A significant shift in Jersey's regulatory landscape

On 9 July 2025, the States of Jersey approved new legislation that will, for the first time, bring consumer credit under formal regulation. Subject to Royal Assent, the Financial Services (Jersey) Amendment Law 202- introduces "consumer credit business" as a regulated activity under the Financial Services (Jersey) Law 1998. This is a change that represents one of the most notable expansions of Jersey's financial regulatory framework in recent years.

The move is a response to growing calls for stronger consumer protection, as well as the need to align Jersey's oversight regime with comparable jurisdictions. Whether you're involved in lending, credit broking, debt collection or other forms of credit-related activity, this marks an important moment to reassess compliance exposure.

A summary of the changes

The new law introduces a broad definition of "consumer credit business", covering a wide range of activities including:

• Lending and hire-purchase agreements
• Credit broking and introduction
• Debt administration and collection
• Providing credit information services

A key feature is its two-tier regulatory model. Complex or high-risk activity will fall under the supervision of the Jersey Financial Services Commission (JFSC), while lower-risk credit activity will be overseen by Trading Standards under a lighter-touch framework. This dual structure allows for proportionate regulation that protects consumers without imposing unnecessary burden on smaller operators.

The framework has been designed with deliberate alignment to UK and Guernsey regimes, opting for a lighter approach where appropriate; notably mirroring Guernsey's more streamlined regime in areas such as exemptions and enforcement.

Will you be affected?

In short: any Jersey-based business offering credit to individuals.

Even if it forms a secondary part of your service, you should assess whether you fall within scope. That includes:

• Traditional lenders, including finance companies and credit card providers
• Retailers offering instalment or deferred payment terms
• Businesses brokering or referring credit arrangements
• Debt collection agencies

That said, the law provides for several targeted exemptions, designed to avoid unnecessary regulation of private wealth and low-risk activity. These include:

• Private lenders (under £5m, across no more than 10 consumers annually, with a short notice filed to the JFSC)
• Family and employee loans, and intra-group arrangements
• High net worth individuals who formally opt out
• Professional advisers providing credit services incidentally
• UK and Guernsey-regulated firms operating cross-border

Importantly, buy-now-pay-later and other short-term, interest-free arrangements remain excluded from credit broking requirements for now, though this could evolve in future regulation.

What businesses need to consider now

Although implementation is phased, it pays to be prepared. For now, the practical steps to consider include:

Map your exposure: Review your business activities to determine whether they fall within the new definition of consumer credit. This includes checking any credit terms, broking relationships or service add-ons.

Understanding where your activity falls: Will your business class as complex or high-risk activity will fall under the supervision of the JFSC or will you be subject to Trading Standards lighter-touch framework

Preparing for registration: Firms will have a six-month window to apply once the law is in force (timeline details can be found further in this article). This includes gathering relevant documentation, clarifying internal roles and reviewing governance procedures.

Reviewing consumer documentation: Consider how lending terms, contracts and client-facing materials may need to be updated to comply with new disclosure and consumer protection standards.

Timeline of changes

The law will formally commence in mid-2026, with exact timing to be confirmed by Ministerial Order. The implementation includes:

• 6-month application window for new registrations (extendable by the JFSC)
• 12-month protection period for existing operators to register or wind down
• Enforcement powers for both the JFSC and Trading Standards starting at the 12-month mark
• Pawnbroking oversight to follow later, once sector-specific guidance is issued

It should be noted that there will be no retrospective effect, only agreements entered into after the law comes into force will be subject to the new regime.

Staying ahead with horizon scanning

With phased implementation and more regulation still to come, including consumer protection measures and sector-specific guidance, businesses will need to remain alert.

At FGC, our horizon scanning support helps clients stay on top of developments like these, with clear analysis and practical support. If you need help interpreting the impact on your structure or preparing for registration, we're here to support you.