Sustainable Finance Lunch and Learn: Understanding the JFSC’s New Sustainable Finance Guidance

Yesterday we hosted a Sustainable Finance lunch and learn with the Jersey Financial Services Commission (JFSC), exploring their new Sustainable Finance Guidance Note and the practical implications for regulated firms.

The session was led by Tom McKenna, our Sustainable Finance Lead, who was joined by Daniella Gingell and Matthew Clegg from the JFSC. Together, they outlined the background to the guidance, the JFSC’s policy direction following industry consultation and the steps firms should consider ahead of implementation.

The webinar followed the publication of the JFSC’s Sustainable Finance Guidance Note in April, which provides clarity on regulatory expectations for managing sustainability-related risks and making sustainability-related claims under the Codes of Practice. Firms have been given a 12-month transition period to familiarise themselves with the requirements and prepare for implementation. The guidance and Principle 7 Code changes are due to take effect in Q1 2027.

The lunch and learn session was an opportunity for firms to understand the scope, intent and practical implications of the new guidance, including its interaction with changes to Principle 7 of the Codes of Practice.

The key takeaways from the session were:

1. There are no changes to the Codes for sustainability risk, with a guidance-led approach adopted in respect to Principle 3 – integrating into existing risk management frameworks
2. Climate risk is the primary focus and firms should assess materiality on a single materiality basis
3. The guidance helps firms integrate sustainability risk into what they already do
4. Anti-greenwashing provisions will be upgraded through a Code enhancement from Q1 2027
5. Practical guidance on how firms can ensure claims about the firm, its products and services meet this standard

Daniella and Matthew explained that, following the JFSC’s consultation in May 2025, industry broadly supported a guidance-led approach to sustainability risk rather than new Code requirements. The view from industry was that existing Codes already provide a sufficient foundation for risk management, with the guidance helping firms apply these existing obligations to sustainability-related risks.

The JFSC’s approach is centred on Principle 3, integrating sustainability risk into firms’ existing risk management frameworks rather than introducing a new governance framework. Climate risk is the primary focus, reflecting the growing international expectation that firms consider climate-related financial risks as part of their broader risk management processes.

The guidance is designed to be proportionate and pragmatic. Firms are expected to assess materiality for themselves and, where sustainability-related risks are not material, no further action is required beyond periodic review. Where risks are more material, firms may choose to go further by using recognised standards such as those issued by the International Sustainability Standards Board.

Strengthening anti-greenwashing expectations

The session explored the JFSC’s approach to anti-greenwashing, which will be supported by an enhancement to Principle 7 of the Codes of Practice.

From Q1 2027, Principle 7 will require sustainability-related claims to be backed by robust evidence and to be fair, clear and not misleading. This builds on existing disclosure requirements for Certified Funds, Fund Services Businesses, Jersey Private Funds and Investment Businesses, while widening the focus to sustainability-related claims made about firms, products and services.

Daniella and Matthew explained that the Code change is intended to align Jersey with international norms and to provide a clearer, more complete framework for sustainability claims. This reflects feedback from the consultation, where there was strong support for enhancing Principle 7 in line with international standards.

This development reinforces Jersey’s position as a well-regulated, internationally recognised finance centre and supports the continued evolution of sustainable finance across the Island.

View the presentation slides.