Consultation on limited liability companies guidance (No. 6 2026)

Summary

This is a JFSC consultation paper seeking industry feedback on proposed revisions to its guidance on limited liability companies (LLCs). It proposes to widen how LLCs can be used, including as corporate trustees and for certain regulated financial services activities, and includes a draft revised guidance note as an appendix.

• Corporate trustees: Proposal to permit LLCs to act as corporate trustees, aligning with recent changes to the Trusts (Jersey) Law 1984.
• Regulated business use: Proposal to allow LLCs to be used for fund services business, trust company business, investment business, general insurance mediation business or money service business under the FSJL.
• Sophisticated investor limitation: Proposal to remove the restriction limiting LLC use to financially sophisticated investors or customers only, while retaining the requirement that administration services be provided by a regulated trust company business.
• Guidance clarity: Proposed drafting changes intended to improve the clarity and accessibility of the LLC guidance note.
• Continuing restrictions (draft guidance): The draft guidance confirms LLCs still cannot carry on banking business, CIF activity or insurance business, and that LLC series provisions are not yet in force.
• Disclosure requirements (draft guidance): The draft guidance restates that LLCs must disclose beneficial owners and significant persons to the Registry, notify changes within 21 days, file an annual confirmation statement, and appoint a nominated person as main Registry contact.

The consultation is informational and does not itself create binding requirements; any resulting guidance changes would take effect after the feedback period, expected to be published in September 2026. Respondents are asked to answer four specific questions on the proposals via the JFSC's online survey.

Key obligations

• Respondents wishing to comment must submit their response via the JFSC SmartSurvey by 12:00pm on Thursday 6 August 2026.
• Where a response is submitted by an industry body or trade association, that body must also provide a summary of the individuals and institutions it represents.
• (Under existing/draft guidance, restated here) LLCs must disclose beneficial owner and significant person information to the Registry and notify any changes within 21 days.
• (Under existing/draft guidance, restated here) LLCs must submit an annual confirmation statement to the Registry with up to date beneficial owner, significant person and registered office information.
• (Under existing/draft guidance, restated here) An LLC must appoint a nominated person as its main contact with the Registry for these disclosures.

Applies to

Jersey corporate trustees, fund services business, trust company business, investment business, general insurance mediation business, money service business, limited liability companies (LLCs)

Deadlines

• 12:00pm on Thursday 6 August 2026: Deadline to submit consultation feedback via the JFSC SmartSurvey; consultation closes at this time.
• September 2026: JFSC plans to publish feedback on the consultation and outline next steps ahead of implementation of the new guidance.
• within 21 days: Existing/draft guidance requirement for LLCs to notify the Registry of changes to beneficial owner or significant person information.