JFSC AIF code to align with the EU’s Alternative Investment Fund Managers Directive II

JFSC Feedback on changes to the JFSC alternative investment fund code to align with the EU’s Alternative Investment Fund Managers Directive II

The Jersey Financial Services Commission (JFSC) has released feedback from its recent consultation on proposed amendments to the Code of Practice for Alternative Investment Funds and Alternative Investment Fund Services Business (AIF Code). These amendments are designed to ensure Jersey’s regulatory framework remains aligned with the EU Alternative Investment Fund Managers Directive II (EU AIFMD II) ahead of its implementation deadline of 16 April 2026

• On 2 October 2025, the JFSC published a consultation paper on changes to the JFSC code of practice for alternative investment funds and alternative investment fund services business (AIF Code) to transpose the EU Alternative Investment Fund Manager Directive II (EU AIFMD II). The JFSC asked relevant stakeholders for their views on the proposed changes and their impact.
• On 9 MARCH 2026, the JFSC have published feedback from the JFSC's recent consultation about changes to the JFSC code of practice for alternative investment funds and alternative investment fund services business, to align Jersey’s framework with the EU’s Alternative Investment Fund Managers Directive II (AIFMD II).

Strategic Importance

• The proposed updates are essential to preserve Jersey’s continued access to EU markets via the private placement regime by maintaining equivalence with the evolving EU AIFMD standards

Consultation Outcomes

• The JFSC received one industry response, which confirmed that the proposed amendments would not have any material impact on Jersey-based firms
• Stakeholder feedback supported the regulatory alignment needed for continued EU market access.

Planned Structural Changes to the AIF Code

• Recognising the regulatory divergence between the EU and UK AIFM regimes, the JFSC proposes splitting the current AIF Code into two streamlined frameworks:
• EU‑Focused AIF Code – incorporating all requirements arising from EU AIFMD II, to be published ahead of the EU implementation date (16 April 2026)
• Future UK‑Focused AIF Code – to be introduced once the UK finalises its own post‑Brexit AIFMD reforms. Until then, the current AIF Code remains applicable for UK‑related AIFM activity

Regulatory Context

• Jersey currently operates a dual AIFM regime, ensuring compliance with both EU AIFMD and UK AIFM Regulations to maintain market access in both jurisdictions.
• The EU finalised its AIFMD II updates in April 2024, with implementation required by April 2026.
• The UK, however, is still developing its AIFMD reforms, creating increasing divergence between the two regulatory landscapes.
• The JFSC’s decision to bifurcate the code will ensure regulatory clarity, continued compliance, and market continuity for Jersey funds targeting both EU and UK investors.

Next Steps

The JFSC will proceed to:

• Publish the EU‑focused AIF Code ahead of the EU’s go‑live date of 16 April 2026.
• Maintain the current AIF Code for UK purposes until a dedicated UK‑focused AIF Code is finalised

SOURCE

• Read the JFSC feedback on changes to the alternative investment fund code to transpose the EU’s Alternative Investment Fund Managers Directive II.
• https://www.jerseyfsc.org/media/4u4fqv0b/feedback-on-changes-to-the-aif-code-to-transpose-the-eu-s-aifmd-ii.pdf