GFSC Reduction in PIF Fees

Introduction

The Guernsey Financial Services Commission (the "GFSC") has implemented certain fee changes effective from 1 January 2026, including a considerable reduction in the application and annual fee applicable to private investment funds ("PIFs"). This development follows the substantial overhaul of the PIF regime introduced by the Private Investment Fund Rules and Guidance, 2025 (the "2025 PIF Rules").

The new PIF regime

As set out in Carey Olsen's briefing note: New PIF rules - the latest innovation in Guernsey funds regulation, a number of key reforms were made to the Guernsey PIF regime by the implementation of the 2025 PIF Rules, including:

• consolidation of the previous three PIF routes into two: the "Qualifying" PIF and the "Family" PIF;
• expansion of the eligible investor categories;
• removal of the limit on the number of investors and offering limits for Qualifying PIFs; and
• removal of the requirement for a prospectus, audit, or a Guernsey manager.

These changes greatly simplified the regime and positioned Guernsey PIFs as a more flexible and fast‑to‑market option for sophisticated private capital structures.

Reduction in GFSC fees and implications for fund sponsors

With effect from 1 January 2026, the GFSC reduced both the application and annual fees for PIFs, reflecting ongoing efforts to maintain Guernsey's competitive positioning in the private funds sector:

• the PIF registration application fee payable to the GFSC has reduced to £1,500 (from £4,795 for an open-ended PIF and £4,790 for a closed ended PIF in 2025); and
• the PIF annual fee payable to the GFSC has reduced to £1,000 (from £4,235 in 2025).

The GFSC have also reduced the application and annual fees for virtual asset service provider applications.

The combination of the 2025 PIF Rules and the 2026 fee reductions delivers a materially more cost-efficient framework for private capital managers by:

• lowering regulatory overheads for launching and maintaining PIFs;
• strengthening Guernsey's appeal as a jurisdiction for private investment structures seeking simplicity, speed to market and proportionate oversight; and
• enhancing alignment between regulatory expectations and supervisory needs, consistent with the GFSC's pro-growth stance.

Conclusion

The GFSC’s reduction of annual PIF fees builds on the reforms introduced under the 2025 PIF Rules and reinforces Guernsey’s status as a modern, flexible and competitively priced fund domicile. For managers looking to establish private capital vehicles in Guernsey, these changes translate into tangible advantages in the form of reduced frictional costs and simplified operational requirements.