By Matt Satchell, Client Relationship Director, Funds and Institutional
Enhancements to the Jersey Private Fund (JPF) regime have been announced last week by the Government of Jersey and the Jersey Financial Services Commission (JFSC). These changes, which take effect from 6 August 2025, seek to improve a JPF’s flexibility, accessibility and speed to market. Here, we summarise the key details that will be of interest to investors and fund managers.
What are the changes?
Pursuant to the new Collective Investment Funds (Jersey Private Funds) Order 2025 (the “JPF Order”) and revisions to the JPF Guide, the key changes include the following:
1. Removal of the 50 offer/investor limit for JPFs
JPFs will no longer be subject to the 50 offer/investor limit, meaning there will no longer be any cap on the number of offers made by a JPF or the number of investors in a JPF.
However, JPFs may only be offered to a “restricted group of investors,” which means:
- The offer of units in the JPF is addressed to an identifiable category of persons and communicated directly by the JPF or by its appointed agent
- Only persons in the restricted group may accept the offer
As well as being updated to reflect this change, the JPF Guide also provides additional guidance on how existing funds (JPFs and collective investment funds) might apply to convert or benefit from the new arrangements under the JPF Order.
2. Expanded categories of eligible investors
The definition of a “professional investor” eligible to invest in a JPF has been expanded to include:
- “Professional clients” as defined by the UK Financial Conduct Authority’s Conduct of Business Sourcebook
- “U.S. accredited investors” as defined by the U.S. Securities and Exchange Commission in rule 501 of Regulation D – Rules Governing the Limited Offer of Sale of Securities Without Registration Under the Securities Act of 1933
3. Reduced authorisation time
Subject to an application meeting all the necessary requirements, the JFSC’s processing time to approve the establishment of a JPF has been reduced from 48 hours to just 24 hours.
4. Permission to list
A JPF is no longer restricted from listing its units on a stock exchange provided consent from the JFSC is obtained in advance.
The JFSC has stated in the JPF Guide that it would not ordinarily expect the units of a JPF to be admitted to trading on a stock exchange but does recognise that some JPFs may seek a “technical listing” with no active trading, or where units have been “privately placed” with select investors (with no public offering).
Timeframe and next steps
The JPF Order and the updated JPF Guide come into effect on 6 August 2025 and will automatically apply to new JPFs. Existing JPFs may also benefit from unlimited offers/investors by filing a request for a new consent under the Control of Borrowing (Jersey) Order 1958 to be issued on or after 6 August 2025, which will disapply the restriction.
These amendments, which follow significant collaboration between the Government of Jersey, the JFSC and the industry, reinforce the JPF regime’s place as a leading fund product and a simple, efficient and flexible solution for private fund players globally.
For more information about the JPF regime and how we can assist with your fund administration, please contact our expert team today.
