JFSC is simplifying regulation on COBOs from 13 April 2026

As part of The JFSC  Competitiveness Programme, the JFSC is introducing changes that reduce friction and make it easier for you to meet your regulatory responsibilities.

• From 31 March, the BENEFICIAL OWNERSHIP threshold collected on company incorporation rises to 25%, cutting routine admin for low‑risk incorporations
• From 13 April, COBO changes streamline processes and remove several consent requirements

These improvements support a more competitive business environment and clearer industry expectations.

Further details on the COBO changes and their implications for you are included below and on the JFSC website.

COBO: simplifying processes

Changes to the Control of Borrowing (Jersey) Order 1958 come into effect on 13 April 2026 following the Control of Borrowing (Jersey) Amendment Order 2026 (Amendment Order). These changes simplify requirements by removing the need for certain COBO consents.

Further information is available from the JFSC  industry update of 10 March 2026.

• https://www.jerseyfsc.org/news-and-events/changes-to-control-of-borrowing-order-to-streamline-regulation/

What’s changing

From 13 April 2026, several COBO consents will no longer be required. As a result:

• Some forms will be removed from the JFSC  website and myJFSC
• Those COBO consents have no further effect and therefore the requirement to notify us of any changes will fall away – this does not affect the validity of anything done in reliance on these consents

myJFSC updates will take effect at 17:00 on Friday, 10 April 2026, with downtime scheduled from 15:00 - 17:00 the same day.

As part of these changes, the JFSC  will:

• Remove the unit trust (UT) (non‑fund) and non‑domiciled scheme (NDS) (non‑fund) application forms
• Limit the non‑Jersey domiciled persons/arrangements form to offers circulated only to retail investors

myJFSC remains unchanged for Jersey Private Funds.

Securities Interests Register amendment

• A consequential amendment to the Security Interests (Registration and Miscellaneous Provisions) (Jersey) Order 2013 will also be made on 13 April.
• This will amend the definition of “prescribed unit trust” in Article 2 by removing the reference to COBO and including a grandfathering provision to ensure past actions are unaffected.

What will still require COBO consent

• You will still need to apply in writing for a COBO consent to:
• circulate offers to retail investors in Jersey for non‑Jersey domiciled funds
• raise capital or hold a register for non‑Jersey domiciled funds

Guidance to be updated

• The JFSC  will update relevant public documents, including:
• [Sound%20Business%20Policy]Sound Business Policy = https://www.jerseyfsc.org/industry/guidance-and-policy/sound-business-policy/
• [Jersey%20Private%20Fund%20Guide]Jersey Private Fund Guide = https://www.jerseyfsc.org/industry/guidance-and-policy/jersey-private-fund-guide/
• [Registry%20Processing%20Statement]Registry Processing Statement = https://www.jerseyfsc.org/industry/guidance-and-policy/registry-processing-statement/
• guidance on the circulation of offers in Jersey of non‑Jersey securities = https://www.jerseyfsc.org/industry/guidance-and-policy/circulation-of-offers-in-jersey-of-non-jersey-securities/
• Removal of webpages that no longer apply

Next steps for COBO

• Before 10 April, check any internal processes that refer to UT (non‑fund) or NDS (non‑fund) applications
• Use the updated COBO requirements from 13 April 2026, supported by updated guidance

Source

• https://www.jerseyfsc.org/news-and-events/simplified-regulation-strengthens-jersey-s-competitiveness/