourcing procedures that had not been tailored to the specific requirements of the outsourcing policy.
suspicious activity reporting (SAR): some firms could not show that they had told their outsourced service providers about SAR obligations.
material changes: some firms did not notify the JFSC of a material change to an outsourcing arrangement.
Read the JFSC feedback on outsourcing examination.
Since 10 August 2026, the JFSC no longer sends separate sanctions email alerts. Government of Jersey sanctions notices are now the single source of this information. You can register to receive Government of Jersey sanctions notifications.
For more information, read the JFSC's changes to sanctions email alerts.
The Financial Penalties Order came into force on 1 September 2026. It amends the Financial Services Commission (Financial Penalties) (Jersey) Order 2015 and extends the JFSC's civil financial penalties regime to more individuals.
Previously, penalties could only be imposed on registered persons and principal persons. The JFSC can now also impose penalties on key persons and on individuals who perform, or have performed, a senior management function.
key persons and senior managers: the maximum penalty is ÂŁ100,000 for a Level 2A contravention and ÂŁ200,000 for a Level 3 contravention. These individuals cannot be penalised for Level 1 or Level 2 contraventions.
principal persons: the maximum penalties are ÂŁ5,000, ÂŁ100,000, ÂŁ150,000 and ÂŁ250,000 for Level 1, 2, 2A and 3 contraventions respectively.
individuals in both roles: where an individual is both a key person and a principal person, the JFSC can impose a penalty up to the higher maximum that applies to principal persons.
The JFSC has updated its guidance to explain what it will include in a public statement when it imposes a civil financial penalty on a firm. Each public statement will:
show the intermediate penalty figure reached after Steps 1 to 8 of the JFSC's methodology, which is part of the calculation and not the final penalty
explain whether that figure was reduced at Step 9 because it was more than the legal maximum
where relevant, explain how any later methodology adjustment or settlement affected the amount
state the final penalty imposed
The aim is to make it clearer how the JFSC applies its civil financial penalty framework. The level of detail in each public statement will depend on the circumstances of the case.
The JFSC has published feedback from its 2025 supervisory review of how a sample of virtual asset service providers (VASPs) are applying the Travel Rule. Overall, it found that firms have made good progress. Most had suitable policies, procedures and controls in place and understood their obligations well.
The JFSC expects VASPs to:
understand the limitations of the Travel Rule solutions they use
keep documented processes for cases where information cannot be exchanged automatically
regularly assess jurisdictional and counterparty risk
keep their policies, procedures and staff training under review
Read the full published feedback from the JFSC’s supervisory review.
The Registrar of Intellectual Property (Jersey) Law 2026 and the Trade Marks (Jersey) Law 2026 came into force on 1 August 2026, making Jersey a standalone trade mark jurisdiction. For more information, read our client advisory: Jersey becomes a standalone trade mark jurisdiction: what this means in practice.
On 20 July 2026, the JFSC published feedback on its consultation on fees for Jersey's new trade marks, patents and designs framework. These fees will support the running of Jersey's new intellectual property registry. The final fees are set out in Appendix B of the feedback paper.
The JFSC has launched Jersey's intellectual property register and myIPO, its online intellectual property service, following the new legislation that came into force on 1 August 2026. Users can now search the register, apply for Jersey trade marks online and manage core trade mark registrations.
The Government of Jersey is consulting on targeted changes to the Intellectual Property (Unregistered Rights) (Jersey) Law 2011 and related legislation. The aim is to bring Jersey's copyright regime up to date and in line with international standards. This would allow the WIPO Copyright Treaty and the WIPO Performances and Phonograms Treaty to be extended to Jersey.
The changes are likely to matter most to businesses that play copyright-protected music or audiovisual content on their premises. Businesses involved in owning or administering IP, or in digital content, may also be affected.
The consultation closes on 6 November 2026. If no material changes are needed after the consultation, the Government expects to lodge the draft Law for debate by the States Assembly in early 2027. Read the full consultation papers.
On 24 July 2026 the GFSC published a guidance note regarding tokenised investments and persons providing services in relation to such products in or from within the Bailiwick of Guernsey. Tokenised investments include collective investment schemes, securities and real-world assets.
The general position adopted by the GFSC is that tokenisation of an investment does not change the regulatory obligations of those undertaking a regulated activity in respect of such investment.
Controlled investments falling under category 1 (collective investment schemes) and category 2 (general securities and derivatives) will continue to be subject to the Protection of Investors (Bailiwick of Guernsey) Law, 2020 (the POI Law), the Prospectus Rules and Guidance, 2025 (where applicable) and relevant AML requirements.
In the case of tokenisation of real world assets, certain activities may fall within the scope of virtual asset service provider (VASP) licensing under the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022 (the LCF Law).
Where portfolios containing multiple underlying assets comprise a single multi-asset token, the GFSC encourages engagement at an early stage to clarify the appropriate regulatory treatment.
Appendix A to the guidance note provides a list of potential benefits and risks associated with tokenisation. Appendix B provides examples of the potential uses for tokenisation.
Stablecoins are outside the scope of the guidance note and will be subject to specific guidance expected to be issued by the GFSC later this year.
For more information, read the full guidance note.
On 24 July 2026, the GFSC published a second feedback paper following its consultation on Supporting Growth with Digital Finance. The feedback paper contains a detailed summary of the results of the consultation and next steps the GFSC intends to take. A fulsome analysis of the feedback paper is outside the scope of this briefing and licensees and those interested in digital assets are encouraged to read the feedback paper in full and seek legal advice with respect to any proposed dealings in virtual assets or implementing emerging technologies in compliance processes.
The general position of the GFSC is that Guernsey’s principals-based and technology-neutral framework already works well for digital finance. The GFSC will work with the States of Guernsey to make targeted changes on a strictly as needed basis to reduce complexity and give firms clearer routes to market. Importantly, the feedback paper also outlines the GFSC’s position going forward regarding matters which do not require further regulatory amendment.
Key points for the investment sector can be found below.
A VASP licence is required only when providing services for and on behalf of another natural or legal person.
Removal of the requirement for licensees under another regulatory law to obtain an additional VASP licence, although a second licence may be needed in some cases. Notably, existing POI Law and insurance licensees will be able to trade, hold or invest in virtual assets when carrying on regulated activities without an additional VASP licence.
Removal of the restriction on VASP licensees to only provide services to institutional and wholesale counterparties and remove the prohibition on servicing retail customers. The GFSC does not propose to impose additional conduct rules for VASP licensees dealing with retail customers, but expects that such licensees will take steps and apply resources corresponding to the increased level of protection owed to retail customers.
A VASP licence is required to advise in connection with a particular virtual asset, however general advice on virtual assets as part of managing a portfolio or providing general investment advice is still subject to appropriate licensing under the POI Law or the LCF Law (as applicable).
The GFSC has revised its position, with immediate effect, to allow the use of public blockchain or distributed ledger technology (DLT) to maintain the register of unitholders of Guernsey registered or authorised funds. The use of private blockchain and DLT was already permitted since May 2024.
The GFSC has confirmed its approach that tokens conveying rights consistent with category 2 controlled investments within the meaning of the POI Law will be regulated as such. This will be the case for both tokenised issuances of shares or other securities as well as with respect to Guernsey vehicles issuing tokenised securities linked to underlying real-world assets.
The regulatory treatment of tokenised securities is set out in more detail in the GFSC’s Guidance Note on the Tokenisation of Investments and Other Assets.
In due course the GFSC intends to introduce a simple annual reporting requirement for fiduciary licensees on tokenisation-related activity they service.
The GFSC has taken significant steps to ease the regulatory burden in the virtual assets space by allowing:
POI Law licensees to act as custodians of digital assets without requiring a VASP licence under the LCF Law
both POI Law and insurance licensees to trade, hold or invest in virtual assets without requiring a VASP licence under the LCF Law
The use of smart contracts has the potential to assist with customer due diligence (CDD), sanctions screening and transaction and compliance monitoring. However smart contracts cannot replace human oversight and firms are advised to avoid over-reliance on automated solutions to discharge their AML / CFT / CPF obligations.
Similarly, blockchain and DLT can be used, where cost appropriate to do so, to evidence completed CDD in respect of introduced business within the meaning of the Handbook. In this context tokens can be used as pseudonymised identifiers linking to off-chain CDD records. Records, including statutory registers, can be maintained on a blockchain provided they are capable of being reproduced in hard copy (as required for company registers of members) or a legible form (as required for registers of limited partners).
The risks associated with the use of technology can, and should, be mitigated through project management, staff training and ongoing monitoring. Firms should ensure that the data used for automatic screening purposes is kept accurate and up to date.
The principles in the Handbook on Countering Financial Crime (AML/CFT/CPF) (the Handbook) are applicable and adaptable to firms of all dimensions and emerging technologies. As covered in our previous update, the Handbook was updated earlier this year to accommodate the use of technology in the CDD process.
For more information, read the full feedback paper.
The GFSC published the Lending, Credit and Finance (Amendment) Rules, 2026 which came into effect on 1 October 2026. The rules form part of the GFSC’s Digital Finance Initiative and amend the Lending, Credit and Finance Rules, 2023 in relation to VASPs. The main changes are:
no separate VASP licence in every case: firms already licensed by the GFSC are no longer always required to hold a separate VASP licence to carry out virtual asset activity
retail customers: the blanket ban on VASPs providing services to retail customers has been removed
environmental reporting: the separate environmental reporting requirement for VASPs has been removed, bringing them into line with firms regulated under the Guernsey supervisory laws
the Banking Deposit Compensation Scheme comes into force: the dates of entry into force of the Banking Deposit Compensation Scheme (Bailiwick of Guernsey) (Amendment) Ordinance, 2026 have been amended as follows:
sections 1(14)(b) and 1(18) came into force on 6 August 2026
the remaining provisions of the ordinance came into force on 1 October 2026
the new ordinance amends the Banking Deposit Compensation Scheme (Bailiwick of Guernsey) Ordinance, 2008 with a particular focus on the governance and independence of the Guernsey Banking Deposit Compensation Board
For more information, read The Lending, Credit and Finance (Amendment) Rules, 2026.
The GFSC has amended its Financial Crime Returns Rules to reflect the revisions made to the Form 152. The changes relate to the name of the form (previously named Financial Crime Risk – Intermediary Annual Return, now named Financial Crime Risk – Investment Vehicles Return), as well as its content, reporting period and submission deadline.
For more information, read the full Financial Crime Return Rules 2026.
The GFSC and the Policy & Resources Committee launched a joint consultation on changes to address the supervisory recommendations in MONEYVAL’s report on its mutual evaluation of the Bailiwick of Guernsey published in February 2025. The proposals would amend the Handbook on Countering Financial Crime (AML / CFT / CPF) and to the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999 (the Proceeds of Crime Law).
Proposed changes to the Handbook:
restricting the existing exemption from identifying and verifying the natural person beneficial owners to listed companies and Bailiwick state owned companies, but not GFSC licensed or registered entities, in line with the Financial Action Task Force's (FATF) recommendations. Application of simplified due diligence will only be permitted where the entity is assessed to be low risk (even where the entity is licensed or regulated by the GFSC)
banks and payment service providers carrying out a wire transfer of ÂŁ1,000 or more as a single transaction or linked transactions will be required to identify and verify the identity of the beneficial owners of the payer and person purporting to act on behalf of the payer and verify their authority to act
when undertaking a relationship risk assessment, firms will also be required to consider the complexity of the structure. Complexity cannot be defined solely by objective criteria (such as the number of entities, layers or jurisdictions involved). The criteria to determine complexity requires an understanding the purpose and rationale for the structure.
Proposed changes to the Proceeds of Crime law:
Schedule 1: removal of credit providers solely for the purpose of providing general insurance premium financing from the list of financial services business subject to Schedule 3 of the Proceeds of Crime Law, as the provision of general insurance (motor or house insurance) falls outside of the scope of financial activities the FATF require to be covered
Schedule 4: removal of the requirement to register with the GFSC for financial services businesses providing services solely in relation to VASPs
Appendix C jurisdictions: no changes are currently proposed, however the GFSC is seeking views as to whether the list of jurisdictions at Appendix C (the list underpins the introducer and intermediary provisions) should be removed or retained
The consultation closed on 9 October 2026.
For more information, read the consultation documents on both sets of proposed changes.
The GFSC has reminded all licensees to complete their annual verification of the information held on the Online Submissions (OS) Portal by 31 October 2026. The exercise forms part of the GFSC's Data Transformation Programme. Its purpose is to keep the basic information the GFSC holds on licensees, such as addresses and contact details, accurate and up to date.
Licensees' records were marked as "unverified" from 1 October 2026. Licensees should:
review the information in the "Entity Details" tab of the OS Portal and update it where necessary
select the relevant entities and complete the declaration by clicking click "declare / verify"
For more information, see the GFSC's reminder.
On 3 September 2026, the GFSC launched a consultation on the fees and administrative penalties that will apply from 1 January 2027. It proposes an overall increase of 4.3%, in line with Bailiwick inflation. Other proposals include:
applying a one-off 17% discount against the proposed annual fee for 2027 to all licensees under the Insurance Business (Bailiwick of Guernsey) Law, 2002 and the Insurance Managers and Insurance Intermediaries (Bailiwick of Guernsey) Law, 2002, as a result of the income received from significant fine to an insurance company earlier this year
introducing a fee for acting as a VASP custodian of an amount equal to the lowest band fee for acting as a custodian under the POI Law
a separate consultation will be launched in future on any proposed changes to fees for stablecoin licences.
The consultation closed on 6 October 2026. The GFSC will publish a feedback statement confirming the fees to apply from 1 January 2027.
For more information, read the GFSC's proposed changes to fees for 2027.
The GFSC has licensed another firm through its Innovation Sandbox, in this case a digital administrator. The Sandbox opened in October 2025 as part of the GFSC’s Digital Finance Initiative. It lets firms test new products and business models while working closely with the GFSC.
For more information on the GFSC’s Sandbox and Concierge service, see our article below:
Guernsey welcomes digital innovation with new GFSC Sandbox service
Ogier extends special congratulations to the five winners of the Fund Foundry's inaugural programme and to the partners behind Guernsey’s successful first-of-its-kind initiative supporting emerging managers both financially and through mentorship and market-leading assistance from local firms.
For insight on how Guernsey caters to the needs of emerging managers, read our article from Investment Funds partner Tim Clipstone:
What's attracting next generation fund managers to Guernsey?
The AI Sprint is a new programme being held in Guernsey between 1 October and 12 November which brings together businesses (including SMEs), charities, business leaders, employees and individuals for more than 50 events exploring the opportunities and challenges presented by AI. The programme includes more than 50 events is published on the AI Sprint website.
The initiative is supported by the GFSC and the Guernsey Chamber of Commerce. The GFSC will also be involved in two of the events exploring:
how AI and synthetic data can be used to develop and test new approaches to anti-money laundering processes and controls, to be held on 12 October
the practical foundations needed to make AI work effectively, including data quality, processes, skills and organisational culture, to be held on 29 October
Find the full programme on the AI sprint webpage: The Guernsey AI Sprint.
The GFSC has appointed Mr Peter Deacon as the first Finance Sector Concierge for the Bailiwick of Guernsey. The position was created as part of the Finance Sector Growth Strategy 2035. The Concierge will work in partnership with the GFSC, Guernsey Finance, Locate Guernsey and professional firms in the Bailiwick and act as a single first point of contact for businesses, investors and advisers considering Guernsey.
The concierge can be contacted by emailing info@guernseyconcierge.gg.
The data protection authorities of Guernsey, Jersey and the Isle of Man have issued a joint advisory note on the use of smart glasses (the Advisory Note). The Advisory Note highlights that their respective data protection laws are technology neutral and apply regardless of how personal data is collected.
The increased use of smart glasses, including in workplaces and businesses. The Advisory Note should be considered by any organisation prior to introducing smart glasses. As is the case with any other surveillance technology, a Data Protection Impact Assessment in relation to the use of smart glasses will be required before processing begins.
For more information, read the full Advisory Note.
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