Since the LLC structure was introduced in Jersey in 2018, only 49 LLCs have been registered, a figure that suggests the current framework has constrained uptake. The JFSC, working with an industry working group, is now proposing four targeted changes designed to make the vehicle more versatile. Notably, none of the proposals require amendments to primary legislation; they are changes to the JFSC's own regulatory guidance only.

LLCs as corporate trustees. The consultation proposes permitting LLCs to act as corporate trustees, following recent amendments to the Trusts (Jersey) Law 1984 that removed the ambiguity over whether an LLC could satisfy the statutory requirements for a corporate trustee. This is a notable expansion of the LLC's functional role in Jersey trust structures.

Use for regulated financial services activities. The JFSC proposes to allow LLCs to carry on fund services business, trust company business, investment business, general insurance mediation business, and money service business under the Financial Services (Jersey) Law 1998 (FSJL). The consultation notes that neither the FSJL nor the LLC Law prohibits this, the change is to the JFSC's own guidance rather than to primary legislation. The standard authorisation process would continue to apply.

Removal of the "financially sophisticated investor" restriction. Currently, LLCs are limited to use by financially sophisticated investors or customers. The JFSC proposes to drop this restriction entirely. Key safeguards remain in place:

• Administration services must still be provided by a regulated trust company business.
• Regulated firms' duties under the relevant codes of practice, including the obligation to have due regard to customer interests, are unaffected.

Improved clarity of the guidance. The consultation includes a draft revised guidance note (Appendix A) intended to be clearer, more accessible, and more proportionate.

Taken together, these proposals represent a deliberate effort to reposition the Jersey LLC as a mainstream structuring option rather than a niche vehicle. The ability to use LLCs for regulated activities and as corporate trustees could make them a more competitive alternative to Jersey companies and limited partnerships in fund, trust, and financial services structures. The removal of the sophisticated investor limitation is particularly significant, as it eliminates a gating criterion that had no direct equivalent in the underlying legislation.

Responses can be submitted via the JFSC's online survey by 6 August 2026. The JFSC expects to publish its feedback, and outline implementation plans in September 2026.

The Industry Update can be found here.

The consultation can be found here and the executive summary here.