Jersey’s new sustainable finance guidance: the practical impact for regulated firms
On 9 April 2026, the Jersey Financial Services Commission issued new sustainable finance guidance, effective from the same date. The guidance gives Jersey firms a clearer supervisory baseline in two important areas: sustainability risk management and anti-greenwashing.
This is not Jersey suddenly importing a heavy EU-style disclosure regime. The approach is deliberately pragmatic and proportionate. However, firms should not mistake “proportionate” for “optional”. The JFSC expects sustainability-related risks, particularly climate change risks, to be considered within existing governance, risk management and internal control frameworks, rather than treated as a separate ESG exercise on the side.
In practical terms, the guidance turns sustainability from a branding topic into a governance, conduct and evidence topic.
What has changed?
The JFSC guidance supports firms in meeting existing obligations under two core principles.
First, under Principle 3, firms are expected to identify, assess and manage sustainability-related risks, with a particular focus on climate change risk. The JFSC frames this through a single financial materiality lens, consistent with the ISSB approach. In plain English, the question is: could climate or sustainability-related matters affect the firm’s financial position, performance, cash flows, clients, counterparties, products or operations?
Second, under Principle 7, firms must ensure that sustainability-related claims are fair, clear and not misleading. These claims may appear on websites, in marketing materials, investor reports, client reporting, pitch decks, product documents or social media.
This second area is likely to catch more firms than they expect. Many businesses have made sustainability statements over the past few years with good intentions but limited supporting evidence. Under the new guidance, those statements may now create unintended conduct and compliance risk.
The impact on Jersey firms
The immediate impact is that firms need to be able to evidence three things:
- that they have considered whether sustainability and climate risks are financially material to their business;
- that the conclusion has been documented and escalated to the board or equivalent governing body; and
- that any sustainability-related claims they make can be supported by robust evidence.
The guidance is not asking every firm to produce a 100-page sustainability report. For lower-risk firms, a qualitative desktop assessment every three years may be sufficient, provided the judgement is properly documented and kept under review. For more complex firms, or firms with material exposure, deeper analysis, clearer metrics, board reporting and more active monitoring may be required.
The JFSC has not created a requirement for new risk architecture from scratch. However, firms still need to assess risks, document their assessment and escalate conclusions to the board. The anti-greenwashing element also requires governance over how sustainability-related claims are formed, reviewed, approved, updated and, where necessary, withdrawn.
There is one important timing point. The JFSC guidance notes that enhancements to Principle 7 are expected to apply from Q1 2027 across firms governed by the Codes of Practice. These enhancements will make explicit that sustainability-related claims regarding the registered person, its products or services must be backed by robust evidence and must not be unclear, misleading or unfair.
The practical message is simple: firms should not wait until 2027. The guidance is already live, and the work required to review claims, evidence judgements and strengthen controls is unlikely to be completed overnight.
How firms can respond, A sensible implementation plan does not need to be complicated.
Start with the existing risk framework. Do not create a parallel ESG risk register.
Firms should identify climate-related physical and transition risks and map them into existing categories such as operational risk, strategic risk, financial risk, reputational risk, market risk, credit risk or conduct risk.
The output should be a short, board-ready assessment covering:
- the scope of the review;
- the risks considered;
- the methodology used;
- the materiality judgement;
- the conclusion reached; and
- any further actions required.
The JFSC expects board or equivalent oversight. That does not mean the board needs to become climate scientists. It does mean the board should understand the assessment, challenge the conclusion and approve the proposed response.
If the conclusion is that sustainability risk is not material, document that decision and the basis for it. If the conclusion is that it is material, agree proportionate controls, monitoring and reporting.
This is the single best practical step most firms can take now.
List every sustainability-related claim currently being made across:
- the website;
- brochures;
- pitch books;
- fund documents;
- investor or client reports;
- policies;
- proposals;
- social media; and
- recruitment materials.
Then ask one question for each claim: Can we evidence this today?
If the answer is no, the claim should be rewritten, supported or removed.
For each claim, keep a simple evidence record. It should explain what the claim means, who approved it, what data supports it, what limitations apply and when it will be reviewed.
This is where many firms will be exposed. The claim itself may appear harmless. The lack of evidence behind it is the problem.
Sustainability claims should not be approved casually by marketing or business development alone. The process should involve compliance, risk, product, legal or senior management where relevant.
The best control is simple: no new sustainability-related claim should go live unless someone has checked whether it is accurate, balanced and evidenced.
Looking for a quick win?
Run a two-hour greenwashing desktop review.
Take your website homepage, sustainability page, pitch deck and most-used proposal template. Highlight every sentence that refers to sustainability, ESG, green credentials, impact, responsible investment, net zero, social value or climate.
For each statement, mark it as:
- Green — evidenced and clear;
- Amber — probably supportable, but needs better wording or evidence; or
- Red — vague, overstated or not currently evidenced.
That one exercise will give management a fast view of the firm’s exposure. It is not the full answer, but it is the quickest way to stop the obvious own goals.
How we can help
Baker Tilly Channel Islands can support Jersey firms through targeted, practical advisory work, including:
Support area | Practical output |
Sustainability risk assessment | Board-ready materiality assessment and risk register wording |
Anti-greenwashing review | Claims inventory, RAG rating and remediation recommendations |
Evidence file creation | Evidence templates for key sustainability claims |
Board reporting | Short board paper setting out compliance position and next steps |
Policy and control design | Lightweight claims approval and review process |
Training | Practical session for directors, compliance, marketing and client-facing teams |
Need a quick sense-check?
We can run a focused sustainability risk and anti-greenwashing review to help you identify your current exposure, document your materiality assessment and create a practical action plan aligned to the JFSC guidance.
Source: JFSC sustainable finance guidance issued 9 April 2026.
