Are We Achieving the Objective? Bailey's Challenge and Jersey's Answer in Time to Win

From Volume to Value: Why the Quality of Regulation and How It Is Delivered Matters More Than the Size of the Rulebook

The following is a personal response (see my disclaimer at the end of this piece) to the Governor of the Bank of England's Mansion House speech with lessons for IFC regulators and a close look at how Jersey's "Time to Win" initiative and the JFSC are already putting the principles into practice

I am delighted that the Governor of the Bank of England has joined the chorus calling for a shift from a discourse of more or less regulation to one about having the right regulation. It echoes a point made by Omar Salem, Financial Regulation & Tech Partner at Pierson Ferdinand (and formerly of Fox Williams, Linklaters and fintech GC roles), in City AM in February 2026:

"We are stuck in an Animal Farm world of less regulation good; more regulation bad, or vice versa, depending on political persuasion.

It is a superficial argument about volume.

The more serious question is about quality."

In his Mansion House speech on 14 July 2026, Growth and regulation, Andrew Bailey, Governor of the Bank of England, put it this way:

"This framing should lead to a better debate on the principle and practice of regulation. Are we achieving our objective or not?

This is a better way to frame the issue than a "too much/too little" debate about regulation that is divorced from the objective.

Yet too much of the debate on regulation is precisely of this too much / too little sort, in abstract from the outcomes we want to see."

The Governor is right.

Framing regulation around whether it meets its stated objectives financial stability as a prerequisite for sustainable growth, market integrity, consumer protection, competition and innovation is far more productive than abstract arguments about the volume of rules. As Bailey noted, well-designed regulation can correct market failures, reduce transaction costs, lower entry barriers and support competition and innovation. Poorly designed or executed regulation does the opposite.

The Missing Piece: Operational Performance

One thing largely missing from the speech, however, is the operational performance of regulators themselves. It may be that what regulators do, not merely what rules they write, has the greatest influence on growth, investment decisions and a jurisdiction's reputation as open for business.

Faster and more consistent authorisations, clearer and more predictable supervisory expectations, higher-quality engagement with firms, and more skilled, experienced supervision would do more to demonstrate that a centre is open for business than any amount of high-level debate about the size of the rulebook.

A rule that is perfectly designed to meet its objective still fails if it is applied slowly, inconsistently, opaquely or without the necessary expertise.

• Quality of regulation (design),
• fitness for purpose (alignment with objectives), and
• operational performance (execution and delivery)

All the above “the Jersey three-legged stool” are essential to an effective regulatory system. The first two, without the third, are incomplete.

The Governor has opened an important door by shifting the conversation from volume to outcomes. Now the whole system needs to walk through it by subjecting operational performance to the same rigorous scrutiny.

Why Operational Performance Matters as Much as Rule Design

Firms experience regulation through authorisation timelines, the consistency and expertise of supervisory dialogue, the clarity of feedback, the predictability of enforcement, and the ability of regulators to engage constructively with innovation.

Key dimensions include:

• Authorisations and permissions: speed, consistency, transparency and quality of decision-making.
• Supervision: depth of knowledge, proportionality in practice, constructive challenge.
• Guidance and communication: timeliness, clarity and stability of expectations.
• Innovation pathways: effectiveness of sandboxes and routes to live permissions.
• Capability: attracting, retaining and deploying skilled people who understand complex markets.

These factors directly affect the cost of capital, investors' willingness to back businesses, and the relative competitiveness of financial centres.

Process friction and uncertainty act as a drag on growth even when the underlying rules are well designed.

What IFC Regulators Can Take from Bailey and How Jersey's "Time to Win" Is Already Acting on It

The Crown Dependencies and other International Financial Centres already market themselves on high international standards combined with agile, proportionate regulation.

Bailey's focus on objectives over volume and the operational performance gap he left unaddressed present both validation and a practical challenge for the Jersey Financial Services Commission (JFSC), Guernsey Financial Services Commission (GFSC), Isle of Man Financial Services Authority (IOMFSA), and their peers.

Jersey provides the clearest current case study.

In March 2026, the Government of Jersey published Time to Win, the final report and action plan of its Financial Services Competitiveness Programme, the most comprehensive review of the island's financial and related professional services (FRPS) sector in more than a decade. The report is clear:

• Jersey does not lack quality, credibility, or regulatory standards.
• The risk is a gradual erosion of its competitive position through friction, complexity, institutional overlap, and a loss of hunger to win.
• The prize is faster, more certain, and a better client experience while maintaining high standards.

Time to Win's regulatory and operational recommendations map directly onto the three-legged stool (ref above):

• Reduce regulatory cost and complexity: while maintaining relevant standards; minimise super-equivalence, simplify laws, AML/KYC and the JFSC framework (Codes, Handbook, Guidance), reform civil penalties and licensing, streamline processes.
• Deliver excellent customer service as standard:- JFSC to develop and publish customer service targets and strengthen supervision with a focus on customer experience and service standards.
• Embed a growth mindset: Across Government, the regulator and industry; clarify boundaries of responsibility so that government sets policy, the regulator upholds standards, and promotion is left to Jersey Finance.
• Innovate and digitalise: Modernise frameworks for tokenisation, deliver registry transformation, explore sandboxes, and improve digital interfaces so that the operational experience matches the high-standards brand.

How the JFSC is helping deliver Time to Win

The JFSC has not treated Time to Win as a government document to be noted and filed. It has actively contributed throughout the programme's development and has publicly aligned its own strategy with it.

In March 2026, the JFSC launched its 2026–2030 strategy and 2026–2027 business plan, explicitly designed to:

• "Align with the Government of Jersey's financial services competitiveness programme and best support the island's economy."

The strategy's three pillars support growth, be risk-based and proportionate, and deliver excellent service, aligning with Bailey's "objectives and outcomes" framing and with Time to Win's call for speed, certainty, reduced friction, and a service culture.

Concrete ways the JFSC is operationalising the agenda (as reflected in its strategy, business plan and mid-year updates) include:

• Simplifying and modernising the regulatory framework, streamlining Schedule 2, enhancing guidance, reviewing MLCO and reliance provisions, revising bank licensing policy, and making published regulatory content more usable and machine-readable.
• Improving operational performance and service culture investment in digital channels, user experience, AI for straight-through processing of administrative tasks, publication of performance against service level agreements, and internal training to strengthen a customer-focused culture.
• Data- and intelligence-led, proportionate supervision targeted interventions, reduced intensity for lower-risk businesses, and a rebalancing of supervisory approach across prudential, conduct and financial crime to support sustainable business models.
• Registry of the future and innovation support modernising and digitising registry services, supporting digital assets and tokenisation, and creating an enabling environment for good business to grow.
• Public commitment and ongoing collaboration the JFSC has welcomed Time to Win, stated that it will continue to support delivery within its remit as regulator and registry, and has used mid-year industry updates (including June 2026) to reaffirm alignment and report progress on legislative and operational workstreams that sit under the Time to Win roadmap.

In short, Jersey (government + JFSC) is already attempting to do what Bailey is urging the UK system to do:

• Move from a volume debate to an outcomes debate,
• And then to back that debate with operational delivery, service standards, simplification, digital capability, and a growth mindset that does not compromise standards.

Lessons and considerations for other IFC regulators

Other IFCs (and the UK itself) can usefully watch how Jersey executes. Key considerations that flow from both Bailey and Time to Win:

1. Align strategy documents explicitly with a growth/competitiveness narrative while protecting the standards brand. JFSC's decision to launch its strategy in lockstep with Time to Win is a model of coherence.
2. Make operational performance measurable and public. Service targets, SLA performance, and firm perception data turn "we are proportionate and service-oriented" from a claim into an accountable commitment.
3. Treat simplification and digitalisation as core regulatory policy, not back-office hygiene. Reducing friction is itself a competitive instrument.
4. Clarify roles: government (policy), regulator (standards + delivery), promotion body (marketing). Blurred boundaries create the institutional overlap that Time to Win correctly identifies as a source of friction.
5. Guard against the reverse volume trap. "We are smaller therefore we are more agile" is as superficial as "more regulation is always better." Operational excellence requires continuous investment in people, data, systems and culture.

Aligning Operational Performance with the New Framing

Bailey's question "Are we achieving our objective or not?"  should apply equally to the operational machinery of regulation in London, St Helier, St Peter Port, Douglas and elsewhere.

Every regulator should be asking whether authorisation processes, supervision, guidance and innovation pathways are actually delivering the outcomes of stability, integrity, competition and sustainable growth, or whether process has become an end in itself.

What Needs to Happen Next

The Governor has usefully reframed the UK debate. Jersey has already begun to act. To capitalise fully:

• UK government and Parliament should hold regulators to account for measurable operational outcomes as well as for the rules they make.
• UK regulators should treat operational delivery with the same seriousness as policy reform and publish clearer performance data.
• JFSC and Jersey government should maintain the current alignment between Time to Win and the JFSC strategy, publish the service targets and implementation plans promised, and continue to report progress transparently so that the island can demonstrate (not just assert) that high standards and superior operational performance can coexist.
• Other IFC regulators (GFSC, IOMFSA and peers) should study the Time to Win / JFSC model closely: a government-led competitiveness reset paired with an explicitly aligned regulatory strategy that elevates service, simplification and outcomes is a practical template for turning Bailey's intellectual framework into day-to-day competitive advantage.
• Industry everywhere should engage with specific, evidence-based proposals for operational improvement rather than defaulting to volume-based lobbying.

Conclusion

The Governor has done the system a service by rejecting the false binary of more versus less regulation and insisting on a focus on objectives and outcomes. That is a necessary but not sufficient condition for an effective regulatory regime that supports growth.

Quality of regulation, fitness for purpose, and operational performance are the three legs of the stool. The speech addresses the first two with clarity. The third now needs equal attention.

Jersey's Time to Win initiative, and the JFSC's deliberate alignment of its 2026–2030 strategy and day-to-day delivery with that initiative, show one high-standard IFC already walking through the door Bailey has opened. Faster, more consistent authorisations, clearer service standards, simplified frameworks and skilled, proportionate supervision are not soft options; they are how a centre converts high standards into sustainable growth and a durable competitive edge.

A rule perfectly designed to meet its objective still fails if it is enforced or applied poorly. The Governor has opened a door. Jersey is already walking through it. The UK and other IFCs should follow with equal intent.

End [15 July 2026]

• Disclaimer :- This is a personal thought leadership piece based on my own views and reflections as Mathew Beale. It is not intended to be controversial, nor does it represent the position of any organisation, regulator, government or client. My sole aim is to contribute constructively to the ongoing conversation within the financial services and regulatory community about how we can achieve better outcomes through right regulation and high-quality delivery. I welcome discussion, challenge and alternative perspectives.

Supporting Links & Source Documents

Bank of England

• Andrew Bailey, “Growth and regulation” – Mansion House speech, 14 July 2026 https://www.bankofengland.co.uk/speech/2026/july/andrew-bailey-speech-at-manison-house

Omar Salem

• “Good regulation can support growth without increasing risk”, City AM, 17 February 2026 https://www.cityam.com/good-regulation-can-support-growth-without-increasing-risk/
• Omar Salem profile (Pierson Ferdinand) https://pierferd.com/omar-salem

Jersey Government – Time to Win

• Full report: Time to Win (Financial Services Competitiveness Programme Action Plan), March 2026 https://www.gov.je/SiteCollectionDocuments/Government%20and%20administration/Time%20to%20Win%20report.pdf
• Summary brochure: Time to Win https://www.gov.je/SiteCollectionDocuments/Government%20and%20administration/Time%20to%20Win%20summary%20brochure.pdf
• Government blog post: “Jersey’s Financial Services industry: It’s Time to Win” (19 March 2026) https://blog.gov.je/2026/03/19/jerseys-financial-services-industry-its-time-to-win/
• Official Government page for the Competitiveness Programme / Time to Win https://www.gov.je/Industry/Finance/pages/financialservicescompetitivenessprogramme.aspx
• Launch news announcement https://www.gov.je/News/2026/pages/competitivenessprogrammeactionplan.aspx

Jersey Financial Services Commission (JFSC)

• 2026–2030 Strategy (explicitly aligned with Time to Win) https://www.jerseyfsc.org/publications/2026-2030-strategy/
• 2026–2027 Business Plan (PDF) https://www.jerseyfsc.org/media/ptpbkinn/2026-2027-business-plan.pdf
• JFSC announcement of new strategy and business plan (23 March 2026) https://www.jerseyfsc.org/news-and-events/new-strategy-and-business-plan-focussed-on-economic-growth/
• JFSC statement on the Government Competitiveness Programme https://www.jerseyfsc.org/news-and-events/government-competitiveness-programme/
• Catch-up page from strategy & business plan launch (includes slides) https://www.jerseyfsc.org/news-and-events/catch-up-on-our-strategy-and-business-plan-launch/