Commission increases Fees for 2022

The Commission plans to increase licence fees paid by firms from 1 January 2022 by 7.6% with the agreement of the Policy & Resources Committee.

On 16 July 2021, the Commission published a consultation paper on its 2022 fees containing four main proposals:-

• an overall fee increase of 10.1% for all sectors;
• a restructuring of fees for the investment sector;
• changes arising from the update to most of the sectors’ laws following the Revision of Laws project; and
• creating a cap for pension scheme fees.

The consultation period ran for eight weeks until 10 September 2021. The Commission’s response to the feedback received as part of the consultation can be found here.

Given the significantly higher than expected level of authorisations so far this year which should have an ongoing positive impact on the Commission's finances as annual licence fees from newly authorised entities are paid from 2022 onwards, the Commission is able to proceed with a fee increase of 7.6% rather than the 10.1% upon which we consulted.

The Commission endeavours, to the extent reasonably practical, to align fees with the costs of regulation undertaken. The Commission will therefore undertake a restructuring of the fees within the investment sector so that the types of investment licensees that require greater supervisory attention pay a licence fee based on the size of the firm. Also, an upper cap will be introduced on the level of fees charged per member in a pension scheme to 7,500 members. This step has been taken in response to feedback that the previous fee structure discouraged larger pension schemes from considering Guernsey as a cost-effective jurisdiction.

Commenting on the fee increase, the Commission’s Chairman, Cees Schrauwers, said: “We appreciate that putting up fees is never going to be popular but hope that fee payers will appreciate that we have listened to feedback and, on the basis of sharing the proceeds of the growth which we are all seeing in the financial services sector, reduced our proposed fee increase for 2022. Considering our history of strong fee control we note that, even with this reduced fee increase, our overall fees will have increased by less than compound inflation over the last eight years.”

The Commission’s Director General, William Mason, added: “The additional income raised will allow us to slightly increase officer numbers - enabling us, inter alia, to increase on-the-ground supervision as we prepare for the Bailiwick's inspection against the Intended Outcomes of the Financial Action Task Force.  The fee increase will also allow us to invest to improve our technology to maintain good quality, proportionate regulation to international standards within the Bailiwick.  Finally, it will allow us to continue to reward our officers fairly in a buoyant financial services employment market.”