This is Phase 1 of a two-phase programme. Phase 1 focusses on modernising and simplifying the existing framework, while Phase 2 will examine broader structural questions, including whether legislative changes are warranted and whether tailored regulatory approaches could be developed for lower-risk categories of bank, given that current legislation provides for only a single class.

Key proposals

Removal of the "Top 1,000" restriction

The current BLP limits registrations to entities within the global "Top 1,000" banking groups by Tier 1 capital, or financial services conglomerates of equivalent size. The Consultation proposes removing this threshold, while retaining requirements for international activity, financial strength, and a satisfactory supervisory track record. Applications from entities that substantially, but not fully, meet these criteria may be considered where depositor risks are clearly mitigated.

This continues a trajectory of relaxation, the threshold was previously reduced from "Top 500" in 2014, following the post-crisis shift towards bail-in regimes.

New framework for Jersey start-up banks

The Consultation introduces, for the first time, a formalised approach to the licensing of de novo banks in Jersey:

• Assessment criteria include board and management experience, alignment of business model with Jersey's risk profile, and stress testing of the business plan against potential financial risks to Jersey in failure scenarios.
• Existing Jersey-based businesses evolving into banks would be assessed on regulatory history and business plans.
• A staged licensing pathway is envisaged: "in-principle" licences to support capital raising, followed by a mobilisation phase under restricted, time-limited conditions.
• Restrictions would be lifted only upon evidence of depositor risk mitigation and compliance with prudential and AML/CFT/CPF requirements.

Removal of managed bank and business continuity provisions

The JFSC proposes removing BLP provisions on managed banks and business-continuity-only registrations, on the basis that no such entities currently exist in Jersey and such structures are uncommon elsewhere.

Proposed removal of the letter of comfort requirements

The letter of comfort regime requiring a Jersey-incorporated bank (JIB) to obtain a parental letter confirming continuing financial viability is proposed for removal. The JFSC considers this requirement superseded by:

• Recovery planning requirements under Pillar 2, which now require JIBs to demonstrate how they can address solvency events through group support and internal actions.
• Resolution planning work by the Jersey Resolution Authority (JRA).

Financial support will instead be assessed through consideration of recovery plans.

Senior officer role

The JFSC is seeking views on the off-island senior officer requirement imposed on all branches under Article 11(2) of the Banking Business (General Provisions) (Jersey) Order 2002. Having established through AML/CFT/CPF work that senior officers form part of senior management, the JFSC is asking whether clarifying the expectations of the role would better support role holders and affected businesses.

General policy simplification

The Consultation also proposes removing general regulatory and application-process material from the BLP (to be communicated via the JFSC's website instead) and eliminating duplication of requirements already in the Code of Practice for Deposit-taking Business (the Banking Code). A draft revised BLP is provided as Appendix A.

Responding to the consultation

Stakeholders are invited to submit responses via the JFSC's online form by Friday 12 June 2026. The Consultation poses eight specific questions covering each key proposal.

For more information, the Industry update and consultation can be found here