Feedback on the consultation on phase 1 updates to our bank licensing policy (2026-09-03)

Summary

This is a feedback paper published by the Jersey Financial Services Commission summarising responses to its consultation (Consultation Paper No. 2 2026) on phase 1 updates to the Bank Licensing Policy (BLP), and setting out the Commission's decisions and next steps. It is not itself a new rule but explains changes the Commission will make to the BLP and the Banking Code.

• Top 1,000 restriction: The Commission will remove the requirement that bank applicants be part of a group ranked in the top 1,000 banks by Tier 1 capital, relying instead on substantive supervisory assessment of financial resilience, governance and financial crime controls.
• Start-up banks: The Commission will proceed with its proposed start-up bank approach largely unchanged, with added detail on stress testing/recovery planning (via ICAAP) and clarification that resolution planning sits with the Jersey Resolution and Deposit Compensation Authority.
• Managed banks and business continuity material: This material will be removed from the BLP as it is not currently in use, though the Commission may still consider managed bank arrangements case by case.
• Letter of comfort requirement: The requirement for a letter of comfort from an acceptable parent bank will be removed from the Banking Code, to be implemented alongside other Basel III related amendments; further details and timing to follow.
• Senior off-island officer requirement: The requirement will be retained, but the Commission will consider making the appointment process less stringent.
• Duplicative regulatory and application material: Duplicative content will be streamlined out of the BLP and hosted separately on the Commission's website, with improved cross-referencing.

The Commission confirms it has already published a revised Bank Licensing Policy alongside this feedback paper and will continue further work on the banking framework, website and application processes, with updates to industry to follow.

Applies to

banks, registered persons under the regulatory laws, bank applicants, start-up banks