Commission allows more time for Firms to complete Key Financial Returns

24th March 2020

Amending the Timing of Financial Return filings with the Commission

The Commission is conscious that almost all firms will be experiencing certain operational issues as they transition to an environment in which many of their staff will be working from home.  Mindful of this and of some significant impending deadlines for financial returns, it is making the following changes to its expectations:-

  • Returns to the Commission which would ordinarily require auditing (e.g. because they relate to a year end result) may be submitted in an unaudited form without a special concession being sought from the Commission.  This modifies the position we took in our media statement of 16th March – something we are prepared to do as the ability of people to work normally becomes increasingly impeded by the public health guidance necessary to constrain the spread of Covid-19.  As things stand, we will expect audited versions of the financial returns to be submitted by end October 2020 but we may delay this target date for the submission of audited financial information further as we see how Public Health advice evolves.  It will not be earlier than the end of October in any event.
  • Those financial returns for insurers, insurance intermediaries and managers, investment firms, funds and fiduciaries which would require submission by the end of April 2020, may be submitted at any point before the end of May 2020 in unaudited form.  Similarly, the deadline for submission of unaudited returns for other firms with a non-calendar financial year, is extended by 1 month.[1]

Any firm which knows that it will not be able to make the revised filing deadlines should write to the Commission to explain what issues it is experiencing, how it is remediating those issues and when it expects to be able to file.  Investment and fiduciary firms should write to [email protected] and insurance and banking firms should write to [email protected].

For the avoidance of doubt the postponement of the auditing requirement above and, unless specifically advised to the contrary, the extension of the returns deadline applies to the following returns:-

  • 123      - Fiduciary – Audited Financial Statements and Statistical Return;
  • 124      - Fiduciary – Annual Return – Full Fiduciary;
  • 125      - Fiduciary – Annual Return – Personal Fiduciary;
  • 126      - Fiduciary Pension Scheme or Gratuity Scheme – Quarterly Return;
  • 127      - Fiduciary – Pension Scheme or Gratuity Scheme – Annual Return;
  • 131      - Insurance Intermediary Annual Return;
  • 132      - Insurance Manager Annual Return;
  • 133      - Insurer Annual Return;
  • 135      - Non-Locally Incorporated Domestic Insurer Annual Return
  • 136      - Insurer Half Yearly Return;
  • 141      - Investment Designated Manager Quarterly Return;
  • 142      - Investment Audited Financial Statements and Compliance Returns      (Licensee);
  • 143      - Investment Audited Financial Statements (Funds);
  • 144      - Investment Half-Yearly financial statements Class A Funds; and
  • 145      - Investment Quarterly Return.

Whilst the Commission is making the above changes to returns filing in response to Covid-19, we will be making specific requests to some firms for enhanced financial information to help it better understand the ongoing health of the financial services economy.  When we makes these requests, we will expect them to be accorded priority and dealt with in a timely manner.

Simplified Procedure for filing of PQs for Alternate Directors

We have had representations that during the Covid-19 pandemic, firms may need to make more use of alternate directors for some key meetings.  The Commission understands that this may require the appointment of alternate directors to licensees at short notice.  Where this occurs the proposed alternate directors should still submit Online Appointments as normal and  they or their service providers should also email [email protected] advising of the submission of the Online Appointment.  Where the proposed alternate director is already known to us as a director of the licensee’s Designated Administrator or Insurance Manager we will expedite our approval process in order to endeavour to meet your deadline to allow that alternate director to act.

For those directors of an insurance licensee licensed under The Insurance Business (Bailiwick of Guernsey) Law, 2002 (“IBIL”), we would refer you to the FAQ 10. Prescribed Positions Q2 that appears on the PQ Portal area of the Commission’s website which we believe you may find helpful. FAQ [2]

Notification of Changes to Business Plans

For the avoidance of doubt we do not require firms to notify us of a change to their business plans because they are markedly increasing home working to comply with Public Health guidance.  That said if a firm is experiencing difficulty in being able to comply with its business plan or other regulatory requirements because of difficulties associated with working from home, we expect it to contact us to explain the nature of the difficulties and its thoughts on managing them at the earliest practical opportunity.

Extension of Notification Timings for Special Purpose Insurer Cells

The deadline for notifying the Commission of the formation of these cells is currently seven days.  This is extended to fourteen days until the end of October 2020.

Extension of Response Times Relating to Commission Correspondence

The Commission is making the following changes to certain specific response times generally required in relation to Commission correspondence:-

  • Firms will have twenty rather than ten days to review and respond to draft Commission post visit letters which frequently set Risk Mitigation Programme actions.
  • Firms will have an additional six months to comply with new RMP actions relative to that which the Commission would ordinarily accord firms.  E.g. An RMP action set for a firm with a deadline of end May 2020 will generally be extended by the Commission so that the deadline becomes the of end November 2020.  Firms will see this change implemented in new post visit letters issued to firms – it does not elongate the deadlines set out in those letters[3].


  • Current RMP deadlines remain unaltered.  If firms anticipate difficulty meeting them they should write to the Commission explaining why they have difficulties and what deadline they could make.  Any such requests for extensions will be considered on their individual merits.

[1] So, for example, a firm with a year-end of 31st January would not be required to file the financial return before the end of June, rather than the usual requirement to file by the end of May.

[3] The Commission reserves the right to set shorter RMP and other deadlines at its sole discretion.