Private Investment Fund - PIF
There are two routes to establishing a PIF: the Qualifying PIF and the Family PIF. This summary sets out the key features of the framework under the Private Investment Fund Rules and Guidance, 2025 (PIF Rules).
The Guernsey private investment fund (PIF) is a popular choice for fund promoters targeting a broad range of sophisticated investors, as well as high-net-worth families seeking a regulated structure. The PIF offers a streamlined regulatory framework, including a fast-track, one business day registration process, and flexibility in fund structuring. These features make it particularly attractive for those seeking speed-to-market and a lighter touch regime while maintaining proportionate regulatory oversight.
Introduction
The PIF regime was introduced in 2016 and updated in 2021 and again in 2025, to simplify fund establishment and enhance flexibility. The latest rules place greater emphasis on the suitability of investors, removing previous limitations on the number of investors and offers.
Previously, there were three routes to establishing a PIF:
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Route 1: Licensed Manager PIF
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Route 2: Qualifying Private Investor PIF
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Route 3: Family Relationship PIF
Under the 2025 regime:
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Routes 1 and 2 have been consolidated into a single Qualifying PIF (QPIF)
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Route 3 has been retained as a distinct option, now known as the Family PIF
Summary of Qualifying Private Investor PIF - 'QPIF'
A QPIF is designed for investors who meet specific eligibility criteria, as defined in the PIF Rules, referred to as 'Qualifying Private Investors' (QPIs). In addition to Professional Investors, Experienced Investors and Knowledgeable Employees (previously eligible under Route 2), the QPIF regime has been extended to include High-Net-Worth Investors, UK/EU Professional Clients, US Accredited Investors, and Licensee Admitted Investors (being those investors assessed by a Guernsey-licensed manager or administrator as capable of understanding the risks and strategy of the QPIF and bearing the consequences of investment, including total loss).
QPIs must acknowledge their investor status and understanding of the associated risks. The designated administrator must also confirm to the Guernsey Financial Services Commission (GFSC) that effective procedures are in place to ensure the QPIF is restricted to eligible investors.
Family PIF
A Family PIF is intended exclusively for investors with a family relationship, or for 'eligible employees', i.e. individuals working within the family structure who also meet the criteria of a QPI.
Whilst all PIFs must appoint a designated administrator licensed under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 (POI Law), a primary fiduciary licensee may apply for a 'limited POI licence' to act as designated administrator of a Family PIF, provided that they do not intend to carry out any other POI-related activities. While such administrators must still comply with the POI Law in the same manner as full POI licensees, many of the associated regulatory requirements are modified or waived to reflect the restricted nature of their activities under the limited licence (and consequently also benefit from a lower annual fee).
Marketing outside the family group is strictly prohibited, and the designated administrator must confirm to the GFSC that robust procedures are in place to ensure the fund remains restricted to family-only investors.
Key features of a PIF
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Flexible structure: a PIF may be structured as a company, unit trust, limited partnership, protected cell company or incorporated cell company
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Designated administrator: all PIFs must appoint a designated administrator licensed under the POI Law. The designated administrator is responsible for ensuring compliance with the PIF Rules and confirming investor eligibility
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Number of investors and offers: there is no limit on the number of investors or offers, and offers must be made on a private basis and not to the general public
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Minimum subscription: there is no minimum investment level
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Manager: there is no requirement to appoint a Guernsey-licensed manager, although one may be appointed voluntarily if desired (such manager potentially benefitting from a light- touch regulation 'PIF-only' investment management licence and audit waiver). If appointed, cell companies must have a single manager across all cells
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Audit: appointment of an auditor is optional. If appointed, the auditor must operate from a place of business in Guernsey
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Other service providers: there is no requirement for a custodian or trustee, however any Guernsey-based entity acting in such capacity must be licensed under the POI Law
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Offer document: there is no requirement to produce an offer document, although one may be provided at the promoter's discretion
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Fast-track registration: PIFs (and corresponding 'PIF-only' Guernsey managers) benefit from the one business day fast-track registration process offered by the GFSC, enabling rapid time-to-market for fund promoters
Checklist for establishing a PIF in Guernsey
All funds applying for registration with the GFSC as a PIF must meet the requirements set out in the PIF Rules.
The manager (if any) or the designated administrator must submit the appropriate application form, the requisite declaration, supporting documentation, payment of the application fee, and any other information or documentation required by the GFSC.
QPIs must also acknowledge their investor status and confirm their understanding of the associated risks.
Conclusion
The PIF regime offers a compelling solution for fund promoters and sophisticated investors seeking a streamlined, efficient, and flexible investment vehicle. With its fast-track one-day registration process, absence of mandatory offer document or custodian requirements, and broad choice of legal structures, the PIF framework is designed to facilitate speed-to-market without compromising regulatory integrity. Its focus on investor suitability rather than numerical limits, combined with proportionate ongoing compliance obligations, makes it particularly attractive for bespoke investment strategies, family offices, as well as a variety of fund managers, from first-time venture capital managers to institutional grade private equity managers. These features collectively reinforce Guernsey's position as a leading jurisdiction for innovative and well-regulated private investment funds.