Consultation on phase 1 updates to our bank licensing policy (No. 2 2026)

Summary

This is a JFSC consultation paper seeking industry feedback on proposed phase 1 changes to its Bank Licensing Policy (BLP), which governs how the JFSC assesses applications to become a registered bank under the Banking Business (Jersey) Law 1991 and how it supervises banks on an ongoing basis. The changes aim to modernise and simplify the BLP; a further phase 2 may consider broader legislative changes later.

• Top 1,000 restriction: Proposes removing the requirement that applicant banking groups fall within the global top 1,000 by Tier 1 capital, while retaining other criteria such as international activity, financial strength and supervisory track record.
• Start up banks: Adds new guidance on how Jersey based start-up banks should evidence that risks to depositors are addressed, including possible in principle licences and time bound mobilisation phases.
• Managed banks and business continuity material: Proposes removing BLP material on managed banks and business continuity registrations, as these categories are unused.
• Letters of comfort: Proposes removing the letter of comfort requirement for Jersey incorporated banks (JIBs), relying instead on recovery and resolution planning.
• Senior officer requirement: Seeks feedback on the existing requirement for an off-island senior officer (under Article 11 of the BBJL and the Banking Business (General Provisions) (Jersey) Order 2002), including whether clarifying expectations would help.
• Website migration of material: Proposes removing general material on Jersey banking regulation and the application process from the BLP, as this is now covered on the JFSC website.

The document is a draft consultation, not a final rule change; no substantive requirements take effect from this paper itself. It affects entities registered under the Banking Law and prospective applicants, and invites stakeholder comment via an online response form or through Jersey Finance Limited (JFL), with feedback and a revised BLP expected by the end of August 2026.

Key obligations

• Respondents wishing to comment must submit their response through the JFSC's online form (or via Jersey Finance Limited) by 5:00pm on Friday 12 June 2026.
• Industry body or trade association respondents must also provide a summary of the types of individuals or institutions they represent.

Applies to

banks, registered persons under the Banking Business (Jersey) Law 1991, applicants for a banking licence, start-up banks, Jersey incorporated banks (JIBs), bank branches, industry bodies and trade associations

Deadlines

• 5:00pm on Friday 12 June 2026: Deadline to submit consultation responses via the online form or through Jersey Finance Limited.
• end of August 2026: JFSC plans to publish consultation feedback and a revised Bank Licensing Policy.