Feedback Statement on Financial Services (Miscellaneous Provisions) Bill 2026

• Home
• FSA News
• 2026
• Apr
• Authority publishes consultation Feedback Statement

Authority publishes consultation Feedback Statement

Published on: 14 April 2026

The Isle of Man Financial Services Authority has published a Feedback Statement in response to the public consultation on the Financial Services (Miscellaneous Provisions) Bill 2026.

The Bill is intended to enhance the Isle of Man’s regulatory and oversight frameworks, reflect updated international standards, and safeguard the Island’s reputation as a well-regulated jurisdiction for financial services.

After considering a range of detailed submissions and recognising the need to meet a challenging legislative timeframe, the Authority has proposed several changes to the Bill, including removing or deferring certain measures and narrowing the scope of others.

The Authority worked with HM Attorney General’s Chambers to revise the Bill for introduction into the branches of Tynwald on 31 March 2026 and is hopeful that the published Feedback Statement provides a comprehensive explanation of the post-consultation changes.

The consultation generated a significant level of engagement from a cross-section of the Island’s financial services sector. Feedback was received on most provisions, including the proposal for a broad enabling power to implement a civil penalty regime for individuals.

On the topic of civil penalties:

• While some respondents welcomed efforts to align with international standards by introducing an additional option within the Authority’s regulatory toolkit that is already used in many peer jurisdictions, concerns were raised regarding the scope and proportionality of the proposed new sanction, as well as the potential impacts on the Island’s competitiveness. Respondents sought additional clarity on how civil penalties for individuals would operate in practice.
• After carefully assessing the submissions, the Authority has revised the civil penalty provisions using the feedback received and the existing penalty power for individuals in section 37 of the Insurance Act 2008. The revised civil penalty provisions may only be applied to:
  • Regulated entities or designated businesses for contraventions of relevant legislation and associated requirements (as is currently the case).
  • Individuals in controlled function roles (or equivalent) with regulated firms or designated businesses (e.g. controllers, directors and key persons).
  • Persons in breach of the general prohibitions on carrying on regulated activity or designated business without the relevant licence, authorisation or registration.
• Such individuals would only be in-scope of the revised civil penalty power where a contravention was committed or caused:
  • to a significant and material extent; and
  • by or with the consent or connivance of, or was attributable to the neglect of, the individual.
• In addition:
  • New powers would only apply prospectively and be subject to a six-year time limit.
  • Where a contravention is also a criminal offence, civil penalties could only be used as an alternative to prosecution and persons subject to such a penalty would receive immunity from prosecution for the same offence.
• Secondary legislation detailing how the civil penalties regime would operate in practice will be required before any new powers can be enforced. This will be informed by a further consultation later in 2026 and will be subject to Tynwald approval.

In terms of other topics, the Authority has removed some provisions from the Bill and deferred others for future consideration, including the proposed extension of warning notice powers. Similarly, proposed changes to guidance provisions and appeal rights to the Financial Services Tribunal for some directions have been removed from the Bill in response to feedback from stakeholders.

Chief Executive Officer Bettina Roth said: ‘The Authority is grateful to all respondents for their valuable contributions to our consultation and remains committed to maintaining a robust, fair and internationally respected regulatory framework for the Isle of Man’s financial services sector. Our direction of travel is informed by constructive industry feedback, and we always listen to what the sector is telling us.’

She added: ‘After careful analysis of the consultation responses, we have decided to remove some proposals and defer consideration of others. The changes to the civil penalties for individuals reflect our commitment to addressing the concerns raised by respondents while still progressing a regime that meets updated international requirements.’

The published Feedback Statement sets out the overarching themes of the consultation submissions, the Authority’s responses, a summary of post-consultation changes, and next steps.