Jersey Financial Services Commission Annual Report 2025

Contents

Performance report

3  Chair's statement

5  Director general's statement 7  Key stats

8  Who we are

10  Performance analysis

11  Supervision

13  Registry

14  Supervision and Registry

service data

16  Policy

17  Innovation Hub

18  Enforcement

19  Intelligence

20  Enabling functions 21  Development of the

2026-2030 strategy

22  Key performance indicators 25  Industry survey

27  Complaints

28  Outreach and engagement 29  Financial overview

30  Risk, legal and data protection 33  Environmental, social

and governance

Accountability report

36  Our team

38  Governance structure 39  Governance statement 44  Remuneration and

employee report

46  Gender pay gap report

Financial statements

48  Independent auditor's report

54  Financial statements

58 Notes to the financial statements

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Chair's statement

2025 was a year of continued geopolitical instability, with slower growth in several major economies and rising competition between internationa finance centres. There are clear risks in this environment but also increased opportunities, particuary in digita assets and AI.

I am delighted to see increasing interest

from banks, funds, and other financial

institutions in the island. This has been

facilitated by a much more joined up

approach to onboarding new businesses.

Our new strategy is designed to build  

on this collaborative and principled

approach.     2025 strategic delivery

We remained focussed on our 2021-

2025 vision to be a high performing

regulator, building for the long-term

success of Jersey. We progressed our  Key strategic activity included:

2025 business plan under our strategic  Facilitate business integrity priorities of:

• facilitating business integrity  implementing our MONEYVAL

• harnessing technology action plan to maintain  

Jersey's international reputation

• developing our people,  for effectiveness in combatting systems and capability financial crime

The progress is not complete, nor is   laying the groundwork for a new it yet reflected in the industry survey, consumer credit regime to ensure and we know we have more to do in  consistently high standards of embedding our new ways of working.  consumer protection

• consulting and publishing feedback on sustainabe finance to provide  clarity for industry
• progressing fees reform to support Jersey's economic growth and uphold our reputation as a trusted regulator  and registry  

Harness technoogy and influence the digitaisation of financia services

We recognise the importance to our stakeholders of improving our digital channels. This focus will be carried through to our new strategy. In 2025 our work included:

• progressing our data strategy, which has significantly reduced time to load and analyse data from industry
• operationalising obliged entity access to beneficia ownership information, increasing transparency and meeting international standards
• laying the groundwork for improvements to our digital platforms, including transferring our website to a new provider and considering the long-term direction of the myRegistry portal
• significanty streamining the special purpose vehicle form, transitioning from a paper-based process to a fully digital one
• laying the groundwork to operate new primary legislation for intellectual property registers

Develop our people, systems and capability to be a high performing organisation

Following sustained improvements, our employee turnover at the end of 2025

was the lowest it's beenin five years, at 11% for the trailing 12 months. Employee sentiment has also tracked positively in

our most recent survey.

Our industry survey highlighted the need for continued focus on improving our service levels. We made important progress in this area in 2025. Our

new strategy will support the more fundamental changes we are planning, including a cultural shift to empower our people to be more commercially aware and service orientated.

years include the successful outcome of Jersey's fifth round MONEYVAL mutual evaluation, which confirmed that our effectiveness in preventing financial

crime is among the highest level found in jurisdictions evaluated around the world.

We also made significant progress with our people strategy, with a particular

focus on training and development, so

we can serve our stakeholders better.

We are also focussed on those areas where we need to do more, including enhancing our digital platforms, continuing to improve service levels, and simplifying regulation and guidance.

Deveopment of our 2026-2030 strategy

In 2025 we defined our 2026-2030 strategy.

The Government of Jersey's financial services competitiveness programme

also moved forward at pace, a collaborative initiative involving the government, JFSC and industry, to support Jersey's continued success

as an international finance centre.

Both initiatives were a significant workstream for us in 2025, complemented by a strategic review of our registry to help us understand the long-term needs of service users, with a focus on the island's competitiveness, technology, and global best practice.

This process involved significant collaboration between our internal teams, government, industry and our other stakeholders, and I would like to thank all these groups for their valued input.

Our 2026-2030 vision is to be a

trusted regulator and registry, enabling Jersey's economic growth. We look forward to working with our stakeholders to make this vision a reality  and to support the long-term success of  Jersey.

Reflecting on our 2021-2025 strategy Jane Platt, CBE Key achievements over the past five Chair

Director General's  statement

2025 was a pivotal year for the JFSC

– one in which we continued to deliver against our strategic objectives

while preparing the organisation

for the next phase of its evolution. Our focus remained on keeping

pace with market developments

and supporting Jersey's global competitiveness, while maintaining the highest standards of integrity.

Across all divisions, our teams made

significant progress in delivering the

final year of our 2021-2025 strategy.

We saw increased interest in banking  Jill Britton licences, fund services businesses and

trust company business applications,  DJeirrseecytoFri nGaencinearal Sl ervices alongside the successful registration  Commission

of a new bank, reflecting confidence

in the jurisdiction.

Virtual asset service providers (VASPs)

were another area of growth. The

number of registered VASPs rose  laying the groundwork for the

to 15 in 2025, three times the level  repeal of the Control of Borrowing at the time of MONEYVAL's visit, framework to modernise and marking Jersey's evolution in the digital  streamline regulation

asset space. This was supported by

developing our policy on tokenisation   making Jersey private funds even and continued engagement with  more attractive to investors, industry on emerging technologies,  removing the 50 offer/investor cap, ensuring our approach remains  introducing 24-hour turnarounds for proportionate and forward-looking. JPF consents and broadening the

definition of professional investor Supporting island competitiveness

We also welcomed the opportunity Our contribution to the Government  to revisit the Schedule 2 framework,

of Jersey's financial services recognising its impact on industry. In competitiveness programme continued  2025 we proposed updates to Schedule at pace, helping to modernise, simplify  2 guidance, working closely with

and strengthen the island's business  industry and government throughout environment. Key actions we took in  the year to deliver changes which

2025 included: improve clarity and consistency.

  exempting ow-risk oca ending

activity from the regulatory perimeter

  reforming the Sound Business Policy

to make it easier to do business in Jersey

A view from our divisions

Overall authorisation numbers increased in our Supervision division, with enhancements to the Jersey private fund regime feeding into higher levels

of authorisations of this product in

Q4 2025. We continued to develop our conduct and prudential focus, while enhancements to our examinations process provided more transparency for industry.

Registry experienced higher levels

of activity, with an increased volume

of incorporations and fewer outflows, supported by improvements in

guidance and digital processes. This

was accompanied by significant and sustained improvements in service

levels, which we will continue to build

on in 2026.

Our Policy team has provided significant support to the policy development

aspect of the competitiveness

programme, alongside important

work to lay the groundwork for a new consumer credit regime and progress

Basel III reforms.

In Enforcement, we continued to see an increase in scams and fraud reports and referrals from our Intelligence division and other agencies. Cases are increasingly complex, and we received several requests for assistance from overseas authorities.

Operationally, we invested in tools and capability to improve efficiency and resilience. The introduction of AI tools, including access to Copilot, is helping

us streamline internal processes and

explore new ways to support our

teams. These changes reflect our commitment to modernisation while prioritising the human skills, judgment

and relationships essential to being an effective regulator and registry.

We have seen real momentum across

2025 to support competitiveness

and Jersey's long-term commercial success. There are important areas, however, where we need to do better.

Our industry survey results showed

that we have more to do to improve people's experience of working with us. Although improvements were delivered, we must continue to modernise our

digital platforms, ensure regulatory content is easier to navigate, and deliver more predictable, high-quality services. These will be central to our focus as we move into 2026 and beyond, with our new strategy playing an important role in driving momentum.

Complexity in certain supervisory and

policy areas continues to grow, requiring

us to maintain a strong focus on risk-

based prioritisation and proportionality.

As our change programme expands, we must remain attentive to capacity, pace

and strategic sequencing to ensure sustainable delivery.

I am proud of what our teams have achieved in 2025, and grateful for

the insight, challenge and partnership provided by industry, government and our international stakeholders.

We were pleased to participate in joint visits with the Government of Jersey and Jersey Finance to key markets

to collectively represent the island's strengths as an international finance centre and support new business opportunities.

As we look ahead, we do so with clarity of purpose, strengthened capability

and a strategy that aligns with Jersey's

long-term ambitions. I am confident

that, together, we will continue to

build momentum and deliver the

outcomes needed to support a thriving, competitive and well-regulated financial services industry.

Jill Britton Director General

Key stats

+16% increase

 registry incorporations

from 2024 to 2025

+20%

increase

in incorporations and registrations of new

companies processed

ithin agreed timeframe

+9% increase

in authorisations1 from 2024 to 2025

+13% increase

in post-incorporation submissions processe within two working day  

– from 83% in Q1 2025 t

Who we are

We support the ong-term success

of Jersey's financia services sector for the good of our entire island community. We do this through high-quaity, proportionate reguation and delivery of registry services that protect the pubic and fight financia crime, while also encouraging

the establishment and growth of egitimate business in the isand.

We are the anti-money laundering' and countering the financing of terrorism' supervisor for Jersey's financial institutions, virtual asset service

providers and designated non-financial businesses and professions. We are

also responsible for supervising

financial institutions for conduct and prudential purposes.

Alignment with island priorities

Our strategy supports the government's Future Jersey vision, namely the following Island Outcomes for economic wellbeing:

• business environment – Jersey is  an attractive and competitive place to do business
• jobs and productivity growth – Jersey encourages talented people to remain employed here, and attracts others who can help businesses grow, become more productive and help create better employment opportunities for islanders

We operate the island's registry, maintaining registers that include Jersey companies, business names, foundations, partnerships, and security interests.

Our guiding principles2 are set out in law to:

• reduce risk to the public of financial loss due to dishonesty, incompetence, malpractice or the financial unsoundness of financial service providers in Jersey
• protect and enhance the reputation and integrity of Jersey in commercial and financial matters
• safeguard the best economic interests of Jersey
• counter financia crime both in  Jersey and elsewhere

For information on our governance and accountability, see the governance  section of this report.

2 See Article 7 of the Financial Services Commission (Jersey) Law 1998 8

Our external-facing teams

All our teams work closely together to develop and deliver our business pan and strategic objectives.

Supervision

The Supervision division is responsible

for authorising and supervising financial services firms, registered businesses

and individuals. We maintain supervisory relationships and conduct on and off-site reviews to assess how firms:

  maintain the viability of their business

models

  manage their relationships with

customers

  develop controls to mitigate financial

crime risk

Policy

Our Policy team maintains the regulatory framework, keeping our handbook, codes and guidance up to date and aligned with global standards by working with government, industry and international standards bodies.

Enforcement

Our Enforcement division investigates and, where appropriate, takes or proposes action against businesses

and individuals for serious breaches of their regulatory and legal requirements. The Enforcement division also investigates and warns the public about scams and frauds.

Intelligence

We also communicate our supervisory

strategies and discuss emerging issues  Owuitrh I nEtneflolirgceenmceendti,v Sisuiopne rwviosriokns calnods ely with trade bodies representing firms  Registry, developing intelligence to

on the island.  enhance our activities as a risk-based Registry regulator. The Intelligence division is also

responsible for maintaining the JFSC's The Registry division's primary function  whistleblowing line and works closely

is to consider and assess incorporation  with law enforcement agencies and the applications to ensure they comply  Financial Intelligence Unit, Jersey.

with legal obligations and the island's

risk appetite. At the time of writing, our Innovation Hub

Registry division maintains 16 registers  The Innovation Hub supports the including Jersey companies, business  development and adoption of new

names, foundations, partnerships and  and innovative technology in financial security interests. services. The hub provides a dedicated

point of contact for firms toask for support on fintech-related issues and seek non-binding guidance on regulatory expectations.

9

Supervision

Financial crime

• 23 financia crime examinations undertaken in 2025 to assess the quality of firms' controls tomitigate financial crime
• seriousness ratings introduced for examination findings so firms can see what matters most, an important enabler of our risk-based approach
• valuable feedback gathered from examined firms to help us improve our visits in the future - we thank

them for their input

Conduct

Our visit programme included conduct risk reviews of:

• virtual asset service providers – to understand their implementation plans for the travel rule
• how non-bank firms understand risks to business models from economic changes and uncertainty
• conflicts of interest
• client treatment in the sale of retail insurance products
• the transparency of fees and charges on the sale of investment products

Fraud focus

We continued our work on fraud controls in banking, issuing

bite-sized feedback and collaborating with government on a new framework to strengthen consumer protection against scams and payment fraud.

Authorisations

Our Authorisations team saw increased interest from firms looking to relocate to Jersey or establish a presence here highlighting:

• our reputation as a well regulated and stable jurisdiction, including Jersey's positive MONEYVAL outcome
• the strength of Jersey's professional services sector
• the renewed message that our jurisdiction is open for business

Other activity included:

• an in-principe icence granted to a new bank, an important step in strengthening our ability to support new business in Jersey
• a 45% year-on-year increase in trust company business authorisations
• a significant increase in interest in Jersey private funds in Q4, following updates to the regime

*bank licence granted in principle

The Schedule 2 regime was introduced in 2023, hence the high number of registrations in 2024.

The increase in revocations in 2024 was due to changes to the anti-money laundering service provider regime, with entities/arrangements subsequently falling out of Schedule 2 registration.

Registry

Our work in 2025 combined improvements to operational delivery with long-term planning for developing the registry of the future.

Harness technology

and influence the digitaisation of financia services

 Obiged Entity Beneficia Owner

Register launched, a key milestone in improving transparency and meeting international standards

  special purpose vehicle form

digitised to significantly streamline processes for customers and reduce turnaround times

  comprehensive strategic review of

the registry completed to support   plans progressed for the long-term needs of service  property registers

users, with a focus on the island's

competitiveness, technology, and

global best practice

new intellectual

Operations

We continued to manage high volumes of incorporations and other filings, with fewer outflows.

Registry statistics  2025 2024 Live entities* 39,597 38,820 Total registrations* 3,267 2,859 Company incorporations 2,889 2,501 Company dissolutions 1,884 1,930 Company strike-offs 306 371 Companies migrated in (continuance in) 99 129 Partnership dissolutions cancellations 216 148

*The live entities and total registrations include all legal entity types.

Our data showed significant improvements across all service level agreements. Our focus now is to

sustain improvements to ensure more consistent "green" ratings against our SLAs. For more information, see the next page of this report.

This was supported by improved guidance for customers, increased outreach and engagement and the roll-out of customer service training for all registry colleagues.

All activities were underpinned by our ongoing commitment to the highest standards of data security.

13

Supervision and Registry 2025 service data

In 2025, we introduced external reporting of our performance against service level agreements. Overall, operational performance strengthened, with sustained improvements through the year across a range of metrics,

reinforcing reliability and efficiency in service delivery.

A green rating applies to 90% or higher achievement of the SLA, amber to 70%-89% achievement, and red to

69% and below.

A dip in Q2 was driven by rising volumes and increased submission complexity

requiring enhanced assessments.

Supervision service levels

Service level agreement Q1 Q2 Q3 Q4 Personal questionnaires processed  77%  73%  84% 72%

within 30 working days

Annual overview

By Q4, on average, applications took us 25 days to complete.

To help us target a green status, in Q1 2026 we will deploy internal enhancements to improve efficiency and speed of no objection for key and principal persons who have previously received a letter of no objection.

Jersey private funds applications  93%  74%  93% 95% processed in 48 hours (Q1 and 2),

24 hours (Q3 and 4)

Anti-money aundering service  93%  89%  92% 99% provider online forms processed in

5 working days

Annual overview

We performed strongly against this measure due to a combination of dedicated resources  and efficient workflow process. Across the year,93% of the 499 applications received were authorised within 5 working days.

Registry service levels

Service level agreement Q1 Q2 Q3 Q4 Incorporations and registration of  70%  59%  80% 84%

new companies processed within

agreed timeframe

Annual overview

Submissions increased by 14% in 2025 compared with 2024.

In Q2 there was a 56% year-on-year increase in priority 1-day submissions, suitable only for lower risk submissions, which affected overall performance against SLA. We engaged with industry to support understanding of when to use the priority

2-hour and 1-day tiers.

In Q4, all services (except for 2-hour priority) met SLA > 80% of the time. We must now build on these results to reach a green rating.

New business names registered  94%  96%  96% 96% within 2 working days

Post-incorporation submissions  83%  77%  96% 94% processed within 2 working days

Annual overview

We ended the year strongly against this measure due to a combination of dedicated resources and efficient workflow process.

Policy

Our focus in 2025 was on improving Jersey's regulatory framework by ensuring alignment with international standards and supporting the government's competitiveness programme.

Government of Jersey financial services competitiveness programme

The Government of Jersey's financial services competitiveness programme

is a major strategic initiative to

strengthen Jersey's position as an international finance centre, through collaboration across government,

industry and the JFSC.

We are playing a leading role in this complex programme of work including:

• reducing the regulatory burden for lower risk activity, by exempting certain local lending activity from parts of Jersey's financial crime framework
• streamlining and modernising Jersey's regulatory environment, by reforming the Sound Business Policy and making progress toward the repeal of the Control of Borrowing framework
• proposing updates to Schedule 2 guidance to improve clarity and consistency
• enhancing the Jersey private fund regime, removing the 50 offer/ investor cap, introducing 24-hour turnarounds for JPF consents

and broadening the definition of professional investor, making this product even more attractive to investors

The programme delivered clear, actionable recommendations in March 2026 to protect and grow Jersey's financial and related professional services sector.

Facilitate business integrity

• MONEYVAL action plan progressed, including consultations on anti-

money laundering, countering the financing of terrorism and countering proliferation financing handbook amendments and enhanced criminal background checks – proposals

were adapted in response to industry feedback concerning complexity and timelines

• Basel III consultations completed

on credit and operational risk and

further engagement carried out on systemic importance and leverage

ratio - Jersey's roadmap was adjusted

to reflect UK delays, maintaining a July 2027 go-live date, but shortening transition periods

• proposed consumer credit regime progressed through drafting and industry engagement, although the new legislative timeline has moved implementation to 2027
• consultation completed on sustainabe finance to support a proportionate framework for ESG requirements
• work carried out with government and industry to deliver effective amendments to the Companies (Jersey) Law

See a full list of our 2025 consultations and feedback, alongside upcoming consultations for 2026, on our website.

Innovation Hub

The Innovation Hub continued to support the adoption of innovative technoogy in Jersey's financia services sector, with a particuar focus on virtua assets.

We are a founder member of Jersey's AI Council, which brings together island expertise and understanding of AI, to encourage responsible and ethical usage.

Key activity included:

Enforcement

Our work in 2025 was shaped by rising complexity, with an increase in scams and fraud reports, many with an internationa nexus. We prioritised these cases to protect consumers, issuing timely public warnings.

Referrals from our Intelligence team and other agencies increased. Given

the growing complexity in cases, and with co-operation having to be sought from other jurisdictions, our cases required more evidence gathering and detailed investigation. This contributed to the length of time some cases are taking to reach a conclusion.

Despite these challenges, we delivered outcomes across a range of cases with a broad use of our enforcement toolkit, including public statements and letters of advice, and use of settlement to conclude cases.

Requests for assistance

from overseas authorities added further demands, with some requiring us to conduct formal compulsion interviews and extensive coordination in the gathering of evidence in Jersey.

We maintained our focus on addressing the most serious risks and continued to adapt our approach to ensure proportionate outcomes

and maintain confidence in Jersey's regulatory framework.

18

Intelligence

During 2025, the Intelligence team received intelligence from whistleblowers, in addition to sector-based reports across industry.

This intelligence underpinned proportionate regulatory responses, ranging from initiating enforcement investigations to implementing supervisory interventions to address identified risks.

We thank all parties who have provided intelligence to support the integrity of Jersey's financial services sector.

Enabling functions

Our enabling functions were essential to the delivery of the activity listed in this report, and include the following teams:

• Office for Director General, including Facilities and Company Secretariat

In 2025, 31 colleagues enjoyed a change in role through a promotion or internal move.

Resourcing

• headcount remained at 95% of plan all year

  People and Culture

  Finance and Change

• Marketing and Communications
• Risk
• Technology and Data

Key deliverables included:

Develop our people, systems and capability to be a high- performing organisation

Workforce engagement and sentiment

• our all-colleague survey saw an 81% response rate and a positive upward trend in scores across all divisions, with an average of 7.7 (out of 10) across all questions
• our employee net promoter score rose from +8 to +25, 9 points higher than the external benchmark

Career development and physical environment remained the areas attracting lower scores, and we are addressing this through:

• an office reocation in 2026, with significant work completed on this project in 2025
• continued focus on career development, with in-role promotion pathways for junior roles
• encouragement and support for all colleagues to have a personal development plan in place

• employee turnover reduced from

19% at the end of 2024 to 11% at

the end of 2025 (both on a trailing 12-month basis) - our lowest turnover rate in the past five years

Learning and development

• £365,000 spent on learning and development throughout the year
• 5,718 learning hours recorded
• service excellence training delivered to our Registry and Supervision teams and regulatory technical training delivered in Supervision

Harness technology and influence the digitalisation of financial services

• successful migration of our website to a new provider, establishing a strong foundation for significant enhancements in 2026
• Cyber Essentias Pus certification obtained, further demonstrating our strong commitment to the security of our systems and data following ISO27001 certification in 2024
• significant efficiency savings in the upload of industry data - we acknowledge that we have more to do to reduce the burden of data collection on industry, which will be a key focus of our new strategy
• Reggie 2.0 aunched , the next  iteration of our AI-powered regulatory chatbot

Development of the  2026-2030 strategy

Creating our new strategy was a major cross-divisiona workstream in 2025, invoving significant engagement with our external stakeholders, including government and industry bodies.

We published our new strategy

externally in March 2026, with the vision to be a trusted regulator and registry,

enabling Jersey's economic growth.

We will deliver our vision through four priorities: support growth, be risk-based and proportionate, combat financial crime and deliver excellent service.

Deliver  Support excellent  growth service

Trusted regulator and registry

enabling Jersey's economic growth

Be risk- Combat based &  financial proportionate crime

Our new strategy aligns to the needs

of the island's largest sector and the

outcomes from the competitiveness programme, which we have been

significantly involved with from the start of 2025. See page 16 for key successes delivered under this programme in 2025.

Read more about our 2026-2030 strategy here.

Read our 2026-2027 business plan here.

21

Key performance indicators

In our business plan we defined several KPIs tomeasure key activities in the delivery of our strategy. We committed to publish our performance against them in our annual reports for the duration of this strategic cycle, toprovide a quantifiable measure to track year-on-year performance.

KPI

18 internationa and 30 local engagements

by the Board of Commissioners and the Executive Directors Committee

Year-on-year improvement in industry survey results for:

1. Ratings of the JFSC as:

- an effective communicator

- operating consistently

- promoting tech

2. % of respondents who agree we support Jersey's competitiveness
3. % of respondents who agree we act in the best interest of Jersey

2025 result

- 48 international engagements

- 219 local engagements

i.

- effective communicator 5.4/10

- operating consistently 5.5/10

- promoting tech, 5.6/10

2. 57%
3. 52%

2024 result

- 30 international engagements

- 126 local engagements

i.

- effective communicator 5.6/10

- operating consistently 5.7/10

- promoting tech, 5.6/10

2. 67%
3. 66%

Narrative Target met.

We placed a particular emphasis on engagement throughout 2025, with significantly increased activity in comparison to the previous year.

Target not met.

These survey results show that we clearly have more work to do. We value industry engagement and feedback and

are committed

to delivering noticeable change for our stakeholders in these areas. For more information see the industry survey section of this report.

KPI 2025 result 2024 result Narrative

90% adherence to  1,088 MyProfile 1,018 MyProfile Target not met. published SLAs applications  applications

processed in 2025,  processed in 2024 –  We have not met 76.75% issued  69% with-in SLA the target across

within SLA both SLAs and have

As of 31 more work to do.

As of 31 December 2024,  Our service levels December 2025,  99% of annual  continue to improve 99% of annual  confirmations re- across our Registry confirmations turned. and Supervision returned.  teams (see service

metrics on page 14), and this will remain

an area of focus in

our next strategy.

One new end-to- Four core  Five core processes  Target met. end digital process  processes built and  built and deployed

per quarter deployed by end of  by end of 2024. The following 2025. processes were

fully digitised:

- special purpose vehicle (SPV) circulation of offers

- SPV securities issues

- SPV memorandum of compliance

- change of anti-money laundering service provider forms

Year-on-year improvement in employee annual happiness index survey

Average score 7.7/10

Average score 7.2/10

Target met.

Our focus on workforce engagement and stability delivered strong results throughout

2025 – for more information, see page 20.

KPI

Increase in proportion of employees with greater than two- year tenure from 50% to 75%

2025 result

67% have more than two years tenure

2024 result

61% have more than two years tenure

Narrative Target not met.

While we have not

yet reached the

75% milestone,

we continue to

see a positive

upward trend in

the percentage

of colleagues

with more than

two years' tenure. Average tenure

is 4.7 years, and

we have reduced employee turnover from 19% at the end

of 2024 to 11% at

the end of 2025 (on a trailing 12-month basis).

Industry survey

We carry out an annual survey to understand industry's views on how we are performing as a regulator and registry and track trends year on year.

Overall, 2025's survey results trended downwards, and we acknowledge that we need to make a step change to improve people's experience of

interacting with the JFSC. We must do better.

While we have made progress through our previous industry survey action plans, it's clear that a strategic response is also required to address recurring themes of competitiveness, engagement, service and online experiences.

Below is a summary of the survey's key themes and recommendations, and what we will do in response.

Key themes and recommendations Online experiences

Improve website usability and search functionality and make more fundamental improvements to the myJFSC and myRegistry portals.

Competitiveness

Support island competitiveness and avoid over-regulation.

What we will do

  continue to invest in technology, laying the

foundations for more substantial improvements to our website and the myJFSC and myRegistry portals

  explore how AI can enhance user experience

in Supervision, by enabling more straight- through processing of administrative tasks and streamlining the examinations process

  take forward actions from the strategic review

of the registry to support the long-term needs of users, including a focus on operational effectiveness, technology capability and continued investment in people and skills

  support legislative changes from the

government's competitiveness programme and implement those changes in the regulatory framework

  work with government and industry to review

the reliance framework and consider e-KYC solutions, recognising that KYC is a particular pain point for industry

  continue to work with government to repeal the

Control of Borrowing Order and streamline Schedule 2 to increase ease of doing business

For more detail, read our full report.

Complaints

In 2025, a total of 9 complaints were submitted to the JFSC, which are shown below by division.

1

1

1

6

Registry 6 Supervision 1

Governance 1

People and Culture 1

Of the nine complaints received in 2025, six were upheld. The primary issues identified by the complaints were systems and internal processes. The median time to resolve complaints was 12 days.

We have put measures in place so that we do not cause future complaints

for the same reasons. This includes adequate training of colleagues on internal systems and processes, as well as improving systems.

The reasons for not upholding the remaining three complaints were:

• one complaint related to actions taken in accordance with our statutory function and authority
• one complaint was due to an incomplete form
• one was a repeat of a previous complaint that had already gone through the complaints process

The overall number of complaints is very small in the context of the scale of our activities.

Alongside complaints, we also receive and resolve a number of queries and

other feedback from our stakeholders, including through our engagement programme. People raising queries

have the opportunity to ask for them

to be treated or recorded as complaints if they wish.

To provide a more rounded picture,

in 2025 we explored how we can also effectively capture and report on those issues where the individual did not wish to record a complaint. This resulted

in the development of a new policy

and procedure for recording broader expressions of dissatisfaction, which was implemented in Q1 2026. We

will assess these expressions of dissatisfaction for themes and areas where we can improve.

Outreach and engagement

In 2025, we carried out 640 local engagements with industry, government and other local stakeholders on:

  fees reform to support increased

transparency

  the development of our 2026-2030

strategy and the government's competitiveness programme

  sector-specific updates through

our regular meetings with trade bodies across the banking, private wealth, funds, law, estate agents, accountancy, compliance and non- profit organisations sectors

We also held events focussed on designated non-financial businesses and professions, non-profit organisations, regulatory consultants and

authorisations.

We held 114 internationa engagements including with:

  the International Organization of

Securities Commissions (IOSCO)

  the Group of International Finance

Centre Supervisors (GIFCS)

 the Global Financial Innovation

Network (GFIN), where we are now a board member

the Dubai Virtual Assets Regulatory Authority, including signing a Memorandum of Understanding

  EuroFi and Point Zero Forum,

ensuring we are well briefed on

global developments in AI, digital assets and enforcement matters

  the Central Bank of Bahrain,

presenting a joint report on tokenisation at the Insights Forum in Singapore

While levels of engagement activity have been positive, our focus now will be on ensuring more structured and purposeful activity, with designated contact points for trade bodies. This will be supported by an international programme of engagement, demonstrating our commitment to this important aspect of our activities.

28

Financial overview

Our 2025 results highlight the continued strength of Jersey's financia services sector and our commitment to transparency and delivering value for stakehoders.

Total income increased to £35.4 million (2024: £33.0 million), driven byhigher income from alterations, applications,

and transfer fees, alongside grant

income to support the development of intellectual property registers and not

for profit supervision.

During the year we advanced reforms

to our fees and funding model, guided by KPMG's independent review and industry feedback, focussing on making our fees clearer, fairer, and simpler.

Fee notices were published earlier to support industry planning, made more user friendly, and streamlined to reduce complexity.

Operating costs were £34.0 million

(2024: £32.4 million), with staff costs (2025: 67% of operating costs, 2024: 66%) remaining our largest area of investment. Through careful workforce planning and prudent vacancy management, we maintained staff costs below budget.

At year end, our accumulated reserves were £13.9 million (2024: £11.6 million), providing a strong foundation for

continued investment in our change programme, digital channels, registry

of the future, and regulatory framework.

Alongside these initiatives, our office move - funded from reserves - remains on track for completion in Q3 2026 and will deliver a modern working environment that enhances collaboration, resilience, and service quality.

These investments support our

strategic priorities and contribute to the Government of Jersey's competitiveness programme. Further information is available in our business plan.

Risk, legal and data protection

We remain committed to proactive and adaptive risk management. The risk landscape continues to evolve due to geopolitical tensions, macroeconomic uncertainty, rapid technological change, and demographic pressures.

We actively monitor macroeconomic and geopolitical developments, drawing on data to inform our responses. Our risk appetite is under constant review, which is essential to our 2026-2030 strategy and Jersey's broader growth and competitiveness agenda.

Through our enterprise risk management framework, we systematically identify, assess and manage principal risks facing the JFSC. Working collaboratively across our governance structures, we evaluate these risks and implement proportionate responses that protect the JFSC, strengthen our risk culture and support the delivery of our purpose.

Below are the high risks we have identified and are managing through our governance process:

Risk

People

Lack of capability and experience across the JFSC

to be able to meet business as usual demands as well as our strategic change agenda.

Third party

Inadequate management and oversight of third- party suppliers leading to service disruption and reputational risk.

Data

Failure to execute

on our data strategy ambitions impeding our ability to

capitalise on the benefits to both the JFSC and industry.

Insider threat

Confidential and/or sensitive information is misused by those with authorised access.

Strategic anchor

Develop our people, systems, and capability

Develop our people, systems, and capability

Harness technology / Develop our people, systems, and capability

Harness technology / Develop our people, systems, and capability

Mitigations

We have a dedicated training and development programme designed

to upskill our staff with the technical capabilities and future skills required for their roles and for the JFSC. This is supported by robust approaches to recognition, performance management, and succession planning. Progress against key measures that matter is regularly monitored and overseen by our executive and board.

Our response is underpinned by an established third-party risk management approach designed to identify, assess, and manage risks arising from third-party relationships at every stage of the lifecycle. Oversight of these activities is supported by a dedicated procurement officer.

We have a clearly defined data strategy with executive ownership, supported

by a programme of work designed to strengthen data governance, provide

training and upskilling, and deliver

enhanced tooling.

Insider threat risk is mitigated through

a structured data loss prevention strategy that safeguards confidential and sensitive information. Our egress monitoring detects and prevents unauthorised data movement. These controls are complemented by robust access management practices, including least-privilege principles and regular entitlement reviews, as well as a security culture supported through ongoing awareness and training programmes. The effectiveness of our information protection controls is independently assured and tested on a regular basis.

Data protection

Compliance with the Data Protection

(Jersey) Law 2018 is overseen bythe JFSC's designated Data Protection

Officer. Throughout 2025, no data protection breaches occurred that

required reporting to the Jersey Office of the Information Commissioner (JOIC).

In October 2025, JOIC published a public statement concerning a vulnerability detected in our Registry system in January 2024. Following its detection, and together with a forensic review, we commissioned an independent third-

party root cause analysis. All actions arising from this analysis have been completed, and we worked closely

with JOIC throughout this process.

We are deeply sorry this data breach occurred, and we fully accepted JOIC's findings and conclusions. We also appreciate JOIC's recognition of the

steps we have taken to address the

issues identified, and we remain fully committed to maintaining and enhancing the technical and organisational

measures necessary to ensure the continued protection of JFSC data.

Anti-bribery and anti-corruption

Under the Financial Services

Commissions (Jersey) Law 1998 we seek to secure a proper balance between

the interests of persons carrying on

the business of financial services, the users of such services and the interests of the public at large. We also require

relevant persons' systems and controls

to prevent, detect and report financial crime, including measures to mitigate

risk associated with money laundering,

terrorist financing, financial sanctions, bribery and corruption, proliferation

financing and carrying on sensitive business activities.

Conflicts of interest within the JFSC staff are strictly managed through formal

policies, routine background checks and

clear procedures covering areas such

as share dealing, gifts and hospitality.

The JFSC also publishes a Board of Commissioners' Code of Conduct on

conflicts of interest, which is specifically designed to ensure that regulatory

decisions remain impartial and free

from any improper influence.

Human rights

We are committed to respecting and   upholding recognised human rights,

and the JFSC is fully compliant with

Human Rights (Jersey) Law 2000.

Environmental, social  and governance

As a regulator and registry, our role,  Social

values and governance have a clear

aignment with ESG considerations.   we continue to measure employee

wellbeing through our employee

We are a values-led organisation,  survey, with sentiment trending

with social good built into our guiding  upwards in 2025 - see page 20 for principles of preventing financial crime, more information

protecting the public from financial loss

and safeguarding the best economic   significant activity from our employee interests of our island.  mental health and inclusion groups,

including mental health awareness

We have robust and transparent  week and baby loss awareness week governance, as laid out in the

accountability section of this report.   our gender balance can be found

in the remuneration and employee

Given our organisational operating  report on page 45

model and purpose, we have a simplified

ESG framework.   our mean gender pay gap reduced

to 7.6% in 2025 from 10.7% in 2024

We have focussed our ESG activity on  - our gender pay gap report can be

the following areas: found on page 47

Environmental

  the tender for our main construction

partner for our building move included ESG within the tender scoring to ensure it was a factor in our decision making

  colleagues participated in a

beach clean to support our wider community's environmental efforts

  we donated decommissioned

equipment to Highlands College, supporting local digital education and preventing waste

  all colleagues have access to secure

garages to encourage cycling to work

  the number of pages printed across

2025 reduced by 28% from 2024 following a colleague campaign with the purchase of each ream contributing to Durrell Wildlife Trust

 we provide mental health support

as part of our employee assistance programme

  we actively support colleague

volunteering for charitable organisations, including the opportunity to take two paid days to support a local charity, and undertaking honorary roles

  bias training is deployed as part

of our year-end performance management cycle

  the gender balance of

commissioners, executive directors and senior leadership is monitored to maintain appropriate levels

of representation

  all our cleaning products and methods

conform to British standards (BS EN)

Governance

  the JFSC is a member of external

ESG groups related to financial services, including the Network for Greening Financial Services and Jersey for Good

  the staff forum brings the voice of

the employee into the board

 our culture book supports a more

modern and progressive approach to employee related issues, specifically leading to greater accountability and

a fairer, more equitable workplace

  see the governance section of this

report for more details

Accountability report

Our Board of Commissioners

   Lynn Cleary

Commissioner

   Robert Milner

Commissioner

Our Executive Directors Committee

Governance structure

Audit and Operational   Remuneration  Nomination  Regulatory Risk Risk Committee Committee Committee Committee

Executive Directors  Executive Risk  

Committee Committee

Governance statement

Constitution

The JFSC is a corporate body established

under Article 2 of the Financial Services Commission (Jersey) Law 1998 (FSC(J)L) which provides that the Minister shall

appoint a Board of Commissioners

comprising persons with financial

services experience, regular users of

such services and persons representing the public interest.

Accountability arrangements

The JFSC operates independently of

the Government of Jersey, however

is accountable to the public through

the island's elected representatives, namely the Minister for External Relations and the States of Jersey. The relationship with Ministers is set out in a memorandum of understanding,

dated 10 December 2014, to ensure the operational independence of the JFSC, while facilitating effective dialogue and working practices.

Article 12 of the FSC(J)L provides that the Minister may give the JFSC general directions in respect of the policies to be followed by the JFSC in relation to the supervision and development of financial services in Jersey and the manner in

which any function of the JFSC is to be carried out, following consultation with

the JFSC and where it is in the public

interest to do so.

The JFSC produces an annual business plan and separately, this annual report, to inform members of the States Assembly and other stakeholders. The JFSC consults extensively on all proposals to create or amend laws and regulatory requirements and provides feedback statements to explain how responses were taken into account.

Governance arrangements

The Board of Commissioners (the board) maintains overall responsibility for

governance, setting strategic aims and supporting the executive director team

to put them into effect; and holding the executive accountable, within the scope

of the FSC(J)L and the powers that the JFSC has been granted under that law.

The board also oversees the running of

the board committees.

Led by Chair Jane Platt, the board believes in high quality and effective governance arrangements and, in the absence of specific codes or standards for the governance of a financial services regulator, the board uses the

UK Corporate Governance Code as a reference point for good governance practice but does not formally apply

or adopt the code or its provisions.

In line with the principles of the UK Corporate Governance Code, the JFSC's board establishes the strategy, and seeks to satisfy itself that this and its culture are aligned. In 2025 the JFSC developed a new strategy for 2026-2030.

The board is mindful of the level of resource required to negotiate an ever more complex regulatory environment, as well as supporting the need to meet international standards. It seeks to ensure that the necessary resources

are in place for the JFSC to meet

its objectives and looks to measure performance against those objectives by way of regular reporting on key performance metrics at board meetings. The board has established a framework of prudent and effective controls, which enable risk to be assessed and managed.

Mindful of its responsibilities to stakeholders, the board ensures effective  engagement with, and encourages participation from, these parties. This was further supported by an external engagement strategy, with the JFSC

seeking to strengthen its relationships both locally and internationally with active participation from commissioners as well as the senior management teams. This enhances Jersey's reputation internationally and improves communication and engagement

with industry.

The board plays a key role in listening to industry to understand issues, current trends, as well as international developments, and is actively seeking to improve the JFSC's interaction with industry. The board fully supports strategic engagement with industry bodies.

In terms of the JFSC's employees,

through its Remuneration Committee,

the board ensures that workforce

policies and practices are consistent

with the company's values and support

its long-term sustainable success. The JFSC's workforce can raise any matters

of concern via the formal route of an internal whistleblowing line or through attendance at the Staff Forum meetings. Commissioner Laurens is the employee engagement commissioner, with the role

of bringing the voice of the employee

into the boardroom.

There is a clear division of responsibility between the chair and the director general, who is also a board member. No individual has unfettered power of decision-making.

Delegation of powers

The board delegates certain powers to the director general to ensure that the JFSC can run smoothly on a day-to-day basis. The director general is responsible for the successful leadership of the JFSC, ensuring that Jersey's position as an international financial centre with high regulatory standards is maintained. In some areas, the power of the commissioners to delegate is restricted by legislation. For example, the board acts in a similar manner to a tribunal in relation to contested enforcement cases. Consequently, the board is more

involved in some areas of detail than a board of a listed or private company. A full explanation regarding the delegation of powers can be found on the JFSC's website: www.jerseyfsc. org/industry/guidance-and-policy/ delegation-of-powers

Director general's responsibilities

The director general is accountable to

the JFSC board, which is made up of

on and off-island commissioners. The director general is an ex officiomember of the board.

The director general:

• provides effective leadership of the JFSC in its day-to-day operations as both a regulator and a registry, ensuring the organisation delivers its strategic priorities
• works collaboratively with the board and the executive directors' team towards common objectives, fostering effective teamwork
• drives the transformation of capabilities through the implementation of strategy and the development of the JFSC's business plan (including financial budget)
• plays a leading role in Jersey's

financial services ecosystem working closely with government and industry

to deliver high standards of regulation and a sustainable future for the sector

• maintains and enhances effective supervision of Jersey's financial services sector with a particular focus on financial crime
• develops and strengthens good relationships with regulated firms, other regulators, and relevant international bodies
• is responsible for the effective  operation of risk management  framework and systems of internal  control

Composition of the board and appointment of commissioners

The board currently consists of the

chair, deputy chair and eight other commissioners, including the director general. Currently over three quarters

(78%) of theboard are women. All the commissioners are considered to be independent, with the exception of the director general. A chart of the current commissioners is set out on page

37 of this annual report and further information on their skills, knowledge

and experience is set out on the JFSC's website at www.jerseyfsc.org/about-us/ board-of-commissioners

New commissioners, Lynn Cleary

and Robert Milner, were appointed in September 2025. Commissioner Palmer retired from the board in August 2025.

Recruitment of commissioners follows

a rigorous and transparent process

in line with the Jersey Appointments Commission's guidance.

2025 board meetings and attendance

Commissioners do not sit on every committee. Where attendance is not applicable to the commissioner, this is marked by "-" in the table.

Audit and  Remuneration Regulatory  Nomination Operational  Risk

Risk

Commissioners Board Chair:  Chair:  Chair:  Chair:

Helene Narcy  Claire Bowes Megan Butler Jane Platt

(from August 2025)

Matt Palmer

(until August 2025)

Jane Platt (Chair) 8/8 -  4/4 - 3/3 Monique O'Keefe 8/8 - 4/4 4/4 3/3 Annamaria Koerling 7/8 - 4/4 - 3/3 Megan Butler 7/8 3/6 - 4/4 - Claire Bowes 7/8 - 4/4 - 3/3 John Laurens 7/8 6/6  - 4/4 - Helene Narcy 8/8 6/6  - - -

Matt Palmer –

4/5 4/4 - 3/3 - retired August 2025

Lynn Cleary –

appointed September  1/2 - - - - 2025

Robert Milner –

appointed September  2/2 - - - - 2025

The board met eight times during 2025 to consider strategy, risk and regular business.

In June 2025, the commissioners and the executive met for a strategy day to progress the development of the new JFSC strategy for 2026-2030, including the JFSC's role in the Government

of Jersey's financial services competitiveness programme, a registry strategic review and 2026/27 divisional plans.

The strategic focus of 2025 board agendas included stakeholder engagement, strategy development and further development of a risk-based approach to supervision.

Throughout the year, the executive

and commissioners participated in

events with fellow regulators, industry representatives and government

ministers. Frequent discussions took

place over the year with government relating to significant financial services matters.

Board members record their conflict of interests on the JFSC's register

of interest and are asked to make

annual attestations as to those entries.

Furthermore, commissioners consider

the potential for conflicts of interest to arise in meetings and recuse themselves should any perceived or actual conflict be identified.

Board effectiveness

The appointment of a new chair in 2024 and two new on-island commissioners in 2025 has provided new skillsets and experience. In 2025 the Nomination Committee refreshed the board skills matrix to ensure focus on the JFSC's strategic goals and requirements.

Nomination Committee

The board's Nomination Committee is responsible for reviewing the structure, size and composition (including the skills, knowledge, experience and diversity) required of the board and makes recommendations to the board about any changes.

Its principal focus in 2025 was to

finalise the recruitment of two new commissioners, Lynn Cleary and Robert Milner, in light of the recent retirement of Matt Palmer, and apending retirement.

Audit and Operational Risk Committee

The Audit Committee expanded its

remit in January 2025 to become the

Audit and Operational Risk Committee. It is responsible for monitoring internal financial control systems and works with the executive directors and the external

auditor to ensure the quality of the management financial reports and the annual accounts. It is also responsible

for overseeing the management of

operational risk across the JFSC,

ensuring that policies exist and the organisational structure, budget and

resources are appropriate to manage

the JFSC's principal risks. The committee

also oversees the development of (and ongoing monitoring against) the JFSC's operational risk appetite. During 2025, external auditors PKF Channel Islands

(a member of firm PKF International) were appointed by the board in

accordance with our governance

framework.

Responsibility for annual report and accounts

This annual report and accounts comply with the requirement in the FSC(J)L which require the Minister for External Relations to lay the report and accounts before the States Assembly no later than seven months after the end of the financial year.

The statutory obligations on the commissioners require that the

annual accounts shall be prepared in accordance with generally accepted accounting principles and show a true

and fair view of the surplus or deficit for the period and state of affairs at

the period end. The commissioners

have elected to prepare the financial statements in accordance with Financial Reporting Standard 102 (FRS102); the Financial Reporting Standard applicable

in the United Kingdom and the Republic

of Ireland.

Taking into account general practice,

the commissioners confirm that they are responsible for:

 keeping adequate accounting records

sufficient to show the financial position within a reasonable period of time

safeguarding the assets and for taking reasonable steps for the prevention and detection of fraud and other irregularities

preparing the financial statements in accordance with applicable laws and regulations

selecting suitable accounting policies and applying them consistently

making judgments and accounting estimates that are reasonable

and prudent

preparing the accounts on a going concern basis unless it is inappropriate to presume that the JFSC will continue in business

Remuneration Committee

As well as monitoring the level and structure of remuneration for senior management (directors at grade

nine and above) including individual performance against objectives, the Remuneration Committee provides

advice and counsel to the JFSC's executive in the production of remuneration policies and practices to support strategy and promote long-term sustainable success.

The director general and the executive director of people and culture also attend Remuneration Committee meetings.

Regulatory Risk Committee

Responsibility for risk and risk management remains with the full board. The Regulatory Risk Committee's main duty is conducting oversight of the JFSC's regulatory risk management approach, including its system of regulation and

the effectiveness of its regulatory risk identification, assessment, and response. In 2025 it principally spent its time working on the further development

of the JFSC's approach to regulatory risk, including sector risk reporting.

43

Remuneration and  employee report

The JFSC's remuneration principes are designed to support our strategic anchor of developing our people, systems and capabilities to be a high performing organisation. We seek to attract, develop and retain high calibre individuals with diverse backgrounds and experiences, and reward them for delivering outcomes and role modelling enabing behaviours.

We complete an annual external pay benchmarking exercise to ensure that our remuneration package remains competitive in the jurisdiction, which has a highly competitive labour market.

Metrics3

We report on several people metrics: 2025 employee split by grade/gender

Grade 1 is the lowest salary band, and 9 the highest.

Gender

• 57% of our total employee population is female
• our executive team has a 56% to 44% female-to-male ratio
• our commissioners have a 78% to 22% female-to-male ratio

Contract type

• 243 employees on permanent contracts
• 3 employees on fixed term contracts
• 0 employees on zero-hour contracts
• 4 employees on apprenticeship contracts
• 9 commissioners

Tenure (incudes ony permanent empoyees)

Average employee tenure is 4.7 years (for those on a permanent contract).

Learning and development £365,000 spent in 2025

Colleague remuneration4

Employees are split between nine grades.

Grades 7-9*

• 77 employees
• average salary: £106,636.20

Grades 4-6

• 139 employees
• average salary: £57,595.12

Grades 1-3

• 33 employees
• average salary £34,617.36

3 Alldata in the remuneration and employee report is presented as at 31 December 2025

4 Includes fixed term contracts, excludes director general *excludes director general 44

Board remuneration

The board comprises commissioners and the director general. Commissioners receive a fixed fee, and noadditional amounts are paid for participating in or chairing sub-committees, dealing with enforcement cases or attending to other matters.

The director general is a board member on an employment contract.

*Fees reflect an appointment or retirement part way through the year

Gender pay gap report

We voluntarily publish our gender pay  Gender pay gap report

gap as part of our ongoing commitment

to incusion and greater transparency. Below is our gender pay gap data for

2025 as at 31 December 2025:[1]

Definition of the gender pay gap

The gender pay gap is the difference between the average hourly pay for men

and women across an organisation. This figure is expressed as a percentage of men's earnings. Apositive percentage figure shows that women have a lower average hourly pay than men, whereas

a negative percentage shows that men

have lower average hourly pay than

women. In effect, the gender pay gap calculation functions as a high-level overview of an organisation's gender pay balance.

What the gender pay gap is not  Explaining our results

The gender pay gap is not a reflection Gender pay gap

on pay equity, which refers to men and  The mean gender pay gap of 7.6%

women receiving equal pay for doing the  has improved from the 2024 position

same or similar jobs. All JFSC colleagues of 10.7%. Overall, women's average

are remunerated on externally  (or mean) salary is marginally lower benchmarked pay scales with equivalent  than men's average salary.

pay for comparable positions, therefore

ensuring pay equity.  In many organisations a gender pay

gap indicates a lack of women in senior

Mean calculation  positions, however this is not the case at

We use the mean calculation for  the JFSC. At all levels other than grade simplicity and ease of understanding.  8, there's either gender balance or a

The mean pay gap is calculated by  greater proportion of female colleagues. adding up the hourly pay of all the  The core disparity is in our junior grades

female colleagues in the JFSC and  2-4, where there is a significantly greater dividing that by the total number of  proportion of women to men, which

females. We then do the same sum for  impacts the average pay by gender, thus

male colleagues and compare the two  explaining the mean gender pay gap.

figures, expressing the result as a % of

men's salaries.

Bonus pay gap

Our discretionary bonus scheme is performance based, with a link between performance rating and a bonus range. This year we have a –12.17% bonus gap, meaning women's average (or mean) bonus was higher than men's average bonus.

To be eligible for a bonus, colleagues must have been in employment for a qualifying period and have met required performance thresholds. Individual awards differ based on individual performance and contribution.

The negative bonus gap can be explained by several factors including:

 differing performance ratings

  proportionally, more women met the

bonus eligibility criteria

  the higher proportion of women to

men at grades 7 and 9 (whohave higher salaries and therefore higher average bonuses)

In support of our people strategy vision to be a leading employer in Jersey,

we have an aspiration to develop

an inclusive culture with a diverse workforce. We include awareness of bias and discrimination within our manager training to drive appropriate decisions around performance assessment and remuneration.

1 All gender pay calculations are based on both temporary and permanent colleagues, while

contractors, agency employees and secondees have been excluded. 47

Independent  auditor's report

to the Minister for External Relations of the States of Jersey Opinion Basis for opinion

We have audited the financial

statements of the Jersey Financial

Services Commission (the Commission') for the year ended 31 December

2025 which comprise the Income and Expenditure Account, the Statement

of Financial Position, the Statement of Changes in Accumulated Reserves, the Statement of Cash Flows and Notes

to the Financial Statements, including

a summary of significant accounting policies. The financial reporting

framework that has been applied in

their preparation is applicable law and

United Kingdom Accounting Standards, including Financial Reporting Standard

102 The Financial Reporting Standard applicable in the UK and Republic of

Ireland (United Kingdom Generally Accepted Accounting Practice').

In our opinion, the financial statements:

• give a true and fair view of the state of the Commission's affairs as at 31 December 2025 and of its results for the year then ended;
• have been prepared in accordance with United Kingdom Generally Accepted Accounting Practice; and
• have been prepared in accordance with the requirements of the Financial Services Commission (Jersey) Law 1998.

We conducted our audit in accordance

with International Standards on Auditing (UK) (ISAs (UK)), the Code of Audit Practice (December 2023) issued by

the Comptroller & Auditor General, and applicable law. Our responsibilities under

those standards are further described

in the Auditor's responsibilities for the audit of the financial statements section of our report. We are independent of

the Commission in accordance with the

ethical requirements that are relevant

to our audit of the financial statements in Jersey, including the FRC's Ethical

Standard, and we have fulfilled our other ethical responsibilities in accordance

with these requirements. We believe that

the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Conclusions relating to going concern

In auditing the financial statements, we have concluded that the Commissioners'

use of the going concern basis of

accounting in the preparation of the

financial statements is appropriate.

Based on the work we have performed,

we have not identified any material uncertainties relating to events or

conditions that, individually or collectively, may cast significant doubt on the Commission's ability to continue as a

going concern for a period of at least

twelve months from when the financial statements are authorised for issue.

Our responsibilities and the  responsibilities of the Commissioners with  respect to going concern are described

in the relevant sections of this report.

48

Key audit matters  and any comments we make on the

results of our procedures thereon, were

Key audit matters are those matters that,  addressed in the context of our audit

in the auditor's professional judgement,  of the financial statements as a whole, wtheerefinoafn mc oiaslts st ia gt ne imfice an nts ceofinththeecu aurr de in tt of awneddion nfoortmpirnogv iodueraopseinpioa nra tt he e orpeionnio, na nodn

period and include the most significant these matters.

assessed risks of material misstatement

(whether or not due tofraud) identified We summarise below the key audit

by the auditor, including those which had  matters in forming our audit opinion,

the greatest effect on: the overall audit  together with an overview of the principal strategy; the allocation of resources in  audit procedures performed to address the audit; and directing the efforts of  each matter and key observations arising

the engagement team. These matters,  from those procedures.

Materiality

The scope of our audit was influenced by our application of materiality. We

set certain quantitative thresholds

for materiality. These, together with qualitative considerations, helped us

to determine the scope of our audit

and the nature, timing and extent of

our audit procedures on the individual

financial statement line items and disclosures and in evaluating the effect

of misstatements, both individually and

in aggregate on the financial statements as a whole.

Based on our professional judgement, we determined materiality for the financial statements as a whole as follows:

We use performance materiality to reduce to an appropriately low level the probability that the aggregate

of uncorrected and undetected misstatements exceeds overall materiality. Specifically, we use performance materiality in determining the scope of our audit and the nature and extent of our testing of account balances, classes of transactions and disclosures, for example in determining sample sizes. Our performance materiality was 75% of overall materiality, amounting to £255,000

for the financial statements.

In determining the performance materiality, we considered a number of factors – the history of misstatements, risk assessment and aggregation risk and the effectiveness of controls -

and concluded that an amount at the upper end of our normal range was appropriate.

We agreed with the Audit and Operational Risk Committee that we would report to

them misstatements identified during our audit above £34,000 as well as misstatements below that amount that, in our view, warranted reporting for qualitative reasons.

An overview of the scope of our audit

As part of designing our audit, we assessed the risk of material misstatement in the financial statements, whether due to fraud or error, and then designed and performed audit procedures responsive to those risks. In particular, we looked at where the Commissioners made subjective judgements such as making assumptions on significant accounting estimates.

We tailored the scope of our audit to

ensure that we performed sufficient

work to be able to give an opinion on

the financial statements as a whole. We used the outputs of a risk assessment,

our understanding of the Commission,  its environment, controls and critical  business processes.

Other information

The other information comprises the information included in the Annual Report, other than the financial statements and our auditor's report

thereon. The Commissioners are

responsible for the other information.

Our opinion on the financial statements does not cover the other information

and, except to the extent otherwise

explicitly stated in our report, we do

not express any form of assurance conclusion thereon.

In connection with our audit of the

financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent

with the financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated. If we identify such material inconsistencies or apparent material misstatements, we are required to

determine whether there is a material misstatement in the financial statements or a material misstatement of the other information. If, based on the work we

have performed, we conclude that there

is a material misstatement of this other information, we are required to report

that fact.

We have nothing to report in this regard. Responsibilities of the Commissioners

As explained in the'Responsibility for annual report and accounts' on p43, the Commissioners are responsible for:

• the preparation of the financial statements in accordance with the Financial Services Commission (Jersey) Law 1998 and United Kingdom Generally Accepted Accounting Practice;

• such internal control as the Commissioners determine is

necessary to enable the preparation

of financial statements that are free from material misstatement, whether

due to fraud or error.

In preparing the financial statements, the Commissioners are responsible for assessing the Commission's ability to continue as a going concern, disclosing, as applicable, matters related to

going concern and using the going concern basis of accounting unless the Commissioners either intend to liquidate the Commission or to cease operations, or have no realistic alternative but to do so.

Auditor's responsibilities for the audit of the financia statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor's report that includes our opinion.

Reasonable assurance is a high level

of assurance, but is not a guarantee

that an audit conducted in accordance

with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud

or error and are considered material

if, individually or in the aggregate,

they could reasonably be expected

to influence the economic decisions of users taken on the basis of these financial statements.

Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud.

The extent to which our procedures being satisfied that they give a true

are capable of detecting irregularities,  and fair view of the results of the  

including fraud is detailed below:  

Commission; and

We obtained an understanding of    Review of correspondence with the

the legal and regulatory framework  Jersey Data Protection Authority; applicable to the Commission through  

  Journal entry testing - including

enquiry of management, review of

analysis of the general ledger to

board minutes and review of legislation.

identify entries deemed to represent

We identified the following principal

a higher risk of fraud or error;

laws and regulations relevant to the

Commission: Assessment of the appropriateness

• Financial Services Commission  of accounting policies; and

(Jersey) Law 1998; and Assessment of the reasonableness United Kingdom Accounting of judgements made by management