Consultation on disclosable beneficial ownership information (No. 2 2025)

Summary

This is a JFSC consultation paper seeking industry feedback on proposals to collect additional beneficial ownership data fields, namely the extent (percentage thresholds) and nature (role/type) of beneficial ownership, from Jersey legal entities. It is a draft proposal, not yet in force, and would require amendment of the Financial Services (Disclosure and Provision of Information) (Jersey) Law 2020 if adopted.

• Extent of ownership: Proposes four thresholds for recording beneficial ownership percentage: up to but not including 25%, 25-50% inclusive, over 50% up to 75%, and over 75%.
• Nature of ownership: Proposes categories describing how ownership/control is exerted: shareholding, ownership interest, voting rights, control by other means, control through positions held, controller as liquidator, and controller as council member (foundations only).
• Direct vs indirect: Proposes not to require entities to specify whether beneficial ownership or control is direct or indirect, and asks for industry views on this.
• Where collected: Information would be collected on establishment/registration of an entity and periodically via the Annual Confirmation Statement.
• Who is affected: Newly incorporated/established entities and existing entities registered with the JFSC Registry (companies, foundations, incorporated limited partnerships, limited liability companies, limited liability partnerships, separate limited partnerships, and any other prescribed bodies).

The JFSC invites written or SmartSurvey responses by 30 May 2025, with an alternative route via Jersey Finance Limited coordinating an industry response by the same date. Feedback is expected to be published by end of June 2025, and if implemented, the new requirements would take effect from 1 January 2026, giving industry roughly six months to prepare.

Applies to

companies, foundations, incorporated limited partnerships, limited liability companies, limited liability partnerships, separate limited partnerships, other prescribed bodies registered with the JFSC Registry, Trust Company Service Providers (as regulated gatekeepers)

Deadlines

• 30 May 2025 (11:59pm): Deadline for submitting consultation responses to the JFSC or to Jersey Finance Limited for the industry response.
• end of June 2025: JFSC aims to consider feedback, finalise any additional data requirements, and publish a feedback paper.
• 1 January 2026: Proposed implementation date for newly incorporated/established entities to provide the additional beneficial ownership information, and start date for existing entities to begin capturing it.
• end of February 2026: Proposed deadline by which existing entities' annual confirmation statements (capturing the required additional information) are to be filed.