Feedback on changes to the alternative investment fund code to transpose the EU’s Alternative Investment Fund Managers Directive II

1    Executive summary

1.1    Overview

1.1.1    On 2 October 2025, we published a consultation paper on changes to our code of practice for alternative investment funds and alternative investment fund services business (AIF Code) to transpose the EU Alternative Investment Fund Manager Directive II (EU AIFMD II). We asked for relevant stakeholders’ views on the proposed changes and their impact.

1.1.2    Through applicable legislation and our current AIF Code, we operate a dual alternative investment fund manager (AIFM) regime which complies with the EU AIFMD and the UK AIFM Regulations. This ensures Jersey’s equivalence and its resulting market access in the EU and UK through the Private Placement Rules.

1.1.3    The EU AIFMD was updated in April 2024 to take account of EU AIFMD II, which must be implemented by April 2026. To maintain market access in the EU, Jersey must adapt its AIFM regime to reflect and align with the EU AIFMD regime changes.

1.1.4    The EU and UK AIFM regimes are diverging. The EU’s changes are already finalised while the UK’s new approach remains under development. Our proposal was to split the AIF Code to reflect:

  • EU AIFMD II requirements by 16 April 2026 (EU AIF Code)
  • the final agreed UK AIFM proposals (UK AIF Code) in due course

1.1.5    The purpose of this paper is to provide feedback on the response received to the consultation paper on the EU AIF Code.

1.2    Feedback received

1.2.1    We received one response to the consultation. Section 2 of this paper presents the comments received and our response.

1.2.2    We are grateful to the respondent for taking the time to consider and comment on the proposals. We are also grateful to the working group for their work prior to the consultation being issued.

1.3    Next steps

1.3.1    We will proceed in line with the consultation as there were no material comments on the proposals.

1.3.2    Any queries should be directed to policy@jerseyfsc.org.

Read the full feedback on changes to the alternative investment fund code to transpose the EU’s Alternative Investment Fund Managers Directive II.