Guernsey Financial Services Commission 2025 Fee Rates Feedback Paper

Guernsey Financial Services Commission • www.gfsc.gg 1 FEEDBACK PAPER ON CONSULTATION FOR FEE RATES FOR 2025 ISSUED 5 DECEMBER 2024

Guernsey Financial Services Commission • www.gfsc.gg 2 Contents

1. Summary ........................................................................................................................................... 3
2. Background ....................................................................................................................................... 3
3. Assessment of Consultation Feedback .............................................................................................. 4 3.1.Overall Increase in Fees................................................................................................................ 4 3.2.Increase in fees for Retail General Insurers (‘RGI’) ..................................................................... 6 3.3.Operating an investment exchange in the Bailiwick of Guernsey ................................................ 6 3.4.Rationalisation of fee regulations ................................................................................................. 7
4. Next Steps ......................................................................................................................................... 7
5. Appendix A –2025 Fee Rates ........................................................................................................... 8 A.1. Banking Sector ............................................................................................................................ 8 A.2. Insurance Sector .......................................................................................................................... 9 A.3. Fiduciary Sector ........................................................................................................................ 14 A.4. Investment Sector ...................................................................................................................... 15 A.5. Lending, Credit and Finance Sector .......................................................................................... 16 A.6. Prescribed Businesses ............................................................................................................... 18 A.7. Director Registration Regime .................................................................................................... 18 A.8. Other Fees and Penalties ........................................................................................................... 19

Guernsey Financial Services Commission • www.gfsc.gg 3

1. Summary 1.1.1. Taking into account the feedback received, the current rate of inflation and the challenges of staff recruitment and retention, the Commission plans to increase fees for most licensees next year by 5.3%.
2. Background 2.1.1. On 11 September 2024, the Guernsey Financial Services Commission (the “Commission”) issued a Consultation Paper on proposals for fee rates and administrative penalties, to apply from 1 January 20251 . 2.1.2. The proposals presented within the Consultation Paper focused on the following areas:  an overall proposed increase in fees of 5.3% for all fees,  an increase in the fees for Retail General Insurers to recognise the additional supervisory effort required to mitigate the risks, including reputational, they pose to the Bailiwick, and  the creation of a specific authorisation fee for an entity that is looking to apply to operate an Investment Exchange. The consultation period ran for four weeks until 4 October 2024. 2.1.3. We are also taking this opportunity to rationalise our fee regulations to ensure consistency, across each regulatory sector, across fee types and for common fees or processes such as a change in controller or the calculation of a pro-rata annual fee which is carried out when a firm is initially licensed. A draft version of these updated fee regulations was included with the consultation paper to allow for comments or questions. 2.1.4. During the consultation period, we received 9 written responses and further verbal feedback, this included comments from every sector. This is on a par with the number of responses received to the prior year’s consultation (7 responses). Thank you to everyone who took the time and effort to respond to this fee consultation. 2.1.5. Section 3 of this Feedback Paper summarises the feedback received and, where applicable, explains how we have responded to that feedback, including any changes we have made to the proposals originally put forward. Where respondents have stated a section is not applicable, or have provided no comment, we have excluded them from the number of respondents in section 3. 1 The original consultation, which closed on 4 October 2024, can be found at: 2025 Fee Consultation - Guernsey Financial Services Commission - Citizen Space (gfsc.gg)

Guernsey Financial Services Commission • www.gfsc.gg 4 3. Assessment of Consultation Feedback 3.1. Overall Increase in Fees What was the general message in the feedback received? 3.1.1. There were five written responses to the question “Do you have any comments on the overall proposed fee increase?” 3.1.2. Two of the responses received understood the rationale for the increase and provided no specific feedback. One respondent stated they understood that the increase was in line with inflation and therefore accepted it was necessary. 3.1.3. Two respondents made note of cost pressures on the industry from regulation and compliance and the additional ‘macro’ pressures currently facing industry from inflation and transport issues. Though limited in numbers, respondents were from every sector, including industry bodies and individual licensees. What specific feedback did we receive? 3.1.4. Cost pressures on Industry: Two respondents highlighted that industry was also experiencing the same cost pressures as the Commission. They wished to emphasise that the Commission increasing its fees will drive up costs in the jurisdiction, and alongside increased fiscal and regulatory pressure, will have a negative impact on the Bailiwick’s competitiveness. In particular, the respondents highlighted the view that the increased cost of fees would negatively impact the Fiduciary sector, especially as over the last year the sector has remained flat with little growth. The respondents have expressed this would lead to increased losses in clients and business in Guernsey. A respondent suggested that a below inflationary increase could be introduced initially and once the Moneyval report was released further increases could take place. The Commission acknowledges that there have been challenges to all industries and sectors from higher inflation in recent years and that we continue to face competition to bring new business to the island and to retain our existing business. This is part of the challenge of being a jurisdiction of choice within the international finance sector. We continue to believe that Guernsey is well-placed to prevail and demonstrate globally that we are a jurisdiction where people choose to do business, and that this is supported by having an effective and well-respected international regulator. To do this effectively, we need to retain, and recruit, appropriately skilled and trained staff and ensure that we are able to demonstrate how our regulations and supervisory effort meets the relevant international standards. With competition, both on-island and off-island for appropriately qualified staff we are unable to do this without a modest increase in staff remuneration. A fee increase of 5.3% will assist us to retain staff whilst absorbing some ongoing increases in other costs. By keeping this increase to around the level of current Bailiwick inflation we are attempting to maintain regulatory fees in line with the other, more material, cost increases experienced by industry whilst keeping an open mind as to what the recommendations from the 2024 Moneyval Inspection will require.

Guernsey Financial Services Commission • www.gfsc.gg 5 3.1.5. New offices and meeting rooms There was a specific comment raised about the fact that the Commission was increasing its office space while a variety of firms in industry were being challenged to reduce their floorplate in order to reduce costs. We understand that since the pandemic there has been a trend to allowing an increasing amount of remote working to retain staff and reduce costs. Recently, in several industries this trend has been reversing as firms recognise the benefits of in-person working. We continue to believe that we are more productive as a regulator if our regulatory teams can work together, in person, transferring knowledge and allowing for more efficient training. This means overall we are a more effective regulator for the Bailiwick. Our new office space should allow us to deliver further in-house training sessions to industry, increasing their knowledge of the Bailiwick’s regulatory requirements and thereby hopefully avoiding unnecessary firm level gold-plating of our rules and regulations. Estate agent fees One respondent suggested that a fairer system of fees for estate agents could be introduced. They proposed basing the bandings of fees on the number of regulated sale transactions rather than number of employees. Estate agents are registered under the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999, which covers a range of sectors and business models, and the current fee schedule is based on a common approach for all these business types. We recognise that for certain sectors or individual businesses within a sector a fee schedule based on transactions may be better suited, however we are not convinced that it would be more appropriate for all business and sectors which fall under this law or that it would serve the underlying purpose of providing us with a reliable income stream to support regulation of the sector. As it was a single comment from only one business covered by this law at this time, we are not proposing to make any changes to this fee structure. What is the Commission going to do next? 3.1.6. Having considered the feedback provided and our current financial position and the impact of inflation alongside the need to retain, recruit and train new staff, the Commission intends to proceed with an overall fee increase of 5.3%. The increased fees will come into effect from 1 January 2025.

Guernsey Financial Services Commission • www.gfsc.gg 6 3.2. Increase in fees for Retail General Insurers (‘RGI’) What was the general message in the feedback received? 3.2.1. We received three responses to the question “Do you have any comments on the increase in fees for RGIs?” 3.2.2. Two of the responses received were diametrically opposed, both responses understood the increased regulatory requirements created by RGIs and understood the need for an increase in their fees. However, one expressed the opinion that smaller scale businesses in the RGI sector do not have the risk mitigations nor controls that larger businesses gain from size and scale, so therefore there should not have a lower fee. The second response believed that the increase in fees placed too much burden on the smaller entities and that the bandings should be adjusted to reflect this. The Commission recognises that there is the option to charge the same fee to all RGIs. However, the Commission tries to ensure that the fees introduced are fair and proportionate to the size of the business being undertaken, which is why we utilise fee banding across several sectors. Whilst we understand that smaller firms may not always have the same opportunities to mitigate risks as some larger firms, we feel that a lower banding based on gross written premium reflects the lower levels of business that these firms carry out. In addition, we acknowledge that this is a material increase in fees for these smaller firms and that this may impact their overall pricing to customers. This would, however, only reflect the true risks and costs of operating these businesses in a well-regulated manner, as well as our substantial costs we have incurred when regulating such firms in recent years. 3.2.3. One respondent suggested that the increased fee income from the new RGI fees should be used to offset the increase in fees for the other sectors in the jurisdiction. These firms’ future fees will reflect the additional work that is carried out by the Commission by an insurance supervision team which the 2019 IAIS inspection observed to be thinly staffed relative to other jurisdictions’ regulators given the number of insurance entities in the Bailiwick2 . What is the Commission going to do next? 3.2.4. The Commission intends to proceed with the proposals outlined within the Consultation Paper. The fee amendments will come into effect from 1 January 2025. 3.3. Operating an investment exchange in the Bailiwick of Guernsey What was the general message in the feedback received? 3.3.1. The Commission received one response to the question “Do you have any comments on the proposed application fee to operate an investment exchange in 2 Please see p.42 - https://www.gfsc.gg/sites/default/files/uploads/Assessment_Report_MAP_Guernsey_2018- 2019.pdf

Guernsey Financial Services Commission • www.gfsc.gg 7 the Bailiwick?” The single response received supported the introduction of the proposed application fee. What is the Commission going to do next? 3.3.2. The Commission intends to proceed with the increase for an application fee to operate an investment exchange in the Bailiwick of Guernsey. This will come into effect from 1 January 2025. 3.4. Rationalisation of fee regulations What was the general message in the feedback received? 3.4.1. The Commission received two responses to the question “Do you have any comments on the proposed rationalisation of the fee regulations?” The two respondents were in support of the rationalisation. 3.4.2. One respondent asked for further clarification on the rationalisation of fee regulations, particularly around the prescribed businesses fees and regulations. Prescribed businesses were not originally included in the rationalisation as they fall under a different section of regulations and laws - the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999. During the consultation period, the Commission has received confirmation that we can also include the relevant fees from the Proceeds of Crime law. These will be included in the amended fee regulations for January 2025. 3.4.3. Since the issuance of the Consultation Paper, the Commission has been working with the Law Officers of the Crown to ensure that the fee regulations are drafted with an appropriate structure and layout in line with other regulations. As part of this work there has been a material restructure of the draft fee regulations whilst maintaining our original goals to bring consistency, clarity and to make the fee regulations easier to follow. What is the Commission going to do next? 3.4.4. The Commission intends to proceed with the proposed changes, as outlined in the Consultation Paper. The amended regulations will also be expanded to include relevant fees within the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999. The restructured and rationalised regulations will come into effect from 1 January 2025. 4. Next Steps 4.1.1. Following due consideration of the feedback provided to the Consultation Paper we propose to implement the fee schedule presented in Appendix A to this paper. For clarity this includes the 5.3% overall increase as proposed in the Consultation Paper. 4.1.2. In due course, amended regulations and fee rates will be published on the Commission’s website. All updated fees will come into force on 1 January 2025.

Guernsey Financial Services Commission • www.gfsc.gg 8 5. Appendix A –2025 Fee Rates A.1. Banking Sector Application Fees Current Fee for 2024 Proposed Fee for 2025 Bank Licence Application £46,550 £49,015

Annual Fees Current Fee for 2024 Proposed Fee for 2025 Total Assets Band: Below £500,000,000 £46,550 £49,015 £500,000,000 to £999,999,999 Total Assets x 0.00007062 Minimum of £46,550 Total Assets x 0.00007436 Minimum of £49,015 £1,000,000,000 or Greater £70,620 £74,365 Plus, Additional Fees for: Guernsey subsidiary banks 25% of relevant annual fee 25% of relevant annual fee Retail operations (both subsidiaries and branches) 50% of relevant annual fee 50% of relevant annual fee Additional trading names, where a bank is effectively operating multiple separate businesses under one licence 50% of relevant annual fee 50% of relevant annual fee Each branch outside of the Bailiwick £17,655 £18,590

Guernsey Financial Services Commission • www.gfsc.gg 9 A.2. Insurance Sector Part 1A – Insurers (including Mutual, Provident or Friendly Societies, PCCs, ICCs and ICs) Current Fee for 2024 Proposed Fee for 2025 International Insurer including PCC or ICC Core: Life Insurer / Reinsurer (Category 1 / 2) £7,060 £7,435 Commercial Insurer / Reinsurer (Category 3 / 4) £10,585 £11,145 Retail General Insurer (Company) - £12,500 Captive Insurer / Reinsurer …..(Category 5) £7,175 £7,555 Category 6 £7,060 £7,435 Cell of a PCC or ICC: Life Insurer / Reinsurer (Category 1 / 2) £2,305 £2,425 Commercial Insurer / Reinsurer (Category 3 / 4) £3,460 £3,645 Retail General Insurer (Cell) - £9,500 Captive Insurer / Reinsurer (Category 5) £2,305 £2,425 Non-Special Purpose Insurer (Category 6) £2,305 £2,425 Special Purpose Insurer (Category 6) £100 £105 Application for Consent to a Scheme of Transfer of Long Term Business £6,620 £6,970 Variation of Activities in respect of which Insurer is licensed £1,430 £1,505 Domestic Insurer £3,975 £4,185 Mutual, Friendly, or Provident Society £3,975 £4,185 Part 1B - Insurance Managers Current Fee for 2024 Proposed Fee for 2025 Insurance Managers £6,570 £6,920 Insurance Manager acting only for business underwritten by members of the Society of Lloyd’s £3,615 £3,805

Guernsey Financial Services Commission • www.gfsc.gg 10 A.2. Insurance Sector (continued) Application Fees (continued) Current Fee for 2024 Proposed Fee for 2025 Part 1C - Application Fees for Insurance Intermediaries Insurance Intermediary (Base Fee) £6,615 £6,965 Adding additional categories to existing licence General – Personal Lines £235 £245 General – Commercial £460 £485 Long Term – Life £460 £485 Long Term – Regular Premium £700 £735 Long Term – Single Premium (Insurance Element) £2,270 £2,390

Guernsey Financial Services Commission • www.gfsc.gg 11 A.2. Insurance Sector (continued) Annual Fees Current Fee for 2024 Proposed Fee for 2025 Part 2A – Insurers (including Mutual, Provident or Friendly Societies, PCCs, ICCs and ICs) Active Life Insurer (ICC, PCC and Non￾Cellular) (Category 1 / 2) Net Policyholder Liabilities Band:

Below £1 £7,060 £7,435 £1 to £999,999 £9,165 £9,650 £1,000,000 to £9,999,999 £11,250 £11,845 £10,000,000 to £99,999,999 £17,500 £18,430 £100,000,000 to £499,999,999 £27,920 £29,400 £500,000,000 to £1,999,999,999 £54,065 £56,930 £2,000,000,000 or Greater £105,995 £111,615 Life Insurer Closed to New Business (ICC, PCC and Non-Cellular) (Category 1 / 2) Net Policyholder Liabilities Band:

Below £1 £7,060 £7,435 £1 to £9,999,999 £9,150 £9,635 £10,000,000 to £499,999,999 £12,595 £13,265 £500,000,000 or Greater £17,500 £18,430 Non-Life International Insurer: Commercial Insurer / Reinsurer (Category 3 / 4)1 £10,585 £11,145 Retail General Insurers (Company) Gross Written Premium Band

£1 to £999,999 - £12,500 £1,000,000 to £10,000,000 - £15,000 more than £10,000,000 - £17,500 Captive Insurer / Reinsurer (Category 5) £7,175 £7,555 Category 6 £7,060 £7,435 Domestic Insurer Gross Written Premium Band: Below £12,000 £590 £620 £12,000 to £4,999,999 £3,975 £4,185 £5,000,000 or Greater £20,275 £21,350

1 For the purposes of Regulation 5, Category 3/4 insurers which have not written any business must pay a fee of £7,435 whilst insurers which have written business must pay a fee of £11,145.

Guernsey Financial Services Commission • www.gfsc.gg 12 A.2. Insurance Sector (continued) Part 2A – Insurers (including Mutual, Provident or Friendly Societies, PCCs, ICCs and ICs) (Annual Fees, Continued) Current Fee for 2024 Proposed Fee for 2025 Mutual, Friendly, or Provident Society: Non-Commercial £590 £620 Commercial £3,975 £4,185 Cell of a PCC or ICC: Life Insurer / Reinsurer (Category 1 / 2) £2,305 £2,425 Commercial Insurer / Reinsurer (Category 3 / 4) £3,460 £3,645 Retail General Insurers (Cell) Gross Written Premium Band

£1 to £999,999 - £9,500 £1,000,000 to £10,000,000 - £12,000 More than £10,000,000 - £15,000 Captive Insurer / Reinsurer (Category 5) £2,305 £2,425 Non-Special Purpose Insurer (Category 6) £2,305 £2,425 Special Purpose Insurer (Category 6) £100 £105 Transformer Cell £100 £105 Dormant Cell £180 £195 Life policy cells £140 £145 Part 2B - Insurance Managers Current Fee for 2024 Proposed Fee for 2025 Insurance Managers (based on companies under management) Pure £6,235 £6,565 Commercial £10,440 £10,995 Society of Lloyd’s £3,615 £3,805

Guernsey Financial Services Commission • www.gfsc.gg 13 A.2. Insurance Sector (continued) Part 2C – Insurance Intermediaries Current Fee for 2024 Proposed Fee for 2025 Intermediary – Base fee £3,210 £3,380 Plus intermediary category of Intermediary licence General – Personal Lines £235 £245 General – Commercial £460 £485 Long Term – Life £460 £485 Long Term – Regular Premium £700 £735 Long Term – Single Premium (insurance element) £2,270 £2,390

Long Term – Single Premium (POI element) £1,405 £1,480 Plus Intermediary turnover from Licensed Bailiwick Activity £0 - £249,999 £2,270 £2,390 £250,000 - £499,999 £3,435 £3,615 £500,000 - £749,999 £4,540 £4,780 £750,000 - £999,999 £5,685 £5,985 £1,000,000 - £1,999,999 £6,825 £7,185 £2,000,000 - £2,999,999 £7,975 £8,340 £3,000,000+ £9,105 £9,590

Guernsey Financial Services Commission • www.gfsc.gg 14 A.3. Fiduciary Sector Application Fees Current Fee for 2024 Proposed Fee for 2025 Personal Fiduciary Licence £1,285 £1,355 Primary Fiduciary Licence £2,930 £3,085 Secondary Fiduciary Licence £710 £750 Discretionary Exemption (Individual) £605 £635 Discretionary Exemption (Company or Partnership) £1,350 £1,420 Consent to Use a Name £2,290 £2,410

Annual Fees Current Fee for 2024 Proposed Fee for 2025 Personal Fiduciary Licensee £1,335 £1,405 Primary Fiduciary Licensee – Turnover Band: Below £250,000 £6,500 £6,845 £250,000 to £499,999 £12,990 £13,680 £500,000 to £999,999 £19,490 £20,525 £1,000,000 to £1,999,999 £25,980 £27,355 £2,000,000 to £3,999,999 £32,480 £34,200 £4,000,000 to £7,999,999 £38,970 £41,035 £8,000,000 to £15,999,999 £51,960 £54,715 £16,000,000 or Greater £64,955 £68,400 Pension Regulation Fee: Fixed Fee £590 £620 Fee per Scheme Member £1 Subject to a £7,500 cap per scheme £1 Subject to a £7,500 cap per scheme

Guernsey Financial Services Commission • www.gfsc.gg 15 A.4. Investment Sector Application Fees Current Fee for 2024 Proposed Fee for 2025 Open-Ended Collective Investment Schemes: Scheme £4,020 £4,235 Plus: Additional Fast Track Application Fee £530 £560 New Class of Existing Umbrella/Multi￾Class Scheme £910 £960 Plus: Additional Fee for Additional Elements to Fast Track Funds £530 £560 Closed-Ended Collective Investment Schemes: Authorised Scheme £4,020 £4,235 Plus: Fast Track Additional Application Fee £530 £560 Registered Scheme £4,550 £4,790 “De-QIFing” £3,245 £3,415 PIF Conversion £3,245 £3,415 Registration of Prospectus £530 £560 Form EX Notification £1,395 £1,470 Other Licensees £2,925 £3,080 Investment Exchange Operator - £30,000 Extension of Licence £1,430 £1,505

Annual Fees Current Fee for 2024 Proposed Fee for 2025 Open-Ended Collective Investment Schemes: Schemes £4,020 £4,235 Plus: per Class £280 £295 Designated Territories Scheme (EX) £700 £735 Closed-Ended Collective Investment Schemes £4,020 £4,235 Designated Persons; Brokers; and Licensees with an Authorised Financial Advisor – Turnover Band: Below £1,500,000 £4,190 £4,410 £1,500,000 to £2,999,999 £6,600 £6,950 £3,000,000 to £5,999,999 £8,895 £9,365 £6,000,000 to £11,999,999 £11,480 £12,090 £12,000,000 or Greater £14,350 £15,110 Managers of Overseas Collective Investment Schemes £4,190 £4,410 Principal Managers of Open-Ended Schemes £2,095 £2,205 Managers of Closed-Ended Schemes £2,095 £2,205 Investment Exchanges £142,160 £149,695 Insurance Intermediary with PoI Licence £1,405 £1,480 Other Licensees £4,190 £4,410

Guernsey Financial Services Commission • www.gfsc.gg 16 A.5. Lending, Credit and Finance Sector Application Fees Current Fee for 2024 Proposed Fee for 2025 Licence Application for: Credit Providers (Home Finance) £6,000 £6,320 Credit Providers (Consumer Credit) £4,500 £4,740 Services Ancillary to Credit (Home Finance) £3,000 £3,160 Services Ancillary to Credit (Consumer Credit with less than £3,000,000 loans brokered in preceding calendar year) £1,000 £1,055 Services Ancillary to Credit (Consumer Credit with more than £3,000,000 loans brokered in preceding calendar year) £2,000 £2,105 Financial Firm Businesses £4,500 £4,740 Platforms £6,000 £6,320 Virtual Asset Service Providers (Exchanges and Stablecoin Issuers) £95,000 £100,035 Virtual Asset Service Providers (Non￾Exchanges) £25,000 £26,325 AMC held virtual asset AMC Issuer £3,750 £3,950 Each AMC Cell £500 £525 Exemption for a Company or Partnership £1,270 £1,335 Exemption for an Individual £570 £600 Extension of a Licence £1,345 £1,415

Guernsey Financial Services Commission • www.gfsc.gg 17 A.5. Lending, Credit and Finance Sector (continued) Annual Fees Current Fee for 2024 Proposed Fee for 2025 Credit Providers (Home Finance): Non-Bank with a Below £100,000,000 Lending Book £6,000 £6,320 Non-Bank with a Greater than £100,000,000 Lending Book £9,000 £9,475 Bank Credit Provider (Home Finance) 50% of Relevant Fee Above 50% of Relevant Fee Above Credit Providers (Consumer Credit): Non-Bank with a Below £10,000,000 Lending Book £4,500 £4,740 Non-Bank with a Greater than £10,000,000 Lending Book £7,500 £7,895 Bank Credit Provider (Consumer Credit) 50% of Relevant Fee Above 50% of Relevant Fee Above Services Ancillary to Credit: Home Finance £3,000 £3,160 Consumer Credit with less than £3,000,000 loans brokered in preceding year £1,000 £1,055 Consumer Credit with more than £3,000,000 loans brokered in preceding year £2,000 £2,105 Financial Firm Businesses £1,500 £1,580 Platforms £6,000 £6,320 Virtual Asset Service Providers: Exchanges and Stablecoin Issuers £95,000 £100,035 Non-Exchanges £25,000 £26,325 AMC held virtual asset AMC issuer £3,750 £3,950 Each AMC cell £500 £525

Guernsey Financial Services Commission • www.gfsc.gg 18 A.6. Prescribed Businesses Registration / Annual Fees Current Fee for 2024 Proposed Fee for 2025 Number of Full-Time / Full-Time Equivalent Staff: 1 to 5 £830 £875 6 £945 £995 7 £1,080 £1,135 8 £1,205 £1,270 9 £1,335 £1,405 10 £1,460 £1,535 11 £1,585 £1,670 12 £1,710 £1,800 13 £1,840 £1,940 14 £1,965 £2,070 15 £2,090 £2,200 16 £2,215 £2,330 17 £2,345 £2,470 18 £2,470 £2,600 19 £2,595 £2,735 20 £2,720 £2,865 21 £2,850 £3,000 22 £2,975 £3,135 23 £3,105 £3,270 24 £3,225 £3,395 25 or Greater £3,350 £3,530 A.7. Director Registration Regime Registration / Annual Fees Current Fee for 2024 Proposed Fee for 2025 Director Registration Regime £75 £80

Guernsey Financial Services Commission • www.gfsc.gg 19 A.8. Other Fees and Penalties Other Fees Not Specific to a Sector Administrative Financial Penalties Late Filing Penalty Current Fee for 2024 Proposed Fee for 2025 First Month £125 £125 Second Month £250 £250 Third Month £375 £375 Each Subsequent Month £375 £375 Inaccurate Filing Penalty Error Identified by Firm Error Identified by the Commission On identification of the error and return of the submission for correction by the firm £125 £500 Each subsequent month taken to correct the error £125 £500 Application Fees Current Fee for 2024 Proposed Fee for 2025 Consent Request to Incorporate a PCC or ICC not Connected to a Licence Application under a Supervisory Law £530 £560 Change of Controller £2,520 £2,655 Amalgamation and Migration £2,800 £2,950 Consent for removal of supervised Limited Liability Partnerships from the Register £2,605 £2,745 Consent for removal of a supervised limited partnership from the Register of Limited Partnerships £2,800 £2,950 Application under section 438 or 469 of the Companies Law (insurance) £1,335 £1,405

Guernsey Financial Services Commission • www.gfsc.gg 1 CONSULTATION PAPER ON PROPOSALS FOR FEE RATES FOR 2025 ISSUED 10th SEPTEMBER 2024

Guernsey Financial Services Commission • www.gfsc.gg 2 Contents

1. Executive Summary .......................................................................................................................... 3 1.1.Consultation Overview ................................................................................................................. 3 1.2.Affected and Interested Parties ..................................................................................................... 3 1.3.Providing Feedback ...................................................................................................................... 3
2. The Commission’s Mission Statement ............................................................................................. 5
3. Purpose and Scope of this Consultation Paper .................................................................................. 5 3.1.Purpose ......................................................................................................................................... 5 3.2.Approach to Setting Fees .............................................................................................................. 5 3.3.Parties with whom we are consulting ........................................................................................... 6
4. Proposals ........................................................................................................................................... 7 4.1.Overall Increase in Fees................................................................................................................ 7 4.2.Increase in fees for Retail General Insurers (‘RGI’) ..................................................................... 8 4.3.Applying to operate an investment exchange in the Bailiwick of Guernsey .............................. 10 4.4.Rationalisation of the fee regulations ......................................................................................... 11 4.5.Next Steps ................................................................................................................................... 12 Appendix A – Questions for Public Comment ...................................................................................... 13 Appendix B – Proposed 2025 Fee Rates ............................................................................................... 14 B.1. Banking Sector .......................................................................................................................... 14 B.2. Insurance Sector ........................................................................................................................ 15 B.3. Fiduciary Sector......................................................................................................................... 20 B.4. Investment Sector ...................................................................................................................... 21 B.6. Lending, Credit and Finance Sector .......................................................................................... 22 B.6. Lending, Credit and Finance Sector (continued) ....................................................................... 23 B.7. Prescribed Businesses ................................................................................................................ 24 B.7. Director Registration Regime .................................................................................................... 24 B.7. Other Fees and Penalties ........................................................................................................... 25

Guernsey Financial Services Commission • www.gfsc.gg 3

1. Executive Summary 1.1. Consultation Overview 1.1.1. The Guernsey Financial Services Commission (the “Commission”) is issuing this Consultation Paper on proposals for the fee rates and administrative penalties to apply from 1 January 2025, including:  an overall proposed increase in fees of 5.3% (in line with current Guernsey inflation) for all fees,  an increase in the fees for Retail General Insurers to recognise the additional supervisory effort required to mitigate the risks, including reputational, they pose to the Bailiwick.  the creation of a specific authorisation fee for an entity that is looking to apply to operate an Investment Exchange. 1.1.2. The purpose of these changes is to ensure that the Commission continues to have sufficient financial resources to meet its statutory objectives, including by having the skilled staff needed to supervise firms in a proportionate manner and being able to make continued investment in our IT infrastructure. 1.1.3. These fees are proposed on the basis that the Commission aims, through 2025, to utilise reserves to cover some portion of the additional staff required to meet our ongoing supervisory requirements and to develop its IT infrastructure and online portals. 1.1.4. We are also taking this opportunity to rationalise our fee regulations to ensure consistency, across each regulatory sector, across fee types and for common fees or processes such as a change in controller or the calculation of a pro-rata annual fee which is carried out when a firm is initially licensed. 1.1.5. The goal for this Consultation Paper is to elicit feedback on the proposed 2025 fee rates. 1.2. Affected and Interested Parties 1.2.1. These proposals would directly affect all existing licensees, registered entities, and authorised entities, as well as any applicants for licensing or registration. This Consultation Paper has also been shared with governmental bodies and industry bodies in the Bailiwick. A full list of parties with whom this Consultation Paper has been shared is included in section 3.3. 1.3. Providing Feedback 1.3.1. Responses to this Consultation Paper are requested by 4th October 2024. 1.3.2. We welcome and strongly encourage respondents to provide feedback or comment. Responses are most useful when they:  directly address a specific issue or question,  provide a rationale and support for the opinions expressed, and  suggest alternative solutions in the event of disagreement.

Guernsey Financial Services Commission • www.gfsc.gg 4 1.3.3. Feedback may be provided online through the Consultation Hub section of the Commission’s website, https://consultationhub.gfsc.gg/. We also welcome meetings with industry bodies, or firms, when they have specific feedback that they would like to give. 1.3.4. Following appropriate consideration of any feedback received the Commission will provide a summary of feedback received, along with the final fees that will come into force from 1 January 2025, within a feedback paper on our website.

Guernsey Financial Services Commission • www.gfsc.gg 5 2. The Commission’s Mission Statement 2.1.1. The Commission seeks to regulate and supervise financial services in the Bailiwick of Guernsey with integrity, proportionality, and professional excellence, and in doing so help to uphold the international reputation of the Bailiwick of Guernsey as a finance centre. 3. Purpose and Scope of this Consultation Paper 3.1. Purpose 3.1.1. This Consultation Paper seeks to detail the Commission’s proposals for fee rates for 2025, including changes to existing fees where appropriate. 3.1.2. This Consultation Paper is on proposed fees and administrative penalties to be issued under:  The Financial Services Business (Enforcement Powers) (Bailiwick of Guernsey) Law, 2020,  The Companies (Guernsey) Law, 2008 (“the Companies Law”),  The Limited Partnerships (Guernsey) Law, 1995,  The Limited Liability Partnerships (Guernsey) Law, 2013,  The Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999, and  the following laws, collectively referred to as “the Supervisory Laws”:

• The Banking Supervision (Bailiwick of Guernsey) Law, 2020,
• The Insurance Business (Bailiwick of Guernsey) Law, 2002,
• The Insurance Managers and Insurance Intermediaries (Bailiwick of Guernsey) Law, 2002,
• The Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020,
• The Protection of Investors (Bailiwick of Guernsey) Law, 2020, and
• The Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022. 3.2. Approach to Setting Fees 3.2.1. The Commission aims to set fees that are fair, proportionate, and broadly aligned with the costs of regulation, as far as is reasonably practicable in each case. 3.2.2. For supervised firms, this is reflected through our use of bandings for charging fees. For most sectors this means that larger firms pay a higher fee, which reflects the additional resources the Commission dedicates to supervising such firms. 3.2.3. For applications, individuals and firms that make a request requiring due consideration by the Commission, such as a new licence application or change of controller, pay for it.

Guernsey Financial Services Commission • www.gfsc.gg 6 3.3. Parties with whom we are consulting 3.3.1. This Consultation Paper will affect all licensees, collective investment schemes, registered businesses, registered individuals, and applicants for licensing, registration, or authorisation, pursuant to the Supervisory Laws. 3.3.2. As required by section 13(b) of the Financial Services Commission (Bailiwick of Guernsey) Law, 1987, and the relevant provisions of the Supervisory Laws, this Consultation Paper has been shared with the following bodies:  States of Guernsey, Policy & Resources Committee,  States of Guernsey, Committee for Economic Development,  States of Alderney, Policy & Finance Committee, and  Chief Pleas of Sark, Policy & Finance Committee. 3.3.3. This Consultation Paper has also been shared with the:  Guernsey International Business Association,  Association of Guernsey Banks,  Guernsey Investment and Funds Association,  Guernsey International Insurance Association,  Guernsey Association of Trustees,  Guernsey Association of Pension Providers,  Guernsey Branch of the Institute of Directors,  NED Forum,  Commercial Bar Association,  Guernsey Bar Council,  Guernsey Association of Compliance Officers, and  Guernsey Society for Chartered and Certified Accountants.

Guernsey Financial Services Commission • www.gfsc.gg 7 4. Proposals 4.1. Overall Increase in Fees 4.1.1. The Commission is seeking an overall increase in its fees of 5.3% for 2025. This is in line with the current rate of inflation in the Bailiwick, as at 30 June 2024, and reflects the ongoing increase in costs which the Commission, alongside the rest of industry, is experiencing. It also, however, reflects a material reinvestment of the Commission reserves into the ongoing update of our IT infrastructure and development of new online portals. 4.1.2. This fee increase is based on the Commission forecast of its ongoing costs and the need to continually invest in our staff to ensure we meet international expectations. As noted within our 2023 and 2024 Fee Consultation Papers1 , our internal financial modelling predicts that the Commission would be capable of sustaining its operations with fee increases benchmarked to inflation and this has not changed for 2025. This modelling also reflects the utilisation of a portion of our reserves to add an additional location to the Commission offices, to provide extra meeting space and a bigger training room to enable more industry outreach events. 4.1.3. Over the last two years we have seen a gradual decline in inflation, both in Guernsey and the UK, from a peak of 8.5% in December 2022 to the most recent inflationary figure for Guernsey of 5.3%. . We may continue to see a downward trend for Guernsey inflation, following the UK, however it is worth noting that from now on Guernsey inflation may not drop as quickly due to the reduced impact of energy inflation alongside a greater focus on services within the Bailiwick, the latter being an area where current inflation levels remain high. 4.1.4. In our prior year fee consultations, we have commented on the higher regulatory inflation that we face not just from ensuring we have appropriately trained staff in the face of industry completion but also in responding to international developments in regulation. We continue to face these pressures and proposing an inflationary fee increase for 2025 enables us to continue to retain and recruit skilled staff as well as to provide relevant training to any less experienced individuals who join the Commission. . We do expect however, that once the Bailiwick’s final Moneyval report is published at the start of 2025 we will need to assess any relevant recommendations regarding our supervisory processes and approach and address these during 2025, which may have an impact on our 2026 fee consultation. 4.1.5. We would hope that this inflationary based fee increase for 2025 will be understood by Guernsey industry and would note that we will need to consider future events, such as the Moneyval report, when we consider fee increases for 2026 onwards. Question 1: Do you have any comments on the overall proposed fee increase? 1 Refer to GFSC – 2023 Consultation paper on Fee rates for 2023.pdf, page 6 and 2024 Fee Consultation - Guernsey Financial Services Commission page 7.

Guernsey Financial Services Commission • www.gfsc.gg 8 4.2. Increase in fees for Retail General Insurers (‘RGI’) 4.2.1. In 2024, the Commission further developed the regulatory regime for retail general insurers. General insurance concerns coverage for house contents, bikes, health costs and so on. Guernsey offers such insurance on a global basis and retail insurers have become an increasingly significant part of the insurance sector in Guernsey. 4.2.2. RGIs have a greater ability than other insurers to damage the reputation of the Bailiwick through not fulfilling contracts with policyholders. Additionally, over recent years the Commission has had to dedicate substantial and increasing amounts of time to mitigate the risks which have crystallised around individual RGIs. To some extent the costs of this work have been borne by other licence holders through their annual fees. 4.2.3. We highlighted, during both the consultation and feedback period, that this would result in future consultation for an increase in fees for these types of insurers to reflect the additional resource requirement. The purpose of this change is not to shift supervisory resources from one sector to another but to increase the resources available for the supervision of RGIs. 4.2.4. Following further consultation with the Guernsey International Insurance Association (‘GIIA’) we are proposing a staged approach to the increase in fees for RGIs. RGI - Companies Gross Written Premium Current Fees 2025 20262 < £1m £10,585 £12,500 £15,000 £1m - £10mn £10,585 £15,000 £20,000

£10m £10,585 £17,500 £25,000 RGI - Cells Gross Written Premium Current Fees 2025 20263 < £1m £3,460 £9,500 £15,000 £1m - £10mn £3,460 £12,000 £20,000 £10m £3,460 £15,000 £25,000 2 These are the projected fees for 2026 but will be subject to the annual increase in line with the 2026 fee consultation. 3 These are the projected fees for 2026 but will be subject to the annual increase in line with the 2026 fee consultation.

Guernsey Financial Services Commission • www.gfsc.gg 9 4.2.5. This staged approach will allow firms and cells which provide general insurance to retail customers to adjust to the proposed increase in their annual fee. In addition, the banding of the fees means they are proportionate to the volume of activity being undertaken. 4.2.6. As detailed within the consultation paper we consider the activity of providing retail general insurance as being the same whether it is carried out from a company or from within a cell. – Therefore it is the intention that fees for RGIs which are companies and RGI cells will be increased to the same level by 2026. 4.2.7. These changes will not affect the fees for PCC cores which include RGI cells, provided that the core itself does not write retail business. For each RGI cell, an RGI fee will be charged at a cellular level for the cell carrying out the retail activity, rather than on the PCC core. The annual fee for a PCC core which contains RGI cells therefore will be the standard fee for the core of an insurance PCC. Question 2: Do you have any comments on the increase in fees for RGIs?

Guernsey Financial Services Commission • www.gfsc.gg 10 4.3. Applying to operate an investment exchange in the Bailiwick of Guernsey 4.3.1. The Commission aims to set fees that are fair, proportionate, and broadly aligned with the costs of regulation, as far as is reasonably practicable in each case. In light of this in our 2024 fees proposals we consulted on and implemented an increased fee for those entities operating an investment exchange in the Bailiwick of Guernsey. However, on reflection we noted that, an application fee for an entity intending to operate an investment exchange would only be £2,9254 , which would not be reflective of the level of due diligence and work that would be carried out during the licensing process. 4.3.2. Whilst we would welcome another reputable exchange operating in Guernsey, to reflect the amount of work that would be carried out on any application for a new operator we are proposing a specific £30,000 application fee. Question 3: Do you have any comments on the proposed application fee to operate an investment exchange in the Bailiwick? 4 Fee for Investment Licensee application in 2024.

Guernsey Financial Services Commission • www.gfsc.gg 11 4.4. Rationalisation of the fee regulations 4.4.1. The Commission’s fee regulations have developed over several years, with amendments made to each individual sector fee regulation from time to time. This has led to small differences in the wording of the fee regulations, even when referring to precisely the same fee. Whilst we have ensured that the fee for each activity, such as change in control or migrations and amalgamations, is the same across all sectors the fact that they are referenced in multiple locations overly complicates our fee regulations and makes them difficult to follow. 4.4.2. For our 2024 fee regulations we brought all the individual fee regulations together into one document for ease of reference. In our proposed 2025 fee regulations we have restructured and rationalised the individual fee regulations into one single document following the below principles:  Where a fee applies to more than one sector it has been added to an area detailing general or miscellaneous fees, for example change in controller fees.  Where a principle applies to multiple fees this has been detailed in the general fees section, for example that an application fee is due when the application is submitted.  All fees have been moved to schedules at the end of the fee regulations, which mirrors the appendices at the end of our annual fee consultations, making it easier for industry to identify the specific fees due and for the fees to be updated on an annual basis.  Re-ordering the layout of fees for each sector to make them clearer and easier to follow along with removing historic fees which are no longer applicable. 4.4.3. Whilst we have not made any material amendments to the fees being charged, with the exception of the points detailed earlier in this consultation paper, we are conscious that the proposed fee regulations do look significantly different to the previous fee regulations. On this basis the draft fee regulations have been included, as Appendix C, with this consultation document for industry consideration. Question 4: Do you have any comments on the proposed rationalisation of the fee regulations?

Guernsey Financial Services Commission • www.gfsc.gg 12 4.5. Next Steps 4.5.1. This Consultation will be open for a period of four weeks, with a closing date for responses of 4 October 2024. 4.5.2. Responses should be submitted through the Commission’s Consultation Hub, which can be found at https://consultationhub.gfsc.gg/. Guidance on how to provide feedback can be found in section 1.3 of this paper. 4.5.3. Following the consultation period, the Commission will collate and consider responses provided. The Commission will consult with the States of Guernsey before issuing a feedback statement. That statement will provide a summary of the responses received, together with the final fees that will come into force from 1 January 2025.

Guernsey Financial Services Commission • www.gfsc.gg 13 Appendix A – Questions for Public Comment Question 1: Do you have any comments on the overall proposed fee increase? Question 2: Do you have any comments on the increase in fees for RGIs? Question 3: Do you have any comments on the proposed application fee for an operator of an investment exchange? Question 4: Do you have any comments on the proposed rationalisation of the fee regulations?

Guernsey Financial Services Commission • www.gfsc.gg 14 Appendix B – Proposed 2025 Fee Rates B.1. Banking Sector Application Fees Current Fee for 2024 Proposed Fee for 2025 Bank Licence Application £46,550 £49,015

Annual Fees Current Fee for 2024 Proposed Fee for 2025 Total Assets Band: Below £500,000,000 £46,550 £49,015 £500,000,000 to £999,999,999 Total Assets x 0.00007062 Minimum of £46,550 Total Assets x 0.00007436 Minimum of £49,015 £1,000,000,000 or Greater £70,620 £74,365 Plus, Additional Fees for: Guernsey subsidiary banks 25% of relevant annual fee 25% of relevant annual fee Retail operations (both subsidiaries and branches) 50% of relevant annual fee 50% of relevant annual fee Additional trading names, where a bank is effectively operating multiple separate businesses under one licence 50% of relevant annual fee 50% of relevant annual fee Branches outside of the Bailiwick £17,655 £18,590

Guernsey Financial Services Commission • www.gfsc.gg 15 B.2. Insurance Sector Application Fees Current Fee for 2024 Proposed Fee for 2025 Part 1A – Insurers (including Mutual, Provident or Friendly Societies, PCCs, ICCs and ICs)

International Insurer including PCC or ICC Core: Life Insurer / Reinsurer (Category 1 / 2) £7,060 £7,435 Commercial Insurer / Reinsurer (Category 3 / 4) £10,585 £11,145 Captive Insurer / Reinsurer …..(Category 5) £7,175 £7,555 Category 6 £7,060 £7,435 Cell of a PCC or ICC: Life Insurer / Reinsurer (Category 1 / 2) £2,305 £2,425 Commercial Insurer / Reinsurer (Category 3 / 4) £3,460 £3,645 Captive Insurer / Reinsurer (Category 5) £2,305 £2,425 Non-Special Purpose Insurer (Category 6) £2,305 £2,425 Special Purpose Insurer (Category 6) £100 £105 Retail General Insurer (Company) - £12,500 Retail General Insurer (Cell) - £9,500 Application for Consent to a Scheme of Transfer of Long-Term Business £6,620 £6,970 Variation of Activities in respect of which Insurer is licenced £1,430 £1,505 Domestic Insurer £3,975 £4,185 Mutual, Friendly, or Provident Society £3,975 £4,185 Part 1B - Insurance Managers Current Fee for 2024 Proposed Fee for 2025 Insurance Managers £6,570 £6,920 Insurance Manager acting only for business underwritten by members of the Society of Lloyd’s £3,615 £3,805

Guernsey Financial Services Commission • www.gfsc.gg 16 B.2. Insurance Sector (continued) Application Fees (continued) Current Fee for 2024 Proposed Fee for 2025 Part 1C - Insurance Intermediaries Insurance Intermediary (Base Fee) £6,615 £6,965 Adding additional categories to existing license General – Personal Lines £235 £245 General – Commercial £460 £485 Long Term – Life £460 £485 Long Term – Regular Premium £700 £735 Long Term – Single Premium (Insurance Element) £2,270 £2,390

Guernsey Financial Services Commission • www.gfsc.gg 17 B.2. Insurance Sector (continued) Annual Fees Current Fee for 2024 Proposed Fee for 2025 Part 2A – Insurers (including Mutual, Provident or Friendly Societies, PCCs, ICCs and ICs) Active Life Insurer (ICC, PCC and Non￾Cellular) (Category 1 / 2) Net Policyholder Liabilities Band:

Below £1 £7,060 £7,435 £1 to £999,999 £9,165 £9,650 £1,000,000 to £9,999,999 £11,250 £11,845 £10,000,000 to £99,999,999 £17,500 £18,430 £100,000,000 to £499,999,999 £27,920 £29,400 £500,000,000 to £1,999,999,999 £54,065 £56,930 £2,000,000,000 or Greater £105,995 £111,615 Life Insurer Closed to New Business (ICC, PCC and Non-Cellular) (Category 1 / 2) Net Policyholder Liabilities Band:

Below £1 £7,060 £7,435 £1 to £9,999,999 £9,150 £9,635 £10,000,000 to £499,999,999 £12,595 £13,265 £500,000,000 or Greater £17,500 £18,430 Non-Life International Insurer: Commercial Insurer / Reinsurer (Category 3 / 4)1 £10,585 £11,145 Captive Insurer / Reinsurer (Category 5) £7,175 £7,555 Category 6 £7,060 £7,435 Retail General Insurers (Company) Gross Written Premium Band £1 to £9,999,999 - £12,500 £1,000,000 to £10,000,000 - £15,000 more than £10,000,000 - £17,500 Domestic Insurer Gross Written Premium Band: Below £12,000 £590 £620 £12,000 to £4,999,999 £3,975 £4,185 £5,000,000 or Greater £20,275 £21,350

1 For the purposes of Regulation 5, Category 3/4 insurers which have not written any business must pay a fee of £7,060 whilst insurers which have written business must pay a fee of £10,585.

Guernsey Financial Services Commission • www.gfsc.gg 18 B.2. Insurance Sector (continued) Annual Fees (continued Current Fee for 2024 Proposed Fee for 2025 Part 2A – Insurers (including Mutual, Provident or Friendly Societies, PCCS, ICCS and ICs) Mutual, Friendly, or Provident Society: Non-Commercial £590 £620 Commercial £3,975 £4,185 Cell of a PCC or ICC: Life Insurer / Reinsurer (Category 1 / 2) £2,305 £2,425 Commercial Insurer / Reinsurer (Category 3 / 4) £3,460 £3,645 Captive Insurer / Reinsurer (Category 5) £2,305 £2,425 Non-Special Purpose Insurer (Category 6) £2,305 £2,425 Special Purpose Insurer (Category 6) £100 £105 Retail General Insurers (Cell) Gross Written Premium Band

£1 to £9,999,999 - £9,500 £1,000,000 to £10,000,000 - £12,000 More than £10,000,00 - £15,000 Transformer Cell £100 £105 Dormant Cell £185 £195 Life policy cells £140 £145 Part 2B - Insurance Managers Current Fee for 2024 Proposed Fee for 2025 Insurance Managers (based on companies under management) Pure £6,235 £6,565 Commercial £10,440 £10,995 Society of Lloyd’s £3,615 £3,805

Guernsey Financial Services Commission • www.gfsc.gg 19 B.2. Insurance Sector (continued) Annual Fees (continued) Current Fee for 2024 Proposed Fee for 2025 Part 2C – Insurance Intermediaries Intermediary – Base fee £3,210 £3,380 Plus intermediary category of Intermediary license General – Personal Lines £235 £245 General – Commercial £460 £485 Long Term – Life £460 £485 Long Term – Regular Premium £700 £735 Long Term – Single Premium (insurance element) £2,270 £2,390

Long Term – Single Premium (POI element) £1,405 £1,480 Plus Intermediary turnover from Licensed Bailiwick Activity £0 - £249,999 £2,270 £2,390 £250,000 - £499,999 £3,435 £3,615 £500,000 - £749,999 £4,540 £4,780 £750,000 - £999,999 £5,685 £5,985 £1,000,000 - £1,999,999 £6,825 £7,185 £2,000,000 - £2,999,999 £7,975 £8,400 £3,000,000+ £9,105 £9,590

Guernsey Financial Services Commission • www.gfsc.gg 20 B.3. Fiduciary Sector Application Fees Current Fee for 2024 Proposed Fee for 2025 Personal Fiduciary Licence £1,285 £1,355 Primary Fiduciary Licence £2,930 £3,085 Secondary Fiduciary Licence £710 £750 Discretionary Exemption (Individual) £605 £635 Discretionary Exemption (Company or Partnership) £1,350 £1,420 Consent to Use a Name £2,290 £2,410

Annual Fees Current Fee for 2024 Proposed Fee for 2025 Personal Fiduciary Licensee £1,335 £1,405 Primary Fiduciary Licensee – Turnover Band: Below £250,000 £6,500 £6,845 £250,000 to £499,999 £12,990 £13,680 £500,000 to £999,999 £19,490 £20,525 £1,000,000 to £1,999,999 £25,980 £27,355 £2,000,000 to £3,999,999 £32,480 £34,200 £4,000,000 to £7,999,999 £38,970 £41,035 £8,000,000 to £15,999,999 £51,960 £54,715 £16,000,000 or Greater £64,955 £68,400 Pension Regulation Fee: Fixed Fee £590 £620 Fee per Scheme Member £1 Subject to a £7,500 cap per scheme £1 Subject to a £7,500 cap per scheme

Guernsey Financial Services Commission • www.gfsc.gg 21 B.4. Investment Sector Application Fees Current Fee for 2024 Proposed Fee for 2025 Open-Ended Collective Investment Schemes: Scheme £4,020 £4,235 Plus: Additional Fast Track Application Fee £530 £560 New Class of Existing Umbrella/Multi￾Class Scheme £910 £960 Plus: Additional Fee for Additional Elements to Fast Track Funds £530 £560 Closed-Ended Collective Investment Schemes: Authorised Scheme £4,020 £4,235 Plus: Fast Track Additional Application Fee £530 £560 Registered Scheme £4,550 £4,790 “De-QIFing” £3,245 £3,415 PIF Conversion £3,245 £3,415 Registration of Prospectus £530 £560 Form EX Notification £1,395 £1,470 Other Licensees £2,925 £3,080 Investment Exchange Operator £30,000 Extension of Licence £1,430 £1,505

Annual Fees Current Fee for 2024 Proposed Fee for 2025 Open-Ended Collective Investment Schemes: Schemes £4,020 £4,235 Plus: per Class £280 £295 Designated Territories Scheme (EX) £700 £735 Closed-Ended Collective Investment Schemes £4,020 £4,235 Designated Persons; Brokers; and Licensees with an Authorised Financial Advisor – Turnover Band: Below £1,500,000 £4,190 £4,410 £1,500,000 to £2,999,999 £6,600 £6,950 £3,000,000 to £5,999,999 £8,895 £9,365 £6,000,000 to 11,999,999 £11,480 £12,090 £12,000,000 or Greater £14,350 £15,110 Managers of Overseas Collective Investment Schemes £4,190 £4,410 Principal Managers of Open-Ended Schemes £2,095 £2,205 Managers of Closed-Ended Schemes £2,095 £2,205 Investment Exchanges £142,160 £149,695 Insurance Intermediary with PoI Licence £1,405 £1,480 Other Licensees £4,190 £4,410 Designated Territories £700 £735

Guernsey Financial Services Commission • www.gfsc.gg 22 B.6. Lending, Credit and Finance Sector Application Fees Current Fee for 2024 Proposed Fee for 2025 Licence Application for: Credit Providers (Home Finance) £6,000 £6,320 Credit Providers (Consumer Credit) £4,500 £4,740 Services Ancillary to Credit (Home Finance) £3,000 £3,160 Services Ancillary to Credit (Consumer Credit with less than £3,000,000 loans brokered in preceding calendar year) £1,000 £1,055 Services Ancillary to Credit (Consumer Credit with more than £3,000,000 loans brokered in preceding calendar year) £2,000 £2,105 Financial Firm Businesses £4,500 £4,740 Platforms £6,000 £6,320 Virtual Asset Service Providers (Exchanges and Stablecoin Issuers) £95,000 £100,035 Virtual Asset Service Providers (Non￾Exchanges) £25,000 £26,325 AMC held virtual asset AMC Issuer £3,750 £3,950 Each AMC Cell £500 £525 Exemption for a Company or Partnership £1,270 £1,335 Exemption for an Individual £570 £600 Variation of a Licence £1,345 £1,415

Guernsey Financial Services Commission • www.gfsc.gg 23 B.6. Lending, Credit and Finance Sector (continued) Annual Fees Current Fee for 2024 Proposed Fee for 2025 Credit Providers (Home Finance): Non-Bank with a Below £100,000,000 Lending Book £6,000 £6,320 Non-Bank with a Greater than £100,000,000 Lending Book £9,000 £9,475 Bank Credit Provider (Home Finance) 50% of Relevant Fee Above 50% of Relevant Fee Above Credit Providers (Consumer Credit): Non-Bank with a Below £10,000,000 Lending Book £4,500 £4,740 Non-Bank with a Greater than £10,000,000 Lending Book £7,500 £7,900 Bank Credit Provider (Consumer Credit) 50% of Relevant Fee Above 50% of Relevant Fee Above Services Ancillary to Credit: Home Finance £3,000 £3,160 Consumer Credit with less than £3,000,000 loans brokered in preceding year £1,000 £1,055 Consumer Credit with more than £3,000,000 loans brokered in preceding year £2,000 £2,105 Financial Firm Businesses £1,500 £1,580 Platforms £6,000 £6,320 Virtual Asset Service Providers: Exchanges and Stablecoin Issuers £95,000 £100,035 Non-Exchanges £25,000 £26,325 AMC held virtual asset AMC issuer £3,750 £3,950 Each AMC cell £500 £525

Guernsey Financial Services Commission • www.gfsc.gg 24 B.7. Prescribed Businesses Registration / Annual Fees Current Fee for 2024 Proposed Fee for 2025 Number of Full-Time / Full-Time Equivalent Staff: 1 to 5 £830 £875 6 £945 £995 7 £1,080 £1,135 8 £1,205 £1,270 9 £1,335 £1,405 10 £1,460 £1,535 11 £1,585 £1,670 12 £1,710 £1,800 13 £1,840 £1, 940 14 £1,965 £2,070 15 £2,090 £2,200 16 £2,215 £2,330 17 £2,345 £2,470 18 £2,470 £2,600 19 £2,595 £2,735 20 £2,720 £2,865 21 £2,850 £3,000 22 £2,975 £3,135 23 £3,105 £3,270 24 £3,225 £3,395 25 or Greater £3,350 £3,530 B.7. Director Registration Regime Registration / Annual Fees Current Fee for 2024 Proposed Fee for 2025 Director Registration Regime £75 £80

Guernsey Financial Services Commission • www.gfsc.gg 25 B.7. Other Fees and Penalties Miscellaneous Fees Administrative Financial Penalties Late Filing Penalty Current Fee for 2024 Proposed Fee for 2025 First Month £125 £125 Second Month £250 £250 Third Month £375 £375 Each Subsequent Month £375 £375 Inaccurate Filing Penalty Error Identified by Firm Error Identified by the Commission On identification of the error and return of the submission for correction by the firm £125 £500 Each subsequent month taken to correct the error £125 £500 Application Fees Current Fee for 2024 Proposed Fee for 2025 Consent Request to Incorporate a PCC or ICC not Connected to a Licence Application under a Supervisory Law £530 £560 Change of Controller £2,520 £2,655 Amalgamation and Migration £2,800 £2,950 Consent for removal of supervised Limited Liability Partnerships from the Register £2,605 £2,745 Consent for removal of a supervised limited partnership from the Register of Limited Partnerships £2,800 £2,950

1 APPENDIX C The Financial Services Commission (Fees and Administrative Penalties) Regulations, 2024 CONSOLIDATED VERSION FEES PERTAINING TO BANKING ................................................................................................... 7

1. Licensing of banks ......................................................................................................................... 7 (1) Application fee ......................................................................................................................... 7 (2) Annual fees ............................................................................................................................... 7 FEES PERTAINING TO INSURANCE BUSINESS, INSURANCE INTERMEDIARIES AND INSURANCE MANAGERS ......................................................................................................... 8
2. Licensing of insurers (including mutual, provident, or friendly societies, ............................. 8 incorporated cell companies (“ICCs”), protected cell companies (“PCCs”) and ......................... 8 incorporated cells (“ICs”)) ................................................................................................................... 8 (1) Application fees ........................................................................................................................... 8 (2) Annual fees ................................................................................................................................... 8
3. Authorisation of new PCs and the reactivation of existing dormant PCs ............................... 8
4. Licensing of insurance managers .................................................................................................... 9 (1) Application fees ........................................................................................................................... 9 (2) Annual fees ................................................................................................................................... 9
5. Licensing of insurance intermediaries ............................................................................................ 9 (1) Application fees ........................................................................................................................... 9 (2) Annual fees ................................................................................................................................... 9 FEES PERTAINING TO CONTROLLED INVESTMENT BUSINESS .......................................... 11
6. Licensing of persons conducting controlled investment business. .......................................... 11 (1) Application fees ......................................................................................................................... 11 (2) Annual fees ................................................................................................................................. 11
7. Authorisation or registration of collective investment schemes ............................................... 12 (1) Application fees ......................................................................................................................... 12 (2) Annual fees ................................................................................................................................. 12
8. Designated territory investment business notification (“Form EX Notification”) ................. 12 (1) Notification fees ......................................................................................................................... 12 (2) Annual fees ................................................................................................................................. 13

2 9. Registration of a prospectus........................................................................................................... 13 10. Insurance Intermediaries undertaking restricted activities under the PoI Law ................... 13 FEES PERTAINING TO FIDUCIARIES ........................................................................................... 15 11. Licensing of fiduciaries ................................................................................................................. 15 (1) Application fees ......................................................................................................................... 15 (2) Annual fees ................................................................................................................................. 15 FEES PERTAINING TO THE PROVISION OF CREDIT ............................................................... 17 12. Part II licences; provision of credit .............................................................................................. 17 (1) Application fees ......................................................................................................................... 17 (2) Annual fees ................................................................................................................................. 17 13. Part II licences; services ancillary to the provision of credit .................................................... 17 (1) Application fees ......................................................................................................................... 17 (2) Annual fees ................................................................................................................................. 18 FEES PERTAINING TO FINANCIAL FIRM BUSINESSES .......................................................... 19 14. Part III Licences: Financial firm businesses (“FFB”) ................................................................. 19 (1) Application fees ......................................................................................................................... 19 (2) Annual fees ................................................................................................................................. 19 FEES PERTAINING TO PLATFORMS ............................................................................................ 20 15. Part IV licences: Financial platforms and intermediation platforms ...................................... 20 (1) Application fees ......................................................................................................................... 20 (2) Annual fees ................................................................................................................................. 20 FEES PERTAINING TO VIRTUAL ASSET SERVICE PROVIDERS ............................................ 21 16. Part III Licences: Virtual asset service providers (“VASP”) .................................................... 21 (1) Application fees ......................................................................................................................... 21 (2) Annual fees ................................................................................................................................. 21 17. Part III Licences: Actively Managed Certificates (“AMC”) holding virtual assets .............. 21 (1) Application fees ......................................................................................................................... 21 (2) Annual fees ................................................................................................................................. 22 MISCELLANEOUS FEES ................................................................................................................... 23 18. Incorporation and conversions of cellular and non-cellular companies................................ 23 19. Removal of supervised Limited Liability Partnerships from the Register ............................ 23 20. Fee payable on application for consent of Commission for migration of supervised limited partnership................................................................................................................................... 23 21. Amalgamations and Migrations .................................................................................................. 23 22. Change of controller...................................................................................................................... 24

3 23. “De-QIFing” and ”PIF” conversion fee ...................................................................................... 24 24. LCF Applications ........................................................................................................................... 24 25. Applications under section 45(3) of the Insurance Business Law .......................................... 25 26. Conversion applications ............................................................................................................... 25 GENERAL POWERS OF THE COMMISSION: FEES .................................................................... 26 27. Application and notification fees ................................................................................................ 26 28. Annual fees..................................................................................................................................... 26 GENERAL POWERS OF THE COMMISSION: WAIVERS AND PENALTIES .......................... 27 29. Power of Commission to waive fees and penalties .................................................................. 27 30. Penalties for late filing of relevant documents .......................................................................... 27 31. Penalties for inaccurate filing of relevant documents – Schedule 8 to this regulation ........ 27 32. Penalties for late payment of fees – Schedule 8 to this Regulation ......................................... 28 33. Appeals against the imposition of penalties .............................................................................. 29 34. Effect on other penalties and sanctions ...................................................................................... 29 35. Powers of the Commission: Recoverability of fees and penalties .......................................... 29 INTERPRETATION, REVOCATIONS AND COMMENCEMENT ............................................. 30 36. Interpretation ................................................................................................................................. 30 37. Revocations .................................................................................................................................... 35 38. Citation ........................................................................................................................................... 35 39. Commencement ............................................................................................................................. 35 SCHEDULE 1 ....................................................................................................................................... 36 Relevant documents ........................................................................................................................ 36 SCHEDULE 2 ....................................................................................................................................... 38 Fees Payable - Banking ................................................................................................................... 38 Part 1 – Application Fees ................................................................................................................ 38 Part 2 – Annual Fees ....................................................................................................................... 38 SCHEDULE 3 ....................................................................................................................................... 39 Fees Payable - Insurance................................................................................................................. 39 Part 1 – Application Fees ................................................................................................................ 39 Part 2 – Annual Fees ....................................................................................................................... 40 SCHEDULE 4 ....................................................................................................................................... 43 Fees Payable - Investment .............................................................................................................. 43 Part 1 – Application Fees ................................................................................................................ 43 Part 2 – Annual Fees ....................................................................................................................... 43 SCHEDULE 5 ....................................................................................................................................... 45

4 Fees Payable – Fiduciary ................................................................................................................ 45 Part 1 – Application Fees ................................................................................................................ 45 Part 2 – Annual Fees ....................................................................................................................... 45 SCHEDULE 6 ....................................................................................................................................... 47 Fees Payable – LCF Law ................................................................................................................. 47 Part 1 – Application Fees ................................................................................................................ 47 Part 2 – Annual Fees ....................................................................................................................... 47 SCHEDULE 7 ....................................................................................................................................... 49 Miscellaneous ................................................................................................................................... 49 Consent Request to Incorporate a PCC or ICC not Connected to a Licence Application under a Supervisory Law ............................................................................................................... 49 Consent for removal of supervised Limited Liability Partnerships from the Register .......... 49 Consent for removal of a supervised limited partnership from the Register of Limited Partnerships ..................................................................................................................................... 49 Amalgamation and Migration fees ............................................................................................... 49 Change of Controller fees ............................................................................................................... 49 Application under section 438 and/or 469 of the Companies Law ........................................... 49 SCHEDULE 8 ....................................................................................................................................... 50 Penalties ............................................................................................................................................ 50 Late Payment ................................................................................................................................... 50 Late Filing ......................................................................................................................................... 50 Inaccurate Filing Penalty ................................................................................................................ 50

5 THE GUERNSEY FINANCIAL SERVICES COMMISSION, in exercise of the powers conferred upon it by section 13 and 25 of the Financial Services Commission (Bailiwick of Guernsey) Law, 1987a , sections 22 and 23 of the Protection of Investors (Bailiwick of Guernsey) Law, 2020b , sections 7 and 60 of the Banking Supervision (Bailiwick of Guernsey) Law, 2020c , sections 7 and 53 of the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc. (Bailiwick of Guernsey) Law, 2020d , sections 40, 50 and 129 of The Financial Services Business (Enforcement Powers) (Bailiwick of Guernsey) Law, 2020e sections 85, 86 and 94 of the Insurance Business (Bailiwick of Guernsey) Law, 2002f, and sections 62, 63 and 71 of the Insurance Managers and Insurance Intermediaries (Bailiwick of Guernsey) Law, 2002g, sections 12, 22, 33 and 37 of the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022, sections 66(2)(i), 94(2)(e), 438, 469, 534, 535 and 538 of the Companies (Guernsey) Law, 2008h , sections 36(2)(c), 45 and 113 of the Limited Liability Partnerships (Guernsey) Law, 2013i , paragraph 3A of schedule 5 to the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999j , k and all other powers enabling it in that behalf, and where required, after consultation with, hereby

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a Ordres en Conseil Vol. XXX, p. 243; as amended by Vol. XXXI, p. 278; Vol. XXXIII, p. 471; Vol. XXXV (1), p. 271; XXXVII, p. 24; Vol. XLII (2), p. 644; Vol. XLII (2), p. 766; Vol. XLIII (1), p. 49; Vol. XLIII (2), p. 574; No's. XIX, XXIII and XXIV of 2008; No. XIX of 2010; No. III of 2013; No. I of 2015; No. IX of 2016 Recueil d'Ordonnances Tome XXIX, p. 406; Ordinance No. XXXIV of 2005; No. XXXIII of 2009; No. XII of 2015; No. XX of 2015; No. XXXIX of 2015; G.S.I. No. 29 of 2009. b Order in Council No. XVIII of 2020. c Order in Council No.XX of 2020. d Order in Council No.XIX of 2020. e Order in Council No. XVII of 2020. f Order in Council No. XXI of 2002; as amended by No. I of 2000; No. XIII of 2010; Ordinance No. XXXIII of 2003; No's. XII and LI of 2008; No's. VIII and XXXI of 2010; No. XXXVI of 2011; No. LV of 2014; Nos. XII and XX of 2015; No. IX of 2016; G.S.I. No. 33 of 2004; G.S.I. No. 4 of 2008; G.S.I. No's. 15 and 83 of 2010; G.S.I. No. 68 of 2014. g Order in Council No. XXII of 2002; No. I of 2000; No. XIII of 2010; Ordinance No. XXXIII of 2003; No. XIII of 2008; No's. IX and XXXII of 2010; Nos. XII and XX of 2015; No. IX of 2016; G.S.I. No. 2 of 2008; G.S.I. No's. 16 and 83 of 2010. h Order in Council No. VIII of 2008. i Order in Council No. VI of 2014. j No. VIII of 1999 (Ordres en Conseil Vol. XXXIX, p. 137) k Ordres en Conseil Vol. XXXIX, p.137

6 makes the following Regulations:

7 FEES PERTAINING TO BANKING

1. Licensing of banks Application fee (a) The application fees to be paid to the Commission under section 5 of the Banking Law are contained in Schedule 2, part 1 to this regulation. Annual fees (a) The annual fees to be paid to the Commission by a licensed institution are contained in Schedule 2, part 2 to this regulation.

8 FEES PERTAINING TO INSURANCE BUSINESS, INSURANCE INTERMEDIARIES AND INSURANCE MANAGERS 2. Licensing of insurers (including mutual, provident, or friendly societies, incorporated cell companies (“ICCs”), protected cell companies (“PCCs”) and incorporated cells (“ICs”)) (1) Application fees (a) The application fees to be paid under section 6, section 11 and section 94 of the Insurance Business Law are set out in Schedule 3, part 1A to this regulation. (b) The application fee payable by a licensee making application to the Commission for a variation of an insurance license is set out in Schedule 3, part 1A to this regulation. (2) Annual fees (a) The annual fees to be paid by insurers licensed under section 7 of the Insurance Business Law are set out in Schedule 3, part 2A to this regulation. 3. Authorisation of new PCs and the reactivation of existing dormant PCs (a) The application fees to be paid for the authorisation of new PCs is set out in Schedule 3, part 1A to this regulation. (b) The fee to be paid for the reactivation of an existing dormant PC is a pro-rata amount of the annual fee relevant to its business plan, calculated from the month reactivation is affected until the end of the year, less the amount of the annual fee already paid in respect of the protected cell.

9 4. Licensing of insurance managers (1) Application fees (a) The application fees to be paid under section 3 of the IMII Law are set out in Schedule 3, part 1B to this regulation. (2) Annual fees (a) The annual fees to be paid by insurance managers licensed under section 4 of the IMII Law are set out in Schedule 3, part 2B to this regulation. 5. Licensing of insurance intermediaries (1) Application fees (a) The application fees to be paid under section 3 of the IMII Law are set out in Schedule 3, part 1C to this regulation. (2) Annual fees (a) The annual fees to be paid by insurer intermediaries licensed under section 4 of the IMII Law are set out in Schedule 3, part 2C to this regulation. (3) In this regulation, "brokerage turnover" means - (a) the figure, if any, shown in the intermediary’s audited financial statements as being the gross turnover from that intermediary's activities as an insurance intermediary in the financial year or, if none,

10 (b) the figure, if any, certified by the auditor to the Commission as being the gross turnover from the activities as an insurance intermediary in the financial year or, (c) the figure shown in the audited financial statements as being the gross turnover in the financial year, or, (d) in the case of an intermediary not obliged to produce audited financial statements for the financial year or not yet carrying on any activities as an insurance intermediary, the figure agreed between him and the Commission as an estimate of the gross turnover from that intermediary's activities as an insurance intermediary for the financial year, provided that if the financial year was not a period of twelve months, the intermediary’s brokerage turnover shall be the brokerage turnover as determined above divided by the number of calendar months and any part of in that financial year and multiplied by twelve.

11 FEES PERTAINING TO CONTROLLED INVESTMENT BUSINESS 6. Licensing of persons conducting controlled investment business. (1) Application fees (a) The application fees to be paid under section 3 of the PoI Law for a licence to carry on controlled investment business in or from within the Bailiwick are set out in Schedule 4, part 1 to this regulation. (b) The application fees payable by a licensee making an application to the Commission for a variation of that licence – (i) to include a further controlled investment category, (ii) to include further restricted activities within a controlled investment category, are set out in Schedule 4, part 1 to this regulation. (2) Annual fees (a) The annual fees to be paid by a person who is licensed under section 4 of the PoI Law to carry on controlled investment business are set out in Schedule 4, part 2 to this regulation. (3) For the purposes of this regulation “turnover” means – (a) the figure shown in a person’s audited financial statements as being the gross turnover from their activities in the relevant accounting period or, if none,

12 (b) the figure certified by their auditor to the Commission as being the gross turnover from their activities in the relevant accounting period, or, (c) in the case of a person not obliged to produce audited financial statements for the relevant accounting period or not yet carrying on any regulated activity, the figure agreed between them and the Commission as an estimate of the gross turnover from activities in the relevant accounting period, provided that if the relevant accounting period was not a period of twelve months, the turnover shall be the turnover determined as above divided by the number of months, including any part of a month, in the relevant accounting period and multiplied by twelve. 7. Authorisation or registration of collective investment schemes (1) Application fees (a) The application fees to be paid under section 8 of the PoI Law are set out in Schedule 4, part 1 to this regulation. (2) Annual fees (a) The annual fees to be paid by a designated administrator of an open-ended or closed-ended collective investment scheme authorised or registered under section 8 of the PoI Law are set out in Schedule 4, Part 2 to this regulation. 8. Designated territory investment business notification (“Form EX Notification”) (1) Notification fees

13 (a) The fee which is payable for each collective investment scheme for which notice is given, under section 44(1)(c)(iv) of the PoI Law, by a person which intends to promote a collective investment scheme in or from within the Bailiwick of Guernsey if the designated country or territory in or from within which, and under the law of which, it is permitted to promote the scheme is anywhere other than the Bailiwick of Jersey is set out in Schedule 4, part 1 to this regulation. If the designated country or territory is the Bailiwick of Jersey, the fee is nil. (2) Annual fees (a) The annual fees to be paid to the Commission by the person who has given notice, in accordance with section 44(1)(c)(iv) of the PoI Law, and in respect of which the Commission’s decision that the person giving the notice is a person to whom section 44(1)(c) of that Law applies is made on or after 1 January, 2010, are set out in Schedule 4, part 2 to this regulation. 9. Registration of a prospectus Where a prospectus is submitted to the Commission for registration of an entity offering a Category 2 controlled investment which is neither an authorised or registered collective investment scheme nor applying to become an authorised or regulated collective investment scheme, a fee as set out in Schedule 4, part 1, is payable to the Commission. 10. Insurance Intermediaries undertaking restricted activities under the PoI Law Where an insurance intermediary is licensed under the PoI Law for either or both of the restricted activities of promotion and advising, and no other restricted activities in respect of “Category 1: collective investment schemes” under Schedule 1 of that Law; or a licensed intermediary applies to the Commission to extend the activities for which

14 it is licensed to carry on business to provide advice on long term single premium products and if the intermediary is licensed under the PoI law as aforementioned.

15 FEES PERTAINING TO FIDUCIARIES 11. Licensing of fiduciaries (1) Application fees (a) The application fees to be paid under section 5 of the Fiduciary Law are set out in Schedule 5, part 1 to this regulation. (b) Where an application for a primary fiduciary licence and one or more secondary fiduciary licences is submitted jointly by companies which are in the same ownership and have common staff, procedures, and clients, the applicants shall nominate one of their number as the designated primary fiduciary licensee. (2) Annual fees (a) The annual fees to be paid to the Commission in relation to fiduciaries are set out in Schedule 5, part 2 to this regulation. (3) In this regulation “fiduciary turnover” means – (a) the figure, if any, shown in a person’s audited financial statements as being the gross turnover from that person's regulated activities in the relevant accounting period or, if none, (b) the figure, if any, certified by that person's auditor to the Commission as being the gross turnover from the regulated activities in the relevant accounting period or, if none, (c) the figure shown in the audited financial statements as being the gross turnover in the relevant accounting period, or

16 (d) in the case of a person not obliged to produce audited financial statements for the relevant accounting period or not yet carrying on any regulated activity, the figure agreed between him and the Commission as an estimate of the gross turnover from regulated activities in the relevant accounting period provided that – (i) if the relevant accounting period was not a period of twelve months, the person’s fiduciary turnover shall be that person's fiduciary turnover determined as above divided by the number of months, including any part of, in the relevant accounting period and multiplied by twelve, and (ii) if the person made a joint application, the gross turnover or gross turnover from regulated activities, of that person and of any other persons with whom he made and remains eligible to make a joint application shall, for the purposes of this regulation, be the aggregate gross turnover, or as applicable the aggregate gross turnover from regulated activities, of all of those persons.

17 FEES PERTAINING TO THE PROVISION OF CREDIT 12. Part II licences; provision of credit (1) Application fees (a) The application fees to be paid by a person applying to the Commission under section 12 of the LCF Law to be licensed as a credit business, alternatively for an exemption from licensing in accordance with the provisions of regulations made under section 9 of the LCF Law, alternatively for a disapplication from the requirement to hold a Part II licence in respect of the provision of credit under section 40 of the LCF Law, are set out in Schedule 6, part 1 to this regulation. (2) Annual fees (a) The annual fees to be paid by a person who is licensed under section 12 of the LCF Law to remain licensed as a credit business, are set out in Schedule 6, part 2 to this regulation. 13. Part II licences; services ancillary to the provision of credit (1) Application fees (a) The application fees to be paid by a person applying to the Commission under section 12 of the LCF Law to be licensed to provide services ancillary to the provision of credit, alternatively for an exemption from licensing in accordance with the provisions of regulations made under section 9 of the LCF Law, alternatively for a disapplication from the requirement to hold a Part II licence

18 in respect of the provision of services ancillary to the provision of credit under section 40 of the LCF Law, are set out in Schedule 6, part 1 to this regulation. (2) Annual fees (a) The annual fees to be paid by a person who is licensed under section 12 of the LCF Law to be licensed to provide services ancillary to the provision of credit, are set out in Schedule 6, part 2 to this regulation.

19 FEES PERTAINING TO FINANCIAL FIRM BUSINESSES 14. Part III Licences: Financial firm businesses (“FFB”) (1) Application fees (a) The application fees to be paid by a person applying to the Commission under section 22 of the LCF Law to be licensed as a financial firm business, alternatively for an exemption from licensing in accordance with the provisions of regulations made under section 20 or 21 of the LCF Law, alternatively for a disapplication from the requirement to hold a Part III FFB licence under section 40 of the LCF Law are set out in Schedule 6, part 1 to this regulation. (2) Annual fees (a) The annual fees to be paid by a person who is licensed under section 22 of the LCF Law to be licensed as a financial firm business are set out in Schedule 6, part 2 to this regulation.

20 FEES PERTAINING TO PLATFORMS 15. Part IV licences: Financial platforms and intermediation platforms (1) Application fees (a) The application fees to be paid by a person applying to the Commission under section 33 of the LCF Law to be licensed to carry on financial platform or intermediation business, alternatively for an exemption from licensing in accordance with the provisions of regulations made under section 32 of the LCF Law, alternatively for a disapplication from the requirement to hold a Part IV licence under section 40 of the LCF Law are set out in Schedule 6, part 1 to this regulation. (2) Annual fees (a) The annual fees to be paid by a person who is licensed under section 33 of the LCF Law to be licensed to be licensed to carry on financial platform or intermediation business are set out in Schedule 6, part 2 to this regulation.

21 FEES PERTAINING TO VIRTUAL ASSET SERVICE PROVIDERS 16. Part III Licences: Virtual asset service providers (“VASP”) (1) Application fees (a) The application fees to be paid by a person applying to the Commission under section 22 of the LCF Law to be licensed as a VASP, alternatively for an exemption from licensing in accordance with the provisions of regulations made under section 21 of the LCF Law, alternatively for a disapplication from the requirement to hold a Part III VASP licence under section 40 of the LCF Law are set out in Schedule 6, part 1 to this regulation. (2) Annual fees (a) The annual fees to be paid by a person who is licensed under section 22 of the LCF Law to be licensed as a VASP are set out in Schedule 6, part 2 to this regulation. 17. Part III Licences: Actively Managed Certificates (“AMC”) holding virtual assets (1) Application fees (a) The application fees to be paid by a person applying to the Commission under section 22 of the LCF Law to be licensed as an AMC licensed to hold virtual assets, alternatively for an exemption from licensing in accordance with the provisions of regulations made under section 21 of the LCF Law, alternatively for a disapplication from the requirement to hold a Part III VASP (AMC)

22 licence under section 40 of the LCF Law are set out in Schedule 6, part 1 to this regulation. (2) Annual fees (a) The annual fees to be paid by a person who is licensed under section 22 of the LCF Law to be licensed as an AMC licensed to hold virtual assets are set out in Schedule 6, part 2 to this regulation.

23 MISCELLANEOUS FEES 18. Incorporation and conversions of cellular and non-cellular companies (a) The application fees payable under section 438 or section 469 of the Companies Law are set out in Schedule 7 to this regulation. Applications can be made by any person, with the exception of (i) a licensee within the meaning of section 4 of the Enforcement Powers Law, or (ii) an applicant for a licence under any of the supervisory Laws within the meaning of section 2(b) of the Enforcement Powers Law. 19. Removal of supervised Limited Liability Partnerships from the Register The fee which, under section 45(2)(d) of the LLP Law, must accompany an application to the Commission for the consent of the Commission for a supervised LLP to be removed from the Register is set out in Schedule 7 to this regulation. 20. Fee payable on application for consent of Commission for migration of supervised limited partnership The fee which, under regulation 17(1)(e) of the Limited Partnerships (Guernsey)(Migration) Regulations, 2020, must accompany an application to the Commission for the consent of the Commission for the removal of a supervised limited partnership from the Register of Limited Partnerships for the purposes of becoming registered as a limited partnership under the law of a district, territory or place outside Guernsey in accordance with the provisions of those regulations is set out in Schedule 7 to this regulation. 21. Amalgamations and Migrations

24 The fees payable in relation to applications made under section 66(2)(i) of the Companies Law for the consent of the Commission for the amalgamation of two or more bodies corporate pursuant to Part VI of that Law and applications made under section 94(2) of the Companies Law for the consideration of the Commission for the removal of a supervised company from the Registrar of Companies for the purposes of becoming registered as a company under the law of a district, territory or place outside Guernsey in accordance of Part VII of that Law are set out in Schedule 7 to this regulation. 22. Change of controller The fees payable in relation to a change of controller application under section 14 of the Banking Law, section 25 of the Insurance Business Law, section 37 of the IMII Law, section 40 of the PoI Law, section 14 of the Fiduciary Law and section 43 of the LCF Law are set out in Schedule 7 to this regulation. 23. “De-QIFing” and ”PIF” conversion fee The fees payable where a collective investment scheme authorised under section 8 of the PoI Law, on which a condition has been imposed under section 9 of the Law, wishes to have a condition that restricts the types of persons who may invest in the scheme, requires the removal of that restrictions associated with being a Qualified Investor Fund or the conversion of a Private Investment Fund (“PIF”) to another class of scheme are set out in Schedule 4, part 1. 24. LCF Applications Where an application fee or annual fee is payable under the LCF Law, in the event that a provider falls under more than one category of LCF Licence, it shall pay the higher

25 fee only. Where an applicant provides both credit in relation to home finance and consumer credit, the applicant shall pay the higher of the two fees only. 25. Applications under section 45(3) of the Insurance Business Law The fees payable by a body serving an application under section 45(3) of the Insurance Business Law to the Royal Court for an order under section 44 of that Law sanctioning a scheme for the transfer of long-term business is set out in Schedule 3, part 1 to this regulation. 26. Conversion applications The application fees to be paid for the purposes of applications made under section 438 and/or section 469 of the Companies Law are set out in Schedule 7 of this regulation.

26 GENERAL POWERS OF THE COMMISSION: FEES 27. Application and notification fees Unless set out to the contrary, application and notification fees are to be paid at the time of making the application. 28. Annual fees (1)Unless set out to the contrary, annual fees are to be paid on or before the last day of the month in which the licensee is first licensed, the fee being one twelfth of the relevant fee payable in the Schedules to this regulation, multiplied by the number of calendar months and any part of between the date on which the licensee is first licensed and the end of the calendar year in which that date falls, and subsequently on or before 31 January each year where the licence is in effect on 1 January of that year, taking into account any specific bandings as more fully set out in the Schedules to this regulation. (2)Where any bandings apply, these must be demonstrated to the Commission prior to the fee becoming due.

27 GENERAL POWERS OF THE COMMISSION: WAIVERS AND PENALTIES 29. Power of Commission to waive fees and penalties The Commission may in its absolute discretion waive any fee, or part of a fee, penalty, or part of a penalty payable pursuant to this regulation. 30. Penalties for late filing of relevant documents (1)A late filing penalty shall become due in the event that a person does not file with the Commission the relevant documents set out at Schedule 1, by or on the last date on which that document was required to be filed with the Commission by that person. (2)A late filing penalty shall be calculated in accordance with the filing date which will be included in the submissions area of the Online Portal and will be particular to each submitter. (3)The late filing penalty arising in (1) – (a) shall be incurred whilst the document remains outstanding after the filing date, commencing from the day after the filing date, and (b) shall not be incurred on the day of filing the document, save where that day is the day immediately after the filing date in which case a penalty shall be incurred. (4)The late filing penalty fees are set out in Schedule 8 to this regulation. 31. Penalties for inaccurate filing of relevant documents – Schedule 8 to this regulation

28 (1) An inaccurate filing of relevant documents penalty shall become due in the event that a person has made an inaccurate submission to the Commission. (2) The fees for penalties for inaccurate filing are set out in Schedule 8 to this regulation. 32. Penalties for late payment of fees – Schedule 8 to this Regulation (1) A late payment penalty shall become due in the event that any fee detailed in regulation 1 to regulation 26 is not paid in full by the due date. For the avoidance of doubt, part payment of a fee, unless the Commission has agreed thereto prior to the part payment being made, shall not result in the late payment penalty not being due or accruing. (2) The late payment arising at (1) – (a) shall be incurred whilst the fee remains outstanding in whole or part after the due date, commencing from the day after the due date, and (b) shall not be incurred on the day of payment of the entirety or the remainder of the outstanding fee. (3) For the purposes of this regulation, “due date” is – (a) the date specified by those regulations as the date by which the fee must be paid, or (b) if no date is so specified, a date notified by the Commission to the person obliged to pay the fee in question which shall not be less than 30 days after the day on which the fee first became payable.

29 33. Appeals against the imposition of penalties The provisions of section 106 of the Enforcement Powers Law apply in relation to a decision of the Commission to impose a late filing penalty, inaccurate filing penalty or late payment penalty as they apply in relation to a decision of the Commission described in section 106, except that the sole ground of appeal is that the decision was wrong. 34. Effect on other penalties and sanctions The imposition of a late filing penalty, inaccurate filing penalty or late payment penalty under these Regulations is without prejudice to any other power, penalty, sanction or remedy, whether criminal, civil or administrative, provided for by or under the prescribed Laws. 35. Powers of the Commission: Recoverability of fees and penalties (1)The fees and penalties payable under these Regulations – (a) are recoverable by the Commission from the person obliged to pay as a civil debt, and (b) are not refundable. (2)If any fee or penalty due under these Regulations is not paid when it is due, the Commission shall, without prejudice to any other remedy in respect of non￾payment, be entitled to the payment of interest calculated on that fee or so much of it as may for the time being be outstanding at the rate of 10% per annum from the date on which payment became due to that on which payment is made.

30 INTERPRETATION, REVOCATIONS AND COMMENCEMENT 36. Interpretation In these Regulations, unless the context otherwise requires – “AMC” means Actively Managed Certificate, "Banking Law" means the Banking Supervision (Bailiwick of Guernsey) Law, 2020, "brokerage turnover" has the meaning given by regulation 5(3), “Category 1” means a long-term insurer with any element of unrelated party business or an insurer so categorised by the Commission under the Insurance Business (Solvency) Rules, 2021l , “Category 2” means a long-term reinsurer with any element of unrelated party business or an insurer so categorised by the Commission under the Insurance Business (Solvency) Rules, 2021, "Category 3" means a general insurer with an element of unrelated party business or an insurer so categorised by the Commission under the Insurance Business (Solvency) Rules, 2021, "Category 4" means a general reinsurer providing reinsurance to a commercial insurer, whether or not part of the same group, and with no direct business or an insurer so categorised by the Commission under the Insurance Business (Solvency) Rules, 2021, "Category 5" means a life or general insurance or reinsurance entity created and owned, directly or indirectly, by one or more industrial, commercial or financial entities or associations, the purpose of which is to provide insurance or reinsurance cover for risks (other than commercial insurance risks) of the entity or entities to which it belongs, or for entities connected to those entities or an insurer so categorised by the Commission under the Insurance Business (Solvency) Rules, 2021,

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l G.S.I. No136 of 2021.

31 "Category 6" means an insurance or reinsurance entity that falls under one of the following categories - (a) transformer cells, being cells of a protected cell company or incorporated cell company whose primary purpose is to enable transactions between the capital and insurance markets by converting contracts written on International Swaps and Derivatives Association master agreements and other documentation into contracts written on traditional insurance documentation or vice versa, (b) Special Purpose Insurers as defined under the Insurance Business Rules 2021m, that are not cells defined in (a), or (c) entities or a cell of a protected cell company or incorporated cell company which the Commission has agreed in writing may fall into this category under the Insurance Business (Solvency) Rules, 2021, "the Commission" means the Guernsey Financial Services Commission, established by the Financial Services Commission (Bailiwick of Guernsey) Law, 1987, “Companies Law” means the Companies (Guernsey) Law, 2008, "consumer credit" means credit provided pursuant to a regulated agreement that falls within the provisions of section 6(1)(a) of the LCF Law, "credit" has the meaning given under section 4 of the LCF Law, “dormant cell” means a cell of a protected cell company in respect of which there are no unexpired insurance policies and no insurance liabilities, “due date” see regulation 32(3), "Enforcement Powers Law", means the Financial Services Business (Enforcement Powers) (Bailiwick of Guernsey) Law, 2020,

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m G.S.I No 137 of 2021

32 "Fiduciary Law" means the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc. (Bailiwick of Guernsey) Law, 2020, "fiduciary licence" means a primary fiduciary licence, secondary fiduciary licence or a personal fiduciary licence, "fiduciary turnover" has the meaning given by regulation 11(3), “filing” includes delivery, deposit, furnishing and submission (and related expressions shall be construed accordingly), “filing date” see regulation 30 and Schedule 1, "financial firm business" means a business specified in Part A of Schedule 1 to the LCF Law, "financial platform or intermediation business" has the meaning given by section 26 of the LCF Law, “gratuity scheme” has the meaning given in section 2(1)(e) of the Fiduciary Law, "home finance" means credit provided pursuant to a regulated agreement that falls within the provisions of section 6(1)(b) of the LCF Law, “incorporated cell” (“IC”) means an incorporated cell within the meaning of the Companies Law, “incorporated cell company” (“ICC”) means an incorporated cell company within the meaning of the Companies Law, "Insurance Business Law" means the Insurance Business (Bailiwick of Guernsey) Law, 2002, "IMII Law" means the Insurance Managers and Insurance Intermediaries (Bailiwick of Guernsey) Law, 2002 "joint application" means an application of the type described in regulation 11, "lending book" has the meaning given by the LCF Rules, "LCF Law" means the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022,

33 “LCF Rules” means the Lending, Credit and Finance Rules, 2022n , “licensee” means a person or entity which holds a licence under the supervisory Laws to carry out business under those Laws, “LLP Law” means the Limited Liability Partnerships (Guernsey) Law, 2013, "manager", in relation to a closed-ended investment company, a closed-ended unit trust or a closed-ended limited partnership, means an entity equivalent to a principal manager of a collective investment scheme authorised by the Commission, “month” means a calendar month calculated from the beginning of the first day of the period of default (and for the avoidance of doubt if a month starts at the end of a month of the calendar which contains more days than the next month of the calendar, the month expires at the end of that next month of the calendar), “pension scheme” has the meaning given in section 59 of the Fiduciary Law, "personal fiduciary licence" means a fiduciary licence granted by the Commission of the category set out in section 4(4) of the Fiduciary Law, "PoI Law" means the Protection of Investors (Bailiwick of Guernsey) Law, 2020, “prescribed Laws” has the meaning given by the Enforcement Powers Law, “primary fiduciary licence” means a fiduciary licence granted by the Commission of the category set out in section 4(2) of the Fiduciary Law, "principal documents", in relation to - (a) a unit trust scheme, means the trust deed, (3) a company scheme, means the articles of association of a Bailiwick company (or the equivalent document under the applicable law of a body corporate incorporated elsewhere than in the Bailiwick), the management agreement and the trustee agreement, (4) a collective investment scheme other than a unit trust scheme or a company scheme, means the documents dealing collectively with the same or similar

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n G.S.I. No. 3 of 2023.

34 obligations, rights and duties as the principal documents of a unit trust scheme or a company scheme, "principal manager", in relation to a collective investment scheme authorised by the Commission, means the principal manager of that scheme appointed under the principal documents which has delegated the performance of some or all of its functions to the designated manager, “protected cell company” (“PCC”) means a protected cell company within the meaning of the Companies Law, “registrant” means a person or entity which holds a registration under the supervisory or regulatory Laws to carry out business under those Laws, "regulated activity", in regulation 11 means an activity described in section 2 of the Fiduciary Law, when carried on by way of business, "regulated agreement" has the meaning given by section 6 of the LCF Law, "relevant accounting period" means a person’s accounting period completed on or most recently completed prior to the 30 June in the year preceding that for which the relevant annual fee is due or, in the case of a person not yet carrying on any regulated activity, the first accounting period in which he will do so, “relevant document” see Schedule 1, “retail bank” means a licensed institution which deals largely with the general public, “secondary fiduciary licence” means a fiduciary licence granted by the Commission of the category set out in section 4(3) of the Fiduciary Law, “services ancillary to the provision of credit” has the meaning given by section 5 of the LCF Law, “supervisory Laws” has the meaning given by the Enforcement Powers Law, “total assets” means the total assets of the licensed institution in question as reported to the Commission on line E.9 of the institution’s return submitted on form BSL/2 in respect of the quarter ending on the 30 September in the year preceding that in which the relevant fee is payable,

35 “trading cell” means a cell of a protected cell company that is not a dormant cell, “turnover" has the meaning given by regulation 5(3), “virtual asset exchange” has the meaning given by the LCF Rules. 37. Revocations The Financial Services Commission (Fees and Administrative Penalties) Regulations, 2023 are revoked. 38. Citation These Regulations may be cited as the Financial Services Commission (Fees and Administrative Financial Penalties) Regulations, 2024. 39. Commencement These Regulations shall come into force on the 1 January 2025.

36 Regulation 30 SCHEDULE 1 Relevant documents This list sets out the relevant documents which attract a penalty when filed late by the licensee and/or registrant and/or being inaccurate. The licensee or registrant will be informed of the deadline for the submission of the relevant document that must be submitted via the Online Portal. Relevant document Audited accounts of Banking Licensees with institutions incorporated in the Bailiwick The Banking Quarterly BSL/2 Return The Banking Monthly LCR Return Financial statements of a licensed fiduciary which holds a primary or secondary fiduciary licence Annual return of a licensed fiduciary Annual return of a Pension Scheme or Gratuity Scheme Annual Statistical Return of a Pension Scheme or Gratuity Scheme Annual return of licensed insurer Audited annual accounts of licensed insurer Auditors’ report of licensed insurer Actuarial report of licensed insurer The Insurer Half-Yearly Solvency Return The Life Insurer Quarterly Returno Auditor’s management letter or confirmation that no such letter is required to be issued under IMII Law Annual return of licensed insurance manager Annual return of licensed insurance intermediary Annual accounts of licensed insurance manager (audited, where applicable) and auditor’s report Annual accounts of licensed insurance intermediary (audited, where applicable) and auditor’s report Evidence of professional indemnity insurance (where applicable) under IMIIL Holder of PoI licence to carry on controlled investment business - Audited financial statements and compliance return of licensee

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o This only applies to the sections completed by the licensed entity.

37 Investment Designated Administrator Quarterly Return Investment Quarterly Return Annual accounts of licensed investment exchange and auditors’ report Collective investment schemes – Class A - Manager’s annual report Collective investment schemes – Class A - Manager’s half-yearly report Collective investment schemes – Class B - Manager’s annual report Collective investment schemes – Class Q - Manager’s annual report and financial statements Authorised closed-ended investment schemes - Audited annual report and accounts for the scheme Registered collective investment schemes - Audited annual report and accounts for the same The Investment Overseas CIS Annual Return The Quarterly Financial Data Returnp The Financial Crime Risk Return The Financial Crime Risk – Multi-scheme Intermediary Annual Return Financial Flows Returns The Prescribed Business Return

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p Relevant to Investment, Fiduciary and Pensions.

38 Regulation 1 SCHEDULE 2 Fees Payable - Banking Part 1 – Application Fees Application Fees Fee Bank Licence Application £49,015 Part 2 – Annual Fees Annual Fees Fee Total Assets Bandq : Below £500,000,000 £49,015 £500,000,000 to £999,999,999 Total Assets x 0.00007436 Minimum of £49,015 £1,000,000,000 or Greater £74,365 Plus, Additional Fees for: Guernsey subsidiary banks 25% of relevant annual fee (subject to maximum asset band) Retail operations (both subsidiaries and branches) 50% of relevant annual fee (subject to maximum asset band) Additional trading names, where a bank is effectively operating multiple separate businesses under one licence 50% of relevant annual fee (subject to maximum asset band) Branches outside of the Bailiwick £18,590

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q May apply in the event that a licensed institution demonstrates to the Commission before the fee becomes due that its total assets as defined fall within the specified bandings

39 Regulations 2 to 5 SCHEDULE 3r Fees Payable - Insurance Part 1 – Application Fees Part 1A – Insurers (including Mutual, Provident or Friendly Societies, PCCs, ICCs and ICs) Fee International Insurer including PCC or ICC Core: Life Insurer / Reinsurer (Category 1 / 2) £7,435 Commercial Insurer / Reinsurer (Category 3 / 4) £11,145 Captive Insurer / Reinsurer (Category 5) £7,555 Category 6 £7,435 Retail General Insurer (Company) £12,500 Cell of a PCC or ICC: Life Insurer / Reinsurer (Category 1 / 2) £2,425 Commercial Insurer / Reinsurer (Category 3 / 4) £3,645 Captive Insurer / Reinsurer (Category 5) £2,425 Non-Special Purpose Insurer (Category 6) £2,425 Special Purpose Insurer (Category 6) £105 Retail General Insurer (Cell) £9,500 Application for Consent to a Scheme of Transfer of Long-Term Business £6,970 Variation of Activities in respect of which Insurer is licenced £1,505 Domestic Insurer £4,185

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r Explanations on Categories 1 to 6 as well as for retail general insurers are included in the Insurance Business Solvency Rules and Guidance, 2021

40 Mutual, Friendly, or Provident Society £4,185 Part 1B - Insurance Managers Fee Insurance Manager £6,920 Insurance Manager acting only for business underwritten by members of the Society of Lloyd’s £3,805 Part 1C - Application Fees for Insurance Intermediaries Fee Insurance Intermediary (Base Fee) £6,965 Adding additional categories to existing licence General – Personal Lines £245 General – Commercial £485 Long Term – Life £485 Long Term – Regular Premium £735 Long Term – Single Premium (Insurance Element) £2,390 Part 2 – Annual Fees Part 2A – Insurers (including Mutual, Provident or Friendly Societies, PCCs, ICCs and ICs) Fee Active Life Insurer (ICC, PCC and Non-Cellular) (Category 1 / 2) Net Policyholder Liabilities Band: Below £1 £7,435 £1 to £999,999 £9,650 £1,000,000 to £9,999,999 £11,845 £10,000,000 to £99,999,999 £18,430 £100,000,000 to £499,999,999 £29,400 £500,000,000 to £1,999,999,999 £56,930 £2,000,000,000 or Greater £111,615 Life Insurer Closed to New Business (ICC, PCC and Non-Cellular) (Category 1 / 2) Net Policyholder Liabilities Band: Below £1 £7,435 £1 to £9,999,999 £9,635 £10,000,000 to £499,999,999 £13,265 £500,000,000 or Greater £18,430 Non-Life International Insurer: Commercial Insurer / Reinsurer £11,145

41

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s Category 3/4 insurers which have not written any business must pay a fee of £7,060 whilst insurers which have written business must pay a fee of £10,585. t If the Commission has certified that it does not consider the society to be a commercial insurer and has not withdrawn that certification (Category 3 / 4)s Captive Insurer / Reinsurer (Category 5) £7,555 Category 6 £7,435 Retail General Insurers (Company) Gross Written Premium Band £1 to £9,999,999 £12,500 £1,000,000 to £10,000,000 £15,000 more than £10,000,000 £17,500 Domestic Insurer Gross Written Premium Band: Below £12,000 £620 £12,000 to £4,999,999 £4,185 £5,000,000 or Greater £21,350 Mutual, Friendly, or Provident Society: Non-Commercial £620t Commercial £4,185 Cell of a PCC or ICC: Life Insurer / Reinsurer (Category 1 / 2) £2,425 Commercial Insurer / Reinsurer (Category 3 / 4) £3,645 Captive Insurer / Reinsurer (Category 5) £2,425 Non-Special Purpose Insurer (Category 6) £2,425 Special Purpose Insurer (Category 6) £105 Retail General Insurers (Cell) Gross Written Premium Band £1 to £9,999,999 £9,500 £1,000,000 to £10,000,000 £12,000 More than £10,000,00 £15,000 Transformer Cell £105 Dormant Cell £195 Life policy cells £145

42 Part 2B - Insurance Managers Fee Insurance Managers (based on companies under management) Pure £6,565 Commercial £10,995 Society of Lloyd’s £3,805 Part 2C - Insurance Intermediaries Fee Intermediary – Base fee £3,380 Plus intermediary category of Intermediary licence General – Personal Lines £245 General – Commercial £485 Long Term – Life £485 Long Term – Regular Premium £735 Long Term – Single Premium (insurance element) £2,390 Long Term – Single Premium (POI element) £1,480 Plus Intermediary turnover from Licensed Bailiwick Activity £0 - £249,999 £2,390 £250,000 - £499,999 £3,615 £500,000 - £749,999 £4,780 £750,000 - £999,999 £5,985 £1,000,000 - £1,999,999 £7,185 £2,000,000 - £2,999,999 £8,400 £3,000,000+ £9,590

43 Regulations 6 to 10 SCHEDULE 4 Fees Payable - Investment Part 1 – Application Fees Application Fees Fee Open-Ended Collective Investment Schemes: Scheme £4,235 Plus: Additional Fast Track Application Fee £560 New Class of Existing Umbrella/Multi-Class Scheme £960 Plus: Additional Fee for Each Additional Element to Fast Track Funds £560 Closed-Ended Collective Investment Schemes: Authorised Scheme £4,235 Plus: Fast Track Additional Application Fee £560 Registered Scheme £4,790 Investment Exchange Operator £30,000 Other licensees £3,080 Variation/extension of Licence £1,505 “De-QIFing” £3,415 “PIF” conversion £3,415 Registration of Prospectus £560 Form EX Notification £1,470

Part 2 – Annual Fees Annual Fees Fee Open-Ended Collective Investment Schemes: Schemes £4,140 Plus: per class £290

44 Closed-Ended Collective Investment Schemes £4,235 Designated Persons; Brokers; and Licensees with an Authorised Financial Advisoruv – Turnoverw Band: Below £1,500,000 £4,410x From £1,500,000 but below £3,000,000 £6,950 From £3,000,000 but below £6,000,000 £9,365 From £6,000,000 but below £12,000,000 £12,090 £12,000,000 or Greater £15,110 Managers of Overseas Collective Investment Schemes £4,410 Principal Managers of Open-Ended Schemes £2,205 Managers of Closed-Ended Schemes £2,205 Investment Exchange Operators £149,695 Other Licensees £4,410 Designated Territories Scheme (EX) £735

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u Authorised by the licensee in accordance with Rule 2.2 of the Licensees (Conduct of Business) Rules and Guidance 2021 (G.S.I. No 141 of 2021) v The holder of a licence issued under section 4 of the PoI Law which has one or more financial advisers and which also holds a licence issued under the Banking Law, but is not a designated administrator, designated trustee or custodian or broker shall pay an annual fee under the Banking Law in addition to the amount stipulated under other licensees in Schedule 4, part 2 w Where turnover refers to the figure shown in audited financial statements as being gross turnover in the relevant accounting period

45 Regulation 11 SCHEDULE 5 Fees Payable – Fiduciary Part 1 – Application Fees Application Fees Fee Personal Fiduciary Licence £1,355 Primary Fiduciary Licence £3,085 Secondary Fiduciary Licence £750 Discretionary Exemption (Individual) £635 Discretionary Exemption (Company or Partnership) £1,420 Consent to Use a Name £2,410 Part 2 – Annual Fees Annual Fees Fee Personal Fiduciary Licensee £1,405 Primary Fiduciary Licensee – Fiduciary Turnovery Band: £249,999 or Below £6,845 £250,000 to £499,999 £13,680 £500,000 to £999,999 £20,525 £1,000,000 to £1,999,999 £27,355 £2,000,000 to £3,999,999 £34,200 £4,000,000 to £7,999,999 £41,035 £8,000,000 to £15,999,999 £54,715 £16,000,000 or Greater £68,400 Pension Provider Fee: Fixed Fee £620 Fee per Scheme Member £1 Subject to a £7,500 cap

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y As defined in Regulation 11

46 per scheme

47 Regulations 12 to 17 SCHEDULE 6 Fees Payable – LCF Law Part 1 – Application Fees Application Fees Fee Licence Application for: Credit Providers (Home Finance) £6,320 Credit Providers (Consumer Credit) £4,740 Services Ancillary to Credit (Home Finance) £3,160 Services Ancillary to Credit (Consumer Credit with less than £3,000,000 loans brokered in preceding calendar year) £1,055 Services Ancillary to Credit (Consumer Credit with more than £3,000,000 loans brokered in preceding calendar year) £2,105 Financial Firm Businesses £4,740 Platforms £6,320 Virtual Asset Service Providers (Exchanges and Stablecoin Issuers) £100,035 Virtual Asset Service Providers (Non-Exchanges) £26,325 AMC held virtual asset AMC issuer £3,950 Each AMC cell £525 Exemption for a Company or Partnership £1,335 Exemption for an Individual £600 Variation/extension of a Licence £1,415 Part 2 – Annual Fees Annual Fees Fee Credit Providers (Home Finance): Non-Bank with a Below £100,000,000 Lending Book £6,320

48 Non-Bank with a Greater than £100,000,000 Lending Book £9,475 Bank Credit Provider (Home Finance)z 50% of Relevant Fee Above Credit Providers (Consumer Credit): Non-Bank with a Below £10,000,000 Lending Book £4,740 Non-Bank with a Greater than £10,000,000 Lending Book £7,900 Bank Credit Provider (Consumer Credit)aa 50% of Relevant Fee Above Services Ancillary to Credit: Home Finance £3,160 Consumer Credit with less than £3,000,000 loans brokered in preceding year £1,055 Consumer Credit with more than £3,000,000 loans brokered in preceding year £2,105 Financial Firm Businesses £1,580 Platforms £6,320 Virtual Asset Service Providers: Exchanges and Stablecoin Issuers £100,035 Non-Exchanges £26,325 AMC held virtual asset AMC issuer £3,960 Each AMC cell £525

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z May apply where the credit provider licensed under the Banking Law demonstrates to the Commission before the annual fee becomes due that it provides home financing and has a lending book with a value that is equal to, or more than, £100,000,000, the relevant annual fee is £4,500, alternatively where lending book has a value of less than £100,000,000, the relevant annual fee is £3,000. aa May apply where the credit provider licensed under the Banking Law demonstrates to the Commission before the annual fee becomes due that it provides consumer credit and has a lending book with a value that is equal to, or more than, £10,000,000, the relevant annual fee is £3,750, alternatively where lending book has a value of less than £10,000,000, the relevant annual fee is £2,250.

49 SCHEDULE 7 Miscellaneous Application fees Fee Amalgamation and Migration fees £2,950 Application fees Fee Change of Controller fees £2,655 Application fees Fee Application under section 438 and/or 469 of the Companies Law £1,375 Application Fees Fee Consent Request to Incorporate a PCC or ICC not Connected to a Licence Application under a Supervisory Law £560 Application fees Fee Consent for removal of supervised Limited Liability Partnerships from the Register £2,745 Application fees Fee Consent for removal of a supervised limited partnership from the Register of Limited Partnerships £2,950

50 Regulations 30 to 32 SCHEDULE 8 Penalties Late Payment Fee First Month £125 Second Month £250 Third Month £375 Each Subsequent Month £375 Late Filing Fee First Month £125 Second Month £250 Third Month £375 Each Subsequent Month £375 Inaccurate Filing Penalty Error Identified by Licensee/Registrant Error Identified by the Commission On identification of the error and return of the submission for correction by the firm £125 £500 Each subsequent month taken to correct the error £125 £500