Changes to Jersey’s Control of Borrowing Regime

However, as part of the continuing and wide-ranging Government-sponsored initiative to streamline the island’s regulatory processes and reduce unnecessary administrative burden, the Government of Jersey has announced the intention to overhaul the COBO Regime, with the first round of changes to become effective on 13 April 2026:

1. Non-Fund Unit Trusts: the requirement to obtain a COBO consent to establish a unit trust will be removed (other than for investment funds). This will facilitate the efficient set-up of non-fund  Jersey property unit trusts, which remain popular for UK real estate investment.
2. Non-Jersey Entities: non-Jersey entities (other than investment funds) will no longer need a COBO consent to raise capital or be registered in Jersey, which is particularly helpful to entities that engage a group administrator in Jersey.
3. Financial services business exemptions: service providers will no longer need to obtain a relevant COBO consent to rely on certain exemptions from regulation to carry on investment business or trust company business under Jersey’s financial services legislation.
4. Circulation of Prospectuses: except where a prospectus is circulated to retail investors by a non-Jersey issuer, the obligation to obtain a COBO consent will fall away.

These changes (which also apply to entities relying on an existing COBO consent) mark the first tranche of reforms to the COBO Regime, ahead of its anticipated expected abolition in 2027, and represent a welcome simplification of Jersey’s regulatory framework.

For more on the enhancements to Jersey’s financial services offering, visit our posts on Amendments to the Jersey Private Fund Guide 2025 and Proposed Improvements to Jersey’s Sound Business Practice Policy – Maples Group.

Please reach out if you have any questions on this topic or for general regulatory compliance advice.