2026 Fee Consultation

1. Executive Summary

1.1.    Consultation Overview

1.1.1.      The Guernsey Financial Services Commission (the “Commission”) is issuing this Consultation Paper proposing the fee rates and administrative penalties to apply from 1 January 2026, including:

• An overall proposed increase in fees of 3.9% (in line with current Guernsey inflation at the time of writing) for all fees. This is reflective of our view of the inflationary environment and prudent modelling and forecasts. 
• The rebasing of our Private Investment Fund (PIF) fees to improve the Bailiwick’s competitive position in the funds sector, with a change to the structure of fees for banded Investment Licensees – including a proposed new banding and consequent adjustments for Designated Administrators. 
• An adjustment to the banded Fiduciary fees in recognition of, and in response to, the growing disparity between firms at the top and bottom of the higher bandings as a result of recent mergers and acquisitions. 
• The introduction of banded fees, rather than a per employee fee, for Prescribed Businesses to make the costs simpler and fairer for businesses with fewer staff. 
• New fees, based on a “user pays” principle, to reflect the additional work and due diligence needed when positive approval is required for the following requests:  a change of Designated Custodian/Designated Administrator for a fund, a Transfer of Business between investment or fiduciary licensees, a change of General Representative for insurance firms and additional fund elements being added to a closed ended investment fund.  Linked to this the introduction of an annual fee in respect of individual elements/share classes of closed ended funds, mirroring the fee for open ended funds.
• Application and annual fees for firms wishing to undertake activities under the new Equity Release framework.  
• A material reduction to our VASP fees as the Commission continues to support and encourage innovation and the development of this emerging market. 

1.1.2.      The main purpose of these changes is to ensure that the Commission continues to have sufficient financial resources to meet its statutory objectives, including having the skilled staff needed to supervise firms in a proportionate manner, to meet international standards, and to make continued investment in new technologies.  We are also proposing other changes with the objective of helping to improve the competitive position of the Bailiwick within certain sectors.

1.1.3.      The aim of this Consultation Paper is to elicit feedback on the proposed 2026 fee rates.

1.2.    Affected and Interested Parties

1.2.1.      These proposals would directly affect all existing licensees, registered entities, and authorised entities, as well as any applicants for licensing, registration or authorisation. This Consultation Paper has also been shared with governmental bodies and industry bodies in the Bailiwick. A full list of parties with whom this Consultation Paper has been shared is included in section 3.3.

1.3.    Providing Feedback

1.3.1.      Responses to this Consultation Paper are requested by 8th October 2025.

1.3.2.      We welcome and strongly encourage respondents to provide feedback or comment. Responses are most useful when they:

• directly address a specific issue or question,
• provide a rationale and support for the opinions expressed, and
• suggest alternative solutions in the event of disagreement.

1.3.3.      Feedback may be provided online through the Engagement Hub. We also welcome meetings with industry bodies, or firms, when they have feedback that they would like to give please contact us on fees@gfsc.gg .

1.3.4.      Following appropriate consideration of any feedback received the Commission will provide a summary of feedback received, along with the final fees that will come into force from 1 January 2026, within a feedback paper on our website.