RegAlertGuernsey: fintech & payments regulation — 2026-09
RegulatedGuernsey fintech: VASP licensing under Lending Law; FSC supervises; no specific payment licence
Frozen snapshot — the guide as it stood at the end of 2026-09. See the live guide for the current state.
Guernsey regulates crypto and virtual asset activities under the Lending, Credit and Finance Law 2022, enforced by the FSC. Traditional payment services (e-money, transfers) are not explicitly licensed under a dedicated payments act; they may fall under the Lending Law if involving credit, or require a Fiduciary licence if involving client money holding. The jurisdiction is actively modernizing its framework to align with FATF standards.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Payment processing / gateway | Uncertainverify with regulator No dedicated payment licence; may require fiduciary or lending licence | — | — | — |
| E-money & wallet issuance | Uncertainverify with regulator No e-money licence; client money rules may apply via fiduciary licence | — | — | — |
| Domestic money transfer | Uncertainverify with regulator Domestic transfers not explicitly regulated; may fall under general financial services | — | — | — |
| Cross-border remittance | Uncertainverify with regulator Cross-border remittance not explicitly regulated; AML/CFT applies | — | — | — |
| Agent network | Uncertainverify with regulator Agent network not explicitly regulated; depends on underlying activity | — | — | — |
| Open banking / account information | Unregulated No open banking framework or mandate | — | — | — |
| Foreign-exchange services | Uncertainverify with regulator FX not explicitly regulated; may require lending licence if credit involved | — | — | — |
New — what changed recently
- 2023-07-01Lending, Credit and Finance Law 2022 Implementation — Established licensing regime for VASPs and credit providers, replacing previous non-regulated status for crypto activities.[1]
- 2022-09-02Fiduciary Rules and Guidance 2021 Consolidated — Updated regulatory framework for fiduciaries, including stricter client money and governance requirements.[2]
- 2021-10-21Guidance on Company Formation by Fiduciary Licensees — Issued guidance requiring robust AML controls and risk assessments for company formation services.[3]
Market-entry checklist
- 1Determine licence typeAssess if VASP (Lending Law) or Fiduciary licence is required based on activity.
- 2Submit application to FSCPrepare detailed business plan, AML/CFT policies, and fit-and-proper declarations.
- 3Meet capital requirementsEnsure GBP 50,000 minimum capital for VASP licence or appropriate fiduciary capital.
- 4Implement AML/CFT frameworkEstablish robust anti-money laundering and counter-terrorist financing procedures.
- 5Appoint compliance officerDesignate a senior manager responsible for regulatory compliance and reporting.
- 6Register with FSCComplete registration process and pay applicable fees upon approval.