JFSC updates to the 2025 supervisory risk data collection [SRDC] + FULL GUIDE

In preparation for the JFSC 2025/26 supervisory risk data collection, the JFSC  have published guidance outlining updates and changes that will affect the data the JFSC collects.  

Building on industry feedback and incorporating relevant policy developments, the JFSC  have:  

• Amended the submission period to 2 February - 30 April 2026 
• Enhanced data validation to reduce submission errors and improve feedback 
• Amended the sensitive activity lists under the Sound Business Policy 
• Maintained targeted data collection for AMLSP-supervised persons and prescribed NPOs 
• Removed DNFBP group structure data requests for 2025 

What’s changing 

• Submission timeline: the 2025 SRDC will be issued on 2 February 2026, with a submission deadline of 30 April 2026 to ease pressure around the UK tax year-end. 
• Validation improvements: email notifications will now reference specific questions, not just cell numbers, and new workbook prompts will clarify mandatory fields. 
• Sound Business Policy: sector workbooks will reflect the reduced list of sensitive activities, from 11 to 5, following policy updates. 
• Prescribed NPOs: annual data collection continues, with formats tailored to TCB-administered and independent NPOs. 
• DNFBPs: no further data requests on group structures until the current review concludes. 

Looking ahead 

The JFSC is also planning future changes to streamline and strengthen the JFSC  data collection: 

• Fund statistics: moving to annual reporting, starting 30 June 2026 
• Jersey private fund annual compliance return: considering integration into the SRDC workbook to simplify submissions 
• Wire transfers: purpose of payment data collection deferred until 2028, pending ISO 20022 rollout 
• Jersey Resolution Authority questions: no additional prudential questions for 2025 

MONEYVAL: exploring existing data sources to meet granular data needs without expanding SRDC requirements 

Read the JFSC's complete guidance on the 2025 SRDC for more details.

• https://www.jerseyfsc.org/industry/guidance-and-policy/updates-to-the JFSC -2025-supervisory-risk-data-collection/

or read here

1 Executive summary

1.1 Overview

1.1.1   This guidance note outlines key developments and plans for the JFSC  supervisory risk data collection (SRDC) process. The SRDC is a critical tool used to inform the JFSC  risk-based supervisory model and support national risk assessments (NRAs), including obligations under MONEYVAL and other international standards.

1.2  Purpose and strategic direction

1.2.1   The data collected through the SRDC allows us to identify key risk areas and will form the basis of a strategic review of the data the JFSC  collect for the JFSC  supervisory risk purposes. The JFSC aims to reduce regulatory burden while enhancing the quality and relevance of the data collected.

1.2.2   The SRDC provides valuable data for benchmarking sector risks, both through the JFSC  risk model and via industry publications of sector-based aggregated data.

• https://www.jerseyfsc.org/industry/risk/supervisory-risk-data-collection-exercise/sector-based-aggregated-data/

1.2.3   In addition, the data forms a valuable source of information for external agencies, on an aggregated basis, and contributes to Jersey’s broader financial stability and economic growth objectives.

1.3  Key updates for the 2025 SRDC

1.3.1   Submission timeline: the 2025 SRDC will be issued on 2 February 2026, with a 3-month submission window, ending 30 April 2026. This change accommodates industry feedback and aligns with UK tax year-end pressures.

1.3.2   Data validation enhancements: improvements to myJFSC upload validations and email notifications will clarify mandatory questions and reduce submission errors.

1.3.3   Sector-specific changes:

• Sound Business Policy: updates reflect a streamlined list of sensitive activities, reducing from 11 to 5.
• Prescribed NPOs: annual data collection will continue via Excel workbooks and online surveys, depending on administration type.
• DNFBP group structures: data under review, and no further collection is planned until conclusions are drawn.
• AMLSP supervised persons: continued data collection confirms most entities are low to standard risk, potentially informing future collection frequency

1.3.4   A comparison document will be published alongside the guidance issued with the 2025 SRDC next year. This will highlight changes and allow the industry to make comparisons against last year’s data request.

1.4  Planned future changes

1.4.1   Fund statistics: transitioning to annual reporting, with the first cycle due 30 June 2026.

1.4.2   Jersey private fund annual compliance return (JPF ACR): proposal to integrate compliance confirmations into the SRDC workbook to streamline submissions.

1.4.3   Wire transfers: Purpose of payment data delayed until 2028, pending ISO 20022 implementation across payment systems.

1.4.4   Jersey Resolution Authority (JRA): No additional prudential questions for 2025; consultation ongoing.

1.4.5   MONEYVAL recommendations: the JFSC  are exploring existing data sources to meet granular data needs without expanding 2025 SRDC requirements.

2  2025 supervisory risk data collection

2.1  Submission timeframe

2.1.1   Next year’s SRDC, requesting data for the 2025 reporting year, will be issued on Monday, 2 February 2026.

2.1.2   The submission timeframe will be 3 months from the date of the request, with a submission deadline of 30 April 2026.

2.1.3   This supports feedback received from the TCB sector that this year’s deadline of 11 April 2025 came at a time when the industry was under additional pressure to prepare client information for the UK tax year end of 5 April.

2.1.4   The JFSC  are implementing new software technology that allows us to integrate the data the JFSC  receive from industry much faster. This supports the JFSC's ability to push the submission deadline back to the end of April. While this update will not affect the JFSC  external technology interface, it will enable us to process and review data more efficiently. This means the JFSC can communicate data exceptions to industry more promptly and incorporate insights into the JFSC supervisory risk model more efficiently, allowing us to react quickly to changes in entity risk profiles.

2.2 Data validation and integrity checking

2.2.1   For the 2024 SRDC, the JFSC  introduced additional portal validation to check for completion of specific mandatory questions within the Section I – Global Footprint Excel Workbook. These are set out in section 2 of the JFSC  

• Guide to integrity-checking your Section I risk-based supervision data.
• https://www.jerseyfsc.org/industry/guidance-and-policy/guide-to-integrity-checking-your-section-i-risk-based-supervision-data-2023/

2.2.2   Failure to complete the questions triggered a ‘validation failed’ email to be sent to submitters. Feedback from industry during this process highlighted that the email notifications were unclear about the reasons for the submission failure. Specifically, they referred to cell numbers rather than question numbers.

2.2.3   The JFSC  have taken this feedback on board and will be amending the validation emails to include reference to the specific questions.

2.2.4   In addition, the JFSC  will be including new prompts within the workbook to make it more straightforward to determine which questions are mandatory.

2.3  Customers conducting Sound Business Policy activities

2.3.1   A new question was introduced to the 2024 SRDC asking for the number of customers that carry out any activity listed in Table 2 of the JFSC’s Sound Business Practice Policy.

2.3.2   Following the consultation on changes to the Sound Business Practice Policy, the Sound Business Practice Policy has been relabelled the Sound Business Policy, and Table 2 has been removed, with a shorter list of sensitive/reputational risks.

• The JFSC  will be updating the Sound Business Policy questions in each of the sector workbooks to reflect this change.
• The intent of the question will remain the same, with the list of activity numbers changing from 11 to 5.

2.4  Schedule 2 supervised persons using an AMLSP

2.4.1   The 2024 SRDC exercise was the first year the JFSC  collected supervisory risk data on supervised persons serviced via an AMLSP.

2.4.2   The JFSC  will continue to collect the same data in the same format for the 2025 SRDC.

2.5  DNFBP groups data collection

2.5.1   This year, the JFSC  collected data from DNFBPs to understand their group structures and how FATF Recommendation 23, regarding the applicability of AML/CFT controls in DNFBP financial groups, may impact the local DNFBP sector.

2.5.2   The output of this data is still under review. As a result, there is no intention to seek any further data requests on this subject until the review has been concluded.

2.5.3   There will be no DNFBP groups data request as part of the 2025 SRDC.

2.6  Non-profit organisations (NPO) data collection

2.6.1   The JFSC  first collected NPO data as part of the 2023 SRDC exercise to inform the JFSC  supervisory risk model and future national risk assessments.

2.6.2   The JFSC  will continue to collect NPO data (only in respect of prescribed NPOs) in the same format as the JFSC  did earlier this year for the 2024 SRDC:

2.6.2.1 Data to be collected from all TCB-administered prescribed NPOs via one Excel workbook. The names of the relevant NPOs will be listed in the workbook based on the data held in the JFSC  records. The questions will remain the same.

2.6.2.2 Data will be collected from all independent prescribed NPOs using an online survey tool, in the same way as the 2023 and 2024 SRDCs.

2.6.3   The JFSC  intend to collect supervisory risk data from TCB-administered Prescribed NPOs on an ongoing annual basis.

2.6.4   For clarity, this does not apply to independent registered NPOs (those that are not Prescribed NPOs).

3  Future changes

3.1  Fund statistics

3.1.1   Following the Government of Jersey’s announcement at the Mid-Year Financial Services Update: Strengthening Jersey’s Competitiveness, the JFSC  informed industry[1] that the JFSC  will be transitioning from a quarterly to an annual reporting cycle for fund statistics.

3.1.2   The new annual reporting cycle will be 30 June each year. The submission period will be one month after the reporting period, with a deadline of 31 July.

3.1.3   The process will follow the same format and reporting mechanism as in previous years, using the Q4 workbook template that includes the asset location.

3.1.4   The nature of these questions and the method for collecting them will form part of the JFSC's more exhaustive review of data.

3.2  Jersey Private Fund Annual Compliance Return (JPF ACR)

3.2.1   To streamline the frequency of data submissions, the JFSC  are considering adding the confirmations required in the JPF ACR, usually provided to us in August each year, within the SRDC JPF workbook. The JFSC  will consider this in 2026 to implement it in the 2026 SRDC. The JFSC  welcome industry feedback on this proposal, which can be sent to datacollections@jerseyfsc.org

3.3  Wire transfer: purpose of payment

3.3.1   As set out in the JFSC  2024 SRDC guidance note, there is no intention to add purpose of payment questions to the JFSC  wire transfer supervisory risk data collection workbook until at least the 2027 SRDC, collected in 2028, and only for higher risk jurisdictions.

3.3.2   The UK’s leading payment system providers continue to work on implementing the ISO 20022 standard, which will introduce standardised purpose of payment information.

3.3.2.1 CHAPS started mandating the use of ISO 20022 in May 2025 for payments between financial institutions and will continue to phase its approach to mandated use of purpose codes for all CHAPS payments by November 2027.

3.3.2.2 BACS is yet to announce a date for mandatory use, expected sometime between now and 2027.

3.3.3   Financial messaging network SWIFT remains on track to mandate ISO 20022 use from November 2025.

3.4  Jersey Resolution Authority (JRA) questions

3.4.1   In October 2023 [2], the JFSC  consulted on the potential to include additional prudential questions for banks and investment businesses to support the JRA’s risk understanding of banks’ critical functions. The JRA is still considering what data it needs and how best to collect this. Therefore, no additional prudential questions for JRA purposes will be collected in the 2025 SRDC.

3.5  MONEYVAL Mutual Evaluation Report

3.5.1   In the JFSC  2024 updates to the JFSC  supervisory risk data collection paper, [https://www.jerseyfsc.org/industry/guidance-and-policy/updates-to-our-supervisory-risk-data-collection/ ], the JFSC  referenced the MONEYVAL fifth Round Mutual Evaluation Report [3] which recommended obtaining more granular risk data about key areas, such as products or activity risks, transactional activities by customers (including links to particular products or services) and high-risk customer groups.

3.5.2   The JFSC  are reviewing how the JFSC  can obtain the data needed from existing data sources, and there is no intention to collect any additional product, service or activity data as part of the 2025 SRDC.

Sources

• [1] Fund statistics move to annual reporting cycle — Jersey Financial Services Commission https://www.jerseyfsc.org/news-and-events/fund-statistics-move-to-annual-reporting-cycle/
• [2] Additional supervisory risk data consultation paper No. 9 2023 — Jersey Financial Services Commission https://www.jerseyfsc.org/industry/consultations/additional-supervisory-risk-data-consultation-paper-no-9-2023/
• [3] FATF and MONEYVAL (gov.je) https://www.gov.je/Industry/Finance/FinancialCrime/pages/fatfandmoneyval.aspx

SOURCE

• https://www.jerseyfsc.org/news-and-events/read-the JFSC -updates-to-the-2025-supervisory-risk-data-collection/