Gemma Palmer
Partner, Walkers (CI) LP
Jersey
On 22 January 2026, the States Assembly adopted the Cyber Security (Jersey) Law (the Law), marking a significant step in formalising Jersey’s cyber resilience framework. The Law received Privy Council approval on 3 June 2026 and, once in force, will introduce mandatory cyber security obligations for certain organisations operating in the Island.
In particular, the Law establishes the statutory role of the Jersey Cyber Security Centre (JCSC) as both an advisory body and an incident response authority, while introducing a regulatory framework for operators of essential services (OES), broadly aligned with equivalent regimes in the UK and EU.
This briefing outlines the key features of the Law and its practical implications.
The Law applies to entities designated as OES. An “essential service” is defined by reference to Schedule 3 of the Law and includes certain financial services activities.
Within the financial services sector, those undertaking deposit-taking business requiring registration under Part 2 of the Banking Business (Jersey) Law 1991 (BBJL) will be designated as an OES.
Importantly, there is no additional threshold test. Where an entity is registered with the Jersey Financial Services Commission under the BBJL, it will automatically fall within scope as an OES.
As a result, all registered banks operating in or from within Jersey will be subject to the new regime.
The Law introduces a series of ongoing obligations for OES, focused on cyber risk management, incident reporting and regulatory oversight.
OES must notify the Minister that they are in scope of the regime, including providing key contact details. This obligation arises once the relevant provisions of the Law come into force.
OES are required to take appropriate and proportionate measures to manage cyber risk across systems supporting their essential services. This includes ensuring the ability to:
These measures must achieve a level of security of network and information systems commensurate with the risks faced.
In practice, this concept extends to maintaining the confidentiality, integrity, availability, authenticity and non-repudiation of systems and data.
Guidance on the application of these requirements is expected to be issued by the Director of the JCSC.
The Minister is empowered to direct an OES to implement specific cyber security measures where considered appropriate and proportionate.
Any such direction will follow consultation with the JCSC and relevant regulators. Importantly, these directions supplement rather than replace the underlying obligation to maintain appropriate cyber security controls.
OES must notify the Director of the JCSC of any cyber incident that has had, or is likely to have, a significant impact on:
In determining whether an incident is significant, OES must take into account factors such as the number of users affected, duration and geographical scope.
Notifications must be made as soon as reasonably practicable and, in any event, within 24 hours of the OES becoming aware of the incident. Reports must include key details relating to the nature, timing and impact of the incident, including any cross-border effects.
Following a significant incident, the Minister may direct an OES to take specific remedial or mitigating measures. Any such direction must be proportionate and targeted at preventing or addressing the impact on essential services.
Non-compliance with the Law may result in:
For many EU or UK-headquartered banks, the core principles underpinning the Law will be familiar.
Existing EU or UK regulatory frameworks already require firms to identify critical services, test resilience and embed governance around operational disruption. As a result, many institutions will already have a strong baseline in place.
However, the Jersey regime introduces some additional considerations:
Banks will therefore need to ensure that their existing cyber resilience frameworks can be clearly mapped against the statutory requirements of the Law and adapted where necessary to reflect local regulatory expectations.
Although the Law is not yet in force, in-scope entities should begin preparing now. In particular, firms may wish to:
Authors
Partner, Walkers (CI) LP/Jersey
Senior Associate/Jersey
Key contacts
Partner, Walkers (CI) LP
Jersey
Partner, Walkers (CI) LP
Jersey
Senior Associate
Jersey