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Jersey outsourcing [OSP] rules – BEWARE "newly caught" Supervised Persons have SIX [6] months to act


JFSC Feedback on Revised Outsourcing Policy [OSP] Follow-on Consultation was published on 04 July 2023, and will the updated OSP will be effective from 1 January 2024, after a six-month transition period.

However, where Supervised Persons

  • Who are "NEWLY CAUGHT" by the Revised OSP and
  • Have existing outsourced services BUT HAVE NOT NOTIFIED the JFSC under the current OSP [no requirement to notify].
  • Must NOW make a full Outsourcing Notification ON OR BEFORE the expiry of the six-month transition period,

On this matter, the JFSC says:-

  • Paragraph 6.4 relating to 'Material Change to Outsourcing Notification' has been amended in the final form Revised OSP to provide as follows:
    • "6.4.1 A Material Change to Outsourcing Notification form is available and must be made via myJFSC in the event of:-
      • ANY MATERIAL CHANGE(S) to an existing Outsourcing arrangement in respect of which, either
        • A No Objection has been granted or,
        • In respect of which an Outsourcing Notification has been submitted but which did not require a No Objection in accordance with paragraph 3.6.5:-
          • "3.6.5 Where a Business Outsources the performance of Outsourced Activity in the form of
            • Cloud Services, Data Centre Services, Cyber Security Services or E-ID Services to a Service Provider,
          • Whilst the relevant Business must still submit an Outsourcing Notification in respect of such Outsourced Activity, IT WILL NOT REQUIRE A NO OBJECTION.
          • As such, the submission of an Outsourcing Notification in respect of THE FOLLOWING will be a straight-through process.
            • Cloud Services, Data Centre Services, Cyber Security Services or E-ID Services
          • PLEASE NOTE
            • No Outsourcing Notification will be required for Cloud-based email services, which are standardised and pre-packaged services available to the general public, such as Microsoft 365."
          • 4.4 Where a No Objection was not previously required but is now required under the OSP (for example where a Supervised Person is newly caught by the OSP in respect of its Outsourced Activity),
            • An Outsourcing Notification will be required in all circumstances.
          • Only once an Outsourcing Notification in respect of the relevant Outsourced Activity has been submitted, and a No Objection granted, where required,
            • Does the Material Change to Outsourcing Notification become relevant
          • Unless, as set out under paragraph 6.4.1,
            • There is new Outsourced Activity in which case, the Business must submit a new Outsourcing Notification and obtain a further No Objection.

See attached – revised OSP

Read the follow-on consultation and revised outsourcing policy feedback here:-


  1. The JFCS has published feedback on the follow-on Consultation to its Revised Outsourcing Policy (OSP).
  2. This feedback shows the JFSC response to comments received to the Follow-on Consultation from Industry participants.
  3. The final revised OSP is in Appendix A and is effective from 1 January 2024 after a six-month transition period.

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