Jersey's most significant update to its private funds regime in nearly a decade comes into force this August and it will bring greater flexibility and a streamlined regulatory model for fund managers and service providers alike.

The Collective Investment Funds (Jersey Private Funds) Order 2025, which takes effect from 6 August 2025, builds on enhancements introduced in July 2024 and marks a further step forward in the evolution of the JPF framework.

Below, we break down what's changed, who it affects, and how to prepare.

What's changing?

A new approach to investor eligibility

The 2025 Order replaces the former "restricted circle of persons" test with a simpler "restricted group of investors" model. A fund offer now qualifies under the regime if:

• It is addressed to an identifiable category of persons
• It is communicated directly by the offeror or their appointed agent
• Only persons in that category can accept the offer

This brings Jersey in line with modern fundraising practices and removes unnecessary complexity around offer structuring.

The 50-investor limit is gone

One of the most practical changes: the longstanding 50-investor cap has been removed. The revised framework allows managers to raise capital from a larger pool of qualifying investors, without increasing regulatory burden, providing that the offer remains within the clearly defined restricted group.

Enhanced regulatory status

From 6 August 2025, JPFs with consents granted under the new framework will no longer be treated as collective investment funds under the CIF Law. That removes an entire layer of classification and provides welcome clarity around fund categorisation and obligations.

A clearer, faster application process

Jersey has long been known for its 48-hour turnaround on JPF applications; the revised regime goes a step further, offering a 24-hour response time for complete submissions, backed by a streamlined regulatory test and a refreshed JPF Guide.

Building on the July 2024 foundations

This Order follows the July 2024 updates to the JPF Guide, which already introduced:

• Broader recognition of co-investment vehicles
• New "professional investor" categories (including financially sophisticated employees and expert consultants)
• Expanded criteria for Jersey-resident directors
• Clarified provisions for family and employment connections

The August changes now go further by recognising US accredited investors under SEC Regulation D, strengthening Jersey's ability to accommodate cross-border investor bases.

What does this mean for fund managers and service providers?

For fund managers:

• Raise more – the investor limit no longer applies
• Reduced regulatory burden – JPFs no longer trigger CIF Law treatment
• Get to market faster – authorisations in 24 hours
• Greater certainty – clearer legal footing across the board

For service providers:

• Fewer regulatory burdens – expanded exemptions under the Professional Investor Regulated Scheme (PIRS) Orders
• Smoother onboarding – less ambiguity in fund classification and streamlined compliance requirements
• Operational clarity – legislative support for procedures and controls

Jersey's strategic position

With more than 700 JPFs established since the regime's launch in 2017, these latest changes further cement Jersey's status as a leading funds domicile. The updated framework reflects a broader commitment to:

• Regulatory innovation – evolving legislation in step with market feedback
• Competitive positioning – staying ahead of other jurisdictions through clarity and speed
• Industry collaboration – shaping reforms in partnership with the local funds community
• Legal certainty – formalising operational flexibility within a clear statutory regime

These enhancements send a strong signal to fund managers and service providers alike: Jersey remains a jurisdiction that listens, adapts and leads.

Transition notes

• Existing JPFs remain under the current framework, unless they choose to apply for updated consents under the new Order
• New applications from 6 August 2025 benefit automatically from the updated framework
• Professional service providers will gain expanded licensing exemptions under amended regulations

What next?

These changes once again reinforce Jersey's position as a responsive, regulatorily mature funds jurisdiction. But they also require fund managers and administrators to revisit how they structure and document JPFs going forward.

If you're currently operating JPFs or planning to launch new structures, now is the time to:

• Reassess investor eligibility processes
• Review offering documents, consents and fund governance
• Align internal policies with the updated JPF Guide

At FGC, our horizon scanning support helps legal and governance teams stay on top of developments like this. Early insight, clear analysis and practical support will help you adapt with confidence.