Statement of Guidance
Registry guidance on beneficial ownership and control (Last revised 2026-03-31)
In forceView on JFSC's website Source document
Summary
This is Jersey Companies Registry guidance explaining how entities must identify and report beneficial owners and controllers under the Financial Services (Disclosure and Provision of Information) (Jersey) Law 2020 (the Disclosure Law) and, for limited partnerships, under the Control of Borrowing (Jersey) Order regime. It sets out the FATF-based 'three tier test' for identifying beneficial owners and controllers, and describes special rules for foundations, partnerships and trusts.
- Who must comply: Companies, foundations, incorporated limited partnerships, limited liability companies, limited liability partnerships, limited partnerships and separate limited partnerships registered in Jersey, and regulated service providers (trust company and fund services businesses) that administer them.
- Core obligation: Provide beneficial owner and controller information upon establishment or registration, and notify the Registry of any change within 21 days of becoming aware of it.
- Identification method: Apply the three tier test: Tier 1 identifies individuals with 25% or more ownership or control as beneficial owners; Tier 2 and Tier 3 identify controllers through other means or control positions where no owner is identified.
- Special categories: Alternative disclosure rules apply to entities listed on a regulated market, entities owned by market-listed parents, entities owned or controlled by FSJL-registered Class H, L or OA businesses, state-owned entities, foundations, partnerships and trusts (including charitable trusts).
- Other triggers: Death of a beneficial owner requires submission of an updated associated parties form naming the executor as controller; a beneficiary reaching 18 years old requires a notified change from guardian to beneficiary.
The guidance clarifies that failure to provide or update beneficial owner information without reasonable excuse within 21 days of knowledge of a change is an offence under the Disclosure Law, and that regulated service providers' compliance failures on behalf of clients may also raise Codes of Practice concerns.
Key obligations
- Provide full beneficial owner and controller information to the Registry upon establishment or registration of the entity
- Notify the Registry of any change in beneficial owner or controller information within 21 days of becoming aware of the change
- For limited partnerships, provide and update beneficial owner information under the COBO consent regime
- Apply the three tier test to correctly identify and record beneficial owners (Tier 1) and controllers (Tier 2/3)
- Regulated service providers must highlight in myRegistry any concerns relating to beneficial owners or business activity upon incorporation or change
- Upon death of a beneficial owner, submit an updated associated parties form identifying the executor as controller
- Notify the Registry of a change of beneficiary information when a child beneficiary turns 18
- Confirm accuracy of beneficial owner (or applicable alternative) details as part of the annual confirmation statement
Applies to
Companies registered under the Companies Law, Foundations registered under the Foundations Law, Incorporated Limited Partnerships, Limited Liability Companies, Limited Liability Partnerships, Limited Partnerships, Separate Limited Partnerships, Regulated service providers (trust company and fund services businesses), Trustees
Deadlines
- 21 days: Entities must notify the Registry of any change in beneficial owner or controller information within 21 days of becoming aware of the change
- 18 years old: Notification of change of beneficiary required when a child beneficiary reaches adulthood