Registry Processing Statement (Revised March 2026)

Summary

This JFSC policy statement explains how the Jersey Companies Registry assesses applications under the Control of Borrowing (Jersey) Order 1958 (COBO consents) and applications to transfer a Reserved Company, where those applications feature higher risk indicators or activities posing potential reputational risk to Jersey. It should be read together with the JFSC's Sound Business Policy (SBP) and sets out the risk factors the Registry considers, the disclosures applicants must make, and the actions the Registry may take when an application is materially inaccurate, inadequate or incomplete.

• Scope of applications covered: COBO consent applications under Articles 1, 2, 3, 4, 4A, 5, 5A, 7 (until 12 April 2026), 8, 9, 10, 11 and 11A, plus applications to transfer a Reserved Company.
• Risk factors considered: Solvency, PEP status, residency in higher-risk jurisdictions, sanctions exposure, and any other reputational risk factors relating to ultimate beneficial owners, controllers, founders or partners.
• Disclosure requirements on application forms: Applicants must confirm due diligence has addressed the listed risk factors, provide free-text details of other risk factors identified, disclose details of regulated/authorised/supervised entities and their holding vehicles, and disclose details of ICO and token issuers.
• Beneficial ownership threshold: Standard disclosure threshold is 25% or more ownership/control on incorporation, but the Registry may require disclosure at a lower threshold where higher risk factors are identified; the TCSP must explain the risk factors, the threshold applied and how it mitigates the risk.
• Registry actions on deficient applications: The Registry may stop the processing clock, return the application, refer the matter to the JFSC Supervisor, or suspend an applicant's fast-track service where there are repeated deficient applications from the same service provider.
• Fees on withdrawal: Application fees are generally not refunded if an application is withdrawn during this process, absent exceptional circumstances.
• Holding company and structure chart requirements: Applicants for Jersey holding companies of non-Jersey regulated groups must provide a structure chart showing entities, jurisdictions and regulators, and confirm whether Regulatory Laws apply; a full ownership and control chain to beneficial owners must be shown.
• Off-island regulatory engagement (Appendix A): Depending on the transaction type, the Registry may require a Letter of Authority and Confirmation (or an undertaking to provide one) enabling it to contact the relevant overseas regulator, and may issue a conditioned COBO Consent if material risks are identified.
• Trust company business competence: Where a trust company business provider services a person subject to the SBP carrying on SBP activity, it must have appropriate knowledge, skills and experience relevant to that activity, which will be assessed as part of supervision of the TCB sector.

The Statement is guidance on the Registry's internal risk-based processing approach rather than a stand-alone set of new statutory duties, but it does create practical disclosure and engagement obligations for applicants and their advisers seeking COBO consents or Reserved Company transfers.

Key obligations

• Applicants for the listed COBO consents or Reserved Company transfers must disclose, via the published application form, higher risk factors relating to beneficial owners, controllers, founders or partners (solvency, PEP status, high-risk residency, sanctions exposure) and any other reputational risk factors.
• Applicants must provide details of regulated, authorised or supervised entities and their holding vehicles, and details of any Initial Coin Offering or token issuers, in the application.
• Where a lower beneficial ownership disclosure threshold than 25% is applied due to identified risk, the TCSP must explain in the application the risk factors identified, the threshold used, and how it mitigates the risk.
• Applicants for Jersey holding companies of non-Jersey regulated groups must provide a structure chart identifying underlying entities, their jurisdictions of incorporation, activities and applicable regulators, and confirm whether the Regulatory Laws apply.
• Where requested, regulated entities, Jersey legal advisers or bid entities must provide (or undertake to provide) a Letter of Authority and Confirmation permitting the Registry to contact the relevant overseas regulator.
• Trust company business providers servicing a person subject to the Sound Business Policy who is carrying on SBP activity must maintain appropriate knowledge, skills and experience relevant to that person's activities.
• Applicants who withdraw an application during Registry review should expect the application fee to be non-refundable absent exceptional circumstances.

Applies to

applicants for COBO consent, holding companies, Reserved Companies, trust and company service providers (TCSPs), trust company business providers, Jersey legal advisers, regulated, authorised or supervised entities, Initial Coin Offering and token issuers

Deadlines

• until 12 April 2026: Article 7 of COBO (issue of government securities) remains within scope of this Statement only until this date.