The Price of the Default: Cayman, Bermuda, Ireland, Jersey & Guernsey
Custodia Advisory | Private Equity | Fund Jurisdiction Comparison
Cayman's 2026 fee reset, and what it actually means against Bermuda, Ireland, Jersey and Guernsey
Cayman is still the default. Nothing in the numbers below changes that — the jurisdiction was recently cleared from the EU's AML list, fund registrations remain at record highs, and no competing domicile comes close to matching its bench of administrators, auditors and fiduciary providers. Clients ask us about alternatives not because Cayman is failing, but because the cost of staying has quietly moved, and most platforms haven't recalculated since it did.
What actually changed. Effective 1 January 2026, CIMA consolidated its fund fee structure and raised most of it at the same time. The annual fee for registered funds rose from CI$3,675 to CI$4,125; for master funds, from CI$2,625 to CI$3,075. The old mid-year Fund Annual Return fee — previously CI$300 — was folded into the annual payment and increased to CI$450 for mutual funds and CI$525 for private-fund sub-funds and alternative investment vehicles, an increase of roughly a quarter on the prior charge. A new CI$100 annual fee now applies to every exempted limited partnership's registered office — a CIMA fee, not a charge set by the registered office provider itself, though it typically arrives on the provider's invoice as a pass-through rather than as a separate bill from CIMA. None of these figures is dramatic in isolation. Stacked across a multi-fund, multi-AIV platform, and layered onto the separate rise in administrator and audit costs that the Private Funds Act's operational requirements have driven since 2020, the direction of travel is unmistakable: Cayman is getting more expensive to run properly, not less.
Why this narrows the gap rather than closes it. The traditional pitch for Ireland, Jersey or Guernsey has always conceded a cost premium in exchange for something Cayman doesn't offer — an EU passport in Ireland's case, or a regulatory badge some LPs find reassuring in the Channel Islands' case. That premium was easier to justify when Cayman was meaningfully cheaper. It's a harder sell now that the gap has narrowed from Cayman's side rather than the alternatives becoming pricier.
Jersey and Guernsey are the clearest beneficiaries of that shift. Both jurisdictions run fast, proportionate regimes for closed-ended, institutional-investor-only funds — the Jersey Private Fund and the Guernsey Private Investment Fund — that were built specifically to compete with Cayman's speed and simplicity for exactly this kind of platform. Neither carries an EU passport, so the case for either still rests on relationship, precedent and a UK-facing investor base rather than access. But the cost argument that used to sit against them has softened considerably.
Ireland is a different calculation, and the 2026 fee reset doesn't really touch it. An ICAV still requires an authorised AIFM and a depositary — fixed governance costs that exist regardless of what CIMA charges in Grand Cayman. Ireland remains the right answer when EU distribution is an actual mandate, not a hedge against sentiment, and that hasn't changed this year. What has changed is that "Ireland costs more, but Cayman is cheap" is a weaker argument than it was twelve months ago.
Bermuda sits outside this comparison in practice. The BMA hasn't run a comparable fee reset, and Bermuda's real strength remains insurance-linked and reinsurance-adjacent strategies rather than general private equity, where its service bench is thinner than Cayman's. For a standard PE feeder with no insurance nexus, Bermuda rarely wins on cost or depth against any of the other four.
The fiduciary layer moves more than the regulatory one. Regulatory fee resets get noticed because they arrive as a single, publicised announcement. Fiduciary fee drift rarely does — it happens quietly, service line by service line, inside a consolidated invoice most platforms never break apart to check. And the two models we see in the market behave very differently over the life of a structure.
Some fiduciary providers price on an escalating basis: the entry fee is competitive, but director, registered office, AML/KYC and administration charges step up incrementally, year over year, often justified as inflation, added regulatory burden, or "repricing to reflect the current scope of work." Taken individually, each increase looks defensible. Compounded over a five- or ten-year fund life across a multi-entity platform, the cumulative effect can dwarf whatever was saved by choosing that provider in the first place — and it lands hardest on exactly the long-dated, closed-ended structures this comparison is about.
Not every line on that invoice is the provider's own decision, and it's worth telling the two apart before assuming a bill increase reflects provider behaviour. The new CI$100 ELP registered-office charge described above, for instance, is a CIMA fee that a provider is simply passing through — it will appear on the invoice, but renegotiating it with the provider achieves nothing, because the provider isn't setting it. Genuine fee escalation is the portion a provider chooses to increase on its own schedule; regulatory pass-throughs are a budgeting line, not a negotiating one. A platform reviewing its rising fiduciary costs should separate the two before deciding where to push back.
Other providers, typically the smaller and independent ones without a law firm or bank parent to satisfy on margin, hold a standard fee for the lifetime of the structure, agreed at appointment and unchanged regardless of how the relationship ages. This is the preferable model, for reasons that go beyond the fee itself: a fixed fee is forecastable, which matters for investor return modelling and platform budgeting in a way that a variable one doesn't; it removes the incentive for a provider to treat the relationship as a repricing exercise once the structure is embedded and switching costs are high; and it's a reasonable proxy for how a provider expects the relationship to be judged — on service, not on what they can extract once you're locked in.
The practical test isn't which model a provider says it uses. It's what the engagement letter actually commits to, and whether that commitment survives a renewal, a change of scope, or a change of ownership at the provider. That's a fee-schedule and OCG question as much as a jurisdiction one, and it's worth checking before a platform is several years into a structure and the increases have already compounded.
The point most platforms miss. None of this is really an argument for moving. It's an argument for recalculating before assuming the old cost hierarchy still holds — and, more importantly, for recognising that CIMA's fee line is the smallest part of what actually drives spend on a Cayman platform. Administrator, audit, legal and director fees dwarf the regulatory fee increase many times over, and those are the costs that respond to how well a platform's Outside Counsel Guidelines are enforced, not to what CIMA charges. A jurisdiction comparison exercise is worth doing. It's rarely the highest-leverage one available to a platform that hasn't reviewed its OCG or re-tendered its fiduciary panel in several years.
We put together a fuller comparative primer on Cayman, Bermuda, Ireland, Jersey and Guernsey for a client asking exactly this question recently — vehicle types, regulators, tax treatment and market access side by side. Happy to share it, or to walk through how the fee reset specifically affects your platform's numbers.