New Online Services Portal
New Portal Background and Transition Date
As you may be aware the Guernsey Registry is upgrading its IT systems as the existing IT system is aging and in need of replacement to ensure that it continues to meet the needs of both the Guernsey Registry users, but also meets modern AML and CFT requirements. The changes that have been made to the system include enhanced functionality for users, and greater reporting and analysis capability for the Registry.The inclusion of modern security features also ensures the ongoing accuracy and security of the data that the Registry holds.
The new system will be available on the 4th December.
The cut off for filings made in the existing system prior to that weekend will be 17:00 on Friday 1st December. Unfortunately, any submissions that are in draft or that have been returned cannot be migrated to the new system and users will need to submit new filings in the new system.
The above-mentioned change to go-live dates does however mean that annual validations will not be available on the 1st December, but will now be available to draft from the 4th December when the system is online. These will not be pre-populated but we have made a list of the questions available to assist you in preparing for the filings Company annual validation form - questions and options list (Jan 2024) [514kb]. The deadline for annual validations will remain the 29th February 2024.
There are some changes that have been made to accessing the new portal, which have been designed to increase the security of the registers. Most users will be able to use their existing username to log in to the new portal but will be required to reset their passwords and set up multi-factor authentication. We understand that this may be confusing for some users and full guidance on how to do this is in this document: New Guernsey Registry online Services Portal [5Mb]
We are also aware that some users will have more than one login as a result of already having a charity account in the portal. These users will be contacted directly to deconflict their logins and usernames.
Other key changes
The introduction of the new solution coincides with a number of improvements in the way the Registry gathers data to support the Island's anti money laundering and counter terrorism funding efforts.
One of our historic weaknesses in this area has been the use of the Entity PIN as a means of identifying users that are authorised to submit filings on a company's behalf. These PINs will now be replaced by a one-off exercise to submit an authorised filer declaration which ensures only those individuals expressly permitted to act on behalf the company may do so.
We recognise that this is a significant change that will impact many of the Registry's users but hope you'll agree that it is a significantly more secure means of identification given the previous solution's weaknesses in terms of PIN loss / theft or inappropriate sharing.
This requirement does not apply to corporate service providers or regulated presenters who will be automatically authorised as regulated users of the service.
The introduction of this change means that users will not be able to submit filings, or the Annual Validation, without first becoming an authorised filer. It is therefore recommended that this process is carried out as soon as possible once the new system is available from the 4th December 2023 and by the 12th January 2024 at the latest. Full guidance on what is required to become an authorised filer is in this document Authorised Filer Guidance [3Mb] and the template declaration is available here Authorised Filer Declaration [99kb]: You will not be able to file these in the existing system, but will be able to file these in the new system from the 4th December 2023.
The new solution will also change the way in which non-corporate service provider resident agents will be authorised to make filings, specifically and solely those filings related to beneficial ownership. Agents will be required to file a nominated persons form, which will include uploading proof of address and certified proof of ID before any changes to beneficial ownership information can be submitted. Guidance is available here: Nominated Person Guidance [2Mb] .
We have contacted corporate service providers directly to discuss who within their organisation requires authorising to file beneficial ownership filings as the resident agent, as this will require specific permissions setting for those users in the new system.
We understand that the transition to the new portal with the new login process, authorised filing and nominated persons filing is taking place at a time when users are also preparing for the end of the year, and that the impact may still be felt during the annual validation period. We are keen to help manage the impacts of these changes and are offering training on the new portal until the end of February 2023. Individuals can register their interest to attend these sessions here: https://forms.office.com/e/fCg1KcKUL2
This is the first step in transitioning the full registry services to the new portal, there will be additional changes that will be made in the coming months to improve the portal and we will continue to work with you to ensure that the impacts of these are understood and managed appropriately. We are keen to receive your feedback about the portal, its functionality and any concerns you may have so that we can continue to improve the services that we provide. Details as to how that feedback can be provided will be included in communications made when the system goes live.
We appreciate that moving to a new system will be challenging but hope that we can work with users to ensure this process is as smooth as possible, to ensure that the new system works for our users, and to ensure that Guernsey continues to be a jurisdiction of choice for businesses both now and in the future.