Guernsey Funds Legal and Regulatory Update – September 2026

An overview of Guernsey legislative and regulatory developments relevant to investment funds for the period 2 June 2026 to 1 September 2026

1.  Digital Finance – Update

The Guernsey Financial Services Commission (Commission) has continued to advance its digital finance strategy through measures designed to facilitate the tokenisation of investment products while maintaining regulatory standards and investor protections.

Key developments include:

• Guidance on tokenisation: the Commission has published new guidance (Guidance) confirming that investment funds, securities and a wide range of other assets may be tokenised within Guernsey’s existing legal and regulatory framework. The Guidance confirms that tokenised interests can be issued, transferred and recorded using distributed ledger technology, with both public and private blockchain solutions capable of being accommodated subject to appropriate governance, security and operational controls.
• Technology-neutral regulation: the Commission has reaffirmed its ‘same activity, same risk, same regulatory outcome’ approach, making clear that tokenisation does not alter the underlying regulatory treatment of a fund, security or other asset.
• Practical applications for funds and securities: the Guidance recognises the potential for distributed ledger technology and smart contracts to improve efficiency across the investment lifecycle, including the issuance, transfer and administration of fund interests and securities. The Commission also notes growing interest in tokenised structures across sectors, including investment funds and insurance-linked securities.

Legal certainty and market accessibility: Guernsey’s existing legal framework permits ownership records to be maintained using distributed ledger technology and recognises electronic records more generally, providing a foundation for the development of tokenised investment structures. The Commission has emphasised a pragmatic approach to innovation while maintaining appropriate governance and compliance standards.

2.  Fund Foundry

Following the launch of the Fund Foundry programme earlier this year, which Mourant supports as a law firm sponsor, Guernsey’s Committee for Economic Development has announced that it will contribute £25,000 towards its delivery.

The Guernsey-based initiative is designed to support five first-time or emerging fund managers through a structured 12-month programme as they establish Guernsey domiciled investment funds and grow their fund management businesses.

3.  Commission’s Annual Report 2025

The Guernsey Financial Services Commission (the Commission) has published its 2025 Annual Report (Report) highlighting a year of regulatory delivery, policy reform and investment in technology to support innovation and growth in Guernsey’s financial services sector.

Key developments include:

• Innovation and digitalisation: the launch of the Digital Finance Initiative, a programme which supports the positioning of the Bailiwick of Guernsey (Bailiwick) as a trusted, agile and forward-thinking jurisdiction for digital innovation; and the completion of the Commission’s Applications & Authorisations Portal – a secure digital platform enabling all regulatory applications to be submitted electronically.
• Policy and regulatory development: measures aimed at supporting Guernsey’s competitiveness and resilience, including:
  • enhancements to the Prospectus Rules and the Private Investment Fund (PIF) regime, including streamlining the framework and permitting licensed fiduciaries, in addition to fund administrators, to act as designated administrators of PIFs
  • sustainability-related regulatory developments, including the Commission’s publication of feedback on sustainability reporting, reflecting the Commission’s ongoing commitment to maintaining the Bailiwick’s reputation while avoiding unnecessary burdens on well-managed firms.
• Stable sector outlook: Guernsey’s financial services sector remained stable during 2025 despite global uncertainty. Applications were approximately 5% higher than in 2024, with particularly strong performance in the investment sector, including the strongest year for PIFs since the regime was launched in 2017. The Report highlights continued demand for investment funds and other investment vehicles, with the investment sector contributing strongly to increased application activity during the year. Activity in the fiduciary sector appears resilient, while the insurance sector saw an increase in new licence applications. The Commission notes opportunities arising from technological developments such as AI, tempered by increasing risks including cyber security and geo-political factors.

The Commission has again produced a podcast on the Report which uses AI-generated scripting, voices and music to help make the report and financial statements easier to explore.

4.  Investment Statistics: Quarter 1 2026

Investment statistics for Quarter 1 of 2026 have been published by the Commission and are available here. Notably, the total net asset value of Guernsey funds at the end of the quarter was £272.6 billion. Within these totals, Guernsey closed-ended funds increased over the quarter by £4.5 billion (+2.0%) to just under £229.0 billion.

5.  Sustainable Finance Award

Guernsey has won the Sustainability Programme (UK) category at the WealthBriefing Wealth for Good Awards 2026. The award recognises leadership in sustainable and responsible investment and reflects the collective work of Guernsey’s government, industry and the regulator in developing a credible sustainable finance ecosystem.

The Commission has played an important role in supporting the development of Guernsey’s sustainable finance offering through regulatory frameworks designed to promote credible sustainability-linked investment products and enhance investor confidence in sustainability-related claims.

This has included the introduction of the Guernsey Green Fund, the world’s first regulated green fund regime, and the subsequent launch of the Natural Capital Fund designation for investment schemes that contribute positively to nature or significantly mitigate adverse environmental impacts.

6.  Appointment of Finance Sector Concierge

Guernsey has appointed its first Finance Sector Concierge (Concierge), creating a single point of contact to help businesses considering Guernsey engage with government, the Commission, Guernsey Finance and other key stakeholders at an early stage. The Concierge will also assist in navigating the regulatory, legal, immigration and practical requirements associated with establishing a presence in the jurisdiction. Created following a recommendation of Guernsey’s Finance Sector Growth Strategy 2035, the role is intended to support business growth and inward investment. Further details are available here.