Feedback Paper on Consultation for Fee Rates for 2025 (2024-12-05)

Summary

This is the GFSC's feedback paper responding to its September 2024 consultation on 2025 fee rates and administrative penalties. It confirms the Commission's final decisions after considering nine written responses, and sets out the revised fee schedule (Appendix A) that will apply to all GFSC-licensed and registered entities from 1 January 2025.

• Overall fee increase: Fees for most licensees and registrants increase by 5.3% across the board, in line with inflation and staff retention costs, effective 1 January 2025.
• Retail General Insurers (RGI): A new, higher fee banding is introduced specifically for Retail General Insurers (both company and cell structures) to reflect increased supervisory effort, despite objections from smaller RGIs about disproportionate impact.
• Investment exchange operators: A new application fee is created for entities seeking to operate an investment exchange in the Bailiwick of Guernsey.
• Rationalisation of fee regulations: The Commission is restructuring and consolidating its fee regulations for consistency across sectors and common processes (e.g. change of controller, pro-rata annual fee calculations on initial licensing), and is now also incorporating prescribed business fees under the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999 into the amended regulations.
• Full fee schedule: Appendix A sets out detailed 2024 versus 2025 fees across banking, insurance, fiduciary, investment, lending/credit/finance, prescribed businesses, director registration, virtual asset service providers, and miscellaneous application fees, plus penalty schedules for late payment, late filing and inaccurate filing.

No changes were made to the estate agent fee structure despite a suggestion to base it on transaction volumes rather than employee numbers, as only one respondent raised this. All amended fees, restructured regulations, and penalty rates take effect from 1 January 2025.

Key obligations

• Licensees and registrants must pay the revised 2025 fees (application and annual) as set out in Appendix A from 1 January 2025.
• Retail General Insurers must pay the new, higher fee bandings applicable to their category from 1 January 2025.
• Entities applying to operate an investment exchange in the Bailiwick must pay the newly created application fee.
• Prescribed businesses registered under the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999 must pay fees now incorporated into the amended fee regulations effective January 2025.
• Licensees and registrants who pay fees late are subject to escalating late payment penalties (£125 first month, £250 second month, £375 third and subsequent months).
• Licensees and registrants who file late are subject to escalating late filing penalties (£125 first month, £250 second month, £375 third and subsequent months).
• Firms that submit inaccurate filings are subject to inaccurate filing penalties, with higher penalties where the error is identified by the Commission rather than self-identified.

Applies to

banks, insurers (including Mutual, Provident or Friendly Societies, PCCs, ICCs and ICs), Retail General Insurers, insurance managers, insurance intermediaries, fiduciary sector licensees, investment sector licensees, investment exchange operators, lending, credit and finance sector firms (including home finance and consumer credit providers), prescribed businesses, virtual asset service providers, registered directors under the Director Registration Regime, estate agents

Deadlines

• 1 January 2025: Effective date for the overall 5.3% fee increase, the new RGI fee bandings, the new investment exchange application fee, and the rationalised and restructured fee regulations (including incorporated prescribed business fees).