S House of Commons m§ Library
Research Briefing
By David Torrance
12 September 2025
The Crown Dependencies
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Summary
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What are Crown Dependencies?
UK Government relations with the Crown Dependencies Extension of UK legislation to the Crown Dependencies Crown Dependencies and international treaties
Useful websites and further reading


commonslibrary.parliament.uk
Number CBP8611
Image Credits
Crown Dependencies by Rixie. Adobe Stock # 488189021
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The Crown Dependencies
Contents
Summary	5
1	What are Crown Dependencies?	6
1.1	Constitutional status	6
1.2	Historical background	7
The Channel Islands	7
Isle of Man	8
1.3	Governance	8
The Channel Islands	8
Isle of Man	9
Tynwald Day	9
1.4	Legislative process	10
1.5	Nationality	11
1.6	The Crown	12
1.7	Judicial systems	13
2	UK Government relations with the Crown Dependencies	14
2.1	Intergovernmental relations	16
British-Irish Council	16
Contact between UK and Crown Dependency officials	17
Judicial Committee of the Privy Council	17
2.2	Financial relations	17
Revenue sharing arrangement	18
2.3	Disputes	19
Relations since 2010	20
3	Extension of UK legislation to the Crown Dependencies	22
3.1	Constitutional convention	22
3.2	Fisheries Act 2020	23
3.3	The Crown Dependencies and “good government”	25
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3.4	Beneficial ownership registers	26
3.5	Response in the Crown Dependencies	28
3.6	Proposals for reform	28
4	Crown Dependencies and external relations	29
The 1950 declaration	29
4.1	Process for extension of international treaties	29
4.2	Brexit and the Crown Dependencies	30
4.3	Letters of Entrustment	32
4.4	International representation	32
4.5	Overseas offices	34
5	Useful websites and further reading	35
Publications	35
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The Crown Dependencies
Summary
The Crown Dependencies are Jersey, Guernsey and the Isle of Man.
The Crown Dependencies are not part of the UK but are self-governing dependencies of the Crown. This means they have their own directly elected legislative assemblies, administrative, fiscal and legal systems. They are not represented in the UK Parliament. The Crown Dependencies have never been colonies of the UK. Nor are they British Overseas Territories, such as Gibraltar, which have a different relationship with the UK.
The constitutional relationship of the Crown Dependencies with the UK is through the Crown and is not enshrined in any formal constitutional document. The UK Government is responsible for the defence and international relations of the Islands, while the Crown, acting through the Privy Council, is ultimately responsible for ensuring their “good government”.
Primary legislation passed by the UK Parliament does not ordinarily apply to the Crown Dependencies. In certain cases, it can be extended by Order in Council made with the agreement of the Crown Dependencies concerned under an enabling provision known as a Permissive Extent Clause.
This briefing paper examines the constitutional status of the Crown Dependencies, their history and governance, as well as relations with the UK, international treaties and the impact of Brexit.
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1
What are Crown Dependencies?
The Crown Dependencies are Jersey, Guernsey and the Isle of Man.1 Within Guernsey there are three separate jurisdictions: Guernsey (which includes the islands of Herm and Jethou); Alderney; and Sark (which includes the island of Brecqhou).
The Crown Dependencies are self-governing entities, over which the Crown has certain responsibilities. Each has a different historic and constitutional relationship with the Crown, but they are not part of the United Kingdom. The three Dependencies each have their own political, legal and fiscal systems, separate from the UK.2
King Charles III is Head of State in each Dependency and is represented in each island territory by a Lieutenant Governor. In the Channel Islands the King is styled Duke of Normandy, and in the Isle of Man, Lord of Mann. Although the Royal Family website notes that the islands “owe allegiance to The King in his role as Duke of Normandy”,3 that title was renounced by Henry III in 1259 and removed from his seal and official styles in 1260.4
The “British Islands” is a term within the law of the United Kingdom which has existed since 1889. The Interpretation Act 1978 defines this as “the United Kingdom, the Channel Islands and the Isle of Man”.
1.1
Constitutional status
The 1973 report of the Royal Commission on the Constitution (also known as the “Kilbrandon Report”) referred to the constitutional position of the Crown Dependencies as “unique”:
In some respects they are like miniature states with wide powers of selfgovernment, while their method of functioning through committees is much more akin to that of United Kingdom local authorities.5
1 For the origins of the term “Crown Dependency”, see “Crown Dependency”: The constitutional version of the “Ploughman’s Lunch”?, Edge_Law blog, 8 April 2024.
2 Social legislation is also distinct. Homosexuality was decriminalised in the Isle of Man 1992, 25 years after England and Wales.
3 Crown Dependencies, Royal Family website.
4 Royal Styles and Titles in England and Great Britain, Heraldica website. In both Jersey and Guernsey the Monarch, whether male or female, is toasted as “the Duke”.
5 Royal Commission on the Constitution 1969-1973 Volume 1, Cmnd 5460, London: HMSO, para 1360.
In 2005 Jersey adopted a ministerial form of government.
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A 2010 Commons Justice Committee report referred to “their essential independence from the UK [and] their independence from each other”.6 The same report emphasised that the Crown Dependencies’ relationship was with the Crown rather than the UK, and that the Government’s responsibilities were derived from that fact. As the former Justice Secretary Jack Straw observed in 2008:
The relationship between us and the Crown Dependencies is a subtle one. They are dependencies of the Crown, they are not part of the United Kingdom, so the responsibilities I have for them are as a privy councillor.7
The Crown Dependencies are not represented in the UK Parliament and their relationship with the European Union between 1973 and 2020 was largely limited to membership of the customs union.8 Although self-governing, the UK Parliament can legislate:
for the Crown Dependencies in the areas of defence, nationality, citizenship, Succession to the Throne, extradition and broadcasting, by implication limiting the competence of the Island jurisdictions in these areas.9
1.2	Historical background
The Crown Dependencies have never been colonies of the UK. Nor are they Overseas Territories, such as Gibraltar, which have a different constitutional relationship with the UK.
The Channel Islands
Situated 10-30 miles off the north-west coast of France, the Channel Islands comprise two Crown Dependencies, Jersey and Guernsey. Guernsey comprises Guernsey (including the islands of Herm and Jethou), Alderney and Sark (including the island of Brecqhou).
The Channel Islands were originally part of the Duchy of Normandy. Following England’s loss of continental Normandy to France in 1204, the Channel Islands remained within the jurisdiction of the English Crown. Royal Charters were subsequently granted to Jersey and Guernsey.10
Jersey and Guernsey annually celebrate Liberation Day on 9 May. This commemorates the islands’ liberation from German occupation during the Second World War.
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Commons Justice Committee, Crown Dependencies, 23 March 2010, p44.
Commons Justice Committee, Crown Dependencies, p6.
Protocol 3 of the UK’s Treaty of Accession also provided for the free movement of goods and (asymmetric) free movement of people in the Crown Dependencies.
Justice Committee, Crown Dependencies, p20.
Royal Family website, Crown Dependencies.
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1.3
Isle of Man
The Isle of Man lies in the Irish Sea, equidistant between England, Scotland and Northern Ireland. Originally part of the Norwegian Kingdom of the Isles, its legislative system was introduced around 800AD, thus making its parliament “the oldest […] in the world with an unbroken existence”.11
In 1266, the island was ceded to Scotland, while England later acquired it by treaty under Edward I. The lordship of Mann was handed over to English lords in return for regular payments to successive monarchs. From 1405 to 1765, the island was ruled by the Earls of Derby and later the Dukes of Atholl, as Lords of Mann.
The use of the island as a secure base for smugglers became such a problem that in 1765 the British government required all customs and taxes to be paid to its Exchequer. The lordship reverted to the Crown and King George III became Lord of Mann.12
The modern constitutional relationship between the Isle of Man and the UK dates from 1866, when an Act of Parliament was passed separating Manx revenues from those of the UK and giving the island a limited measure of control over “insular” (or domestic) expenditure. Since then a series of measures, culminating in the Isle of Man Act 1958,13 transferred more control into local hands.14
Appendix 1 of the Justice Committee’s 2010 report on Crown Dependencies includes an overview of the “geography, people, government, economy and constitutional position of each jurisdiction”.
Governance
The Channel Islands
The unicameral States of Guernsey (États de Guernesey) is the parliament of Guernsey. It comprises 38 People’s Deputies and 2 Alderney Deputies. All its enactments apply to the island of Herm, while some also apply to Alderney and Sark as “Bailiwick-wide legislation” (with the consent of the States of Alderney or Sark Chief Pleas).15
Until relatively recently, Sark’s government was based on a feudal system (under a “Seigneur”, or Lord) and was therefore unelected. This arrangement
11 Tynwald website, Welcome to the Oldest Continuous Parliament in the World.
12 The Isle of Man’s Path to Autonomy, History Today website, 9 September 2014.
13 This was later repealed and replaced by the Isle of Man Act 1979.
14 See the Isle of Man Customs, Harbours, and Public Purposes Act 1866 and House of Keys Election Act 1866.
15 The States of Guernsey may legislate for Sark on criminal matters without the consent of the Chief Pleas.
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came to be considered untenable in the light of human rights law, and reforms led to elections in 2008 (see Section 3.1 below).16
Jersey’s States Assembly (Assemblée des États) is also unicameral, consisting of 37 Deputies elected across 9 districts and 12 Constables representing 12 parishes.17 The States Assembly elects the Chief Minister who, with Assembly approval, appoints the Council of Ministers.
According to Andrew Le Sueur, Professor of Constitutional Justice at Essex Law School, Jersey and Guernsey are “unique globally in having constitutions that in the ancient office of Bailiff fuse together the roles of chief justice and presiding officer of their respective courts and parliaments”.18 Several attempts have been made in the Jersey States Assembly to end the Bailiff’s role as president but they have not been successful.19
Isle of Man
The Isle of Man Parliament, known as the (High Court of) Tynwald, consists of two branches: the Legislative Council and the House of Keys. All Members of the Legislative Council (MLCs) are indirectly elected by the 24 Members of the House of Keys (MHKs), with the exception of the President of Tynwald, the Lord Bishop of Sodor and Man (a voting member) and the Attorney General. These are all ex-officio office holders.20 Tynwald sits as a single body to deal with financial and policy matters.
Tynwald Day
On 5 July each year, the Tynwald Court assembles in the open air on Tynwald Hill at St John’s for Tynwald Day. The Lieutenant-Governor of the Isle of Man presides.
Following a religious service in the Royal Chapel, members of Tynwald process to Tynwald Hill for proceedings presided over by the Lieutenant Governor. They then return to the Royal Chapel where a formal sitting of Tynwald takes place. By statute, each Act of Tynwald must be promulgated on Tynwald Hill within 18 months of enactment or it ceases to have effect. It is
16 Jonathan Parry · Life on Sark, London Review of Books 45:10, 18 May 2023.
17 Jersey’s next election is due on 7 June 2026. The States Assembly has agreed that Senators elected on an Island-wide mandate will be re-introduced at that election. The role of Senator had been abolished at the 2022 election (Senators due to return in 2026 elections, Vote.je website, 25 March 2025).
18 Andrew Le Sueur: Finally, separation of powers in Jersey?, UK Constitutional Law Association blog, 28 November 2024.
19 For the most recent, see States of Jersey to debate on dual Bailiff roles, BBC News online, 20 November 2024.
20 Under the Constitution Bill 2023, a private members bill guided through the House of Keys by Lawrie Hooper MHK, the Bishop of Sodor and Man would retain their seat in the Legislative Council but lose the right to vote (see Removal of bishop's vote moves forward in Legislative Council, BBC News online, 12 June 2024).
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promulgated in English and in Manx Gaelic. Any person may also approach Tynwald Hill on Tynwald Day to present a Petition for Redress.21
Political parties
Party politics is not well established in the Crown Dependencies and most members of their legislatures are independents.
Two parties are, however, represented in the States of Jersey, Advance Jersey (centre-right) and Reform Jersey (social democratic). Only one political party is represented in the States of Guernsey, Forward Guernsey. At the most recent election in the Isle of Man, the Liberal Vannin Party and Manx Labour Party won representation in the House of Keys.22
1.4	Legislative process
Principal legislation made by Crown Dependency legislatures requires Royal Assent. The UK Ministry of Justice examines each piece of legislation to ensure there is no conflict with the UK’s international obligations (including the European Convention on Human Rights) or with any “fundamental constitutional principles”. Having done so, it advises the Privy Council ofthe United Kingdom as to whether His Majesty should make an Assenting Order.23
The Justice Secretary can recommend that Royal Assent be withheld, although this is rare (see Section 3.1 below).
For Jersey legislation, Royal Assent is granted by the King in Council (the Privy Council).24 For Isle of Man legislation, the granting of Royal Assent is delegated to the Lieutenant Governor for many “non-reserved” purposes.25 The Ministry of Justice still reviews Manx legislation prior to indicating to the Lieutenant Governor that s/he may grant Assent. Projets de Loi (legislation) approved by the States of Guernsey, the States of Alderney or the Chief Pleas of Sark have, as of 29 February 2024, been subject to a procedure similar to that in the Isle of Man.26 For more on Royal Assent in the Crown Dependencies, see Commons Library research briefing CBP9466, Royal Assent.
The 1973 report of the Royal Commission on the Constitution observed that it was practice at the beginning of each reign to appoint Committees of the
21 See Tynwald website, Tynwald Day. There are no equivalent ceremonies in the Channel Islands.
22 Isle of Man government structure and political parties, CountryReports website.
23 See Ministry of Justice, Background briefing on the Crown Dependencies: Jersey, Guernsey and the Isle of Man.
24 There are proposals that assent for Jersey legislation be delegated to its Lieutenant Governor as per the Isle of Man precedent.
25 See the Isle of Man Constitution Act 1990 and the Royal Assent to Legislation and Sodor and Man Diocesan Synod Measures (Isle of Man) Order 2022.
26 Royal Assent to Legislation (Delegation to Lieutenant-Governor) (Bailiwick of Guernsey) Order 2024.
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Privy Council to “entertain petitions from the Channel Islands and the Isle of Man respectively”.27
The Committee for the Affairs of Jersey and Guernsey, for example, is the body which recommends approval of Channel Islands legislation. There is no longer an active Privy Council committee for the Isle of Man.
Farida Eden, a constitutional law specialist at the Ministry of Justice, explained the process to the Commons Justice Committee in 2010:
What happens is that a piece of legislation comes into us and we think maybe the drafting is not quite tight enough or we think there might be a human rights point, and we will get on the phone to our opposite numbers in one of the Crown Dependencies and talk them through it. It is a sort of partnership rather than us taking a hard line and saying we are going to refuse Royal Assent. Sometimes they will explain something to us and we will say that makes sense or sometimes we might seek assurances as to how a piece of legislation is actually going to be operated in practice.28
A Justice Committee inquiry found that Ministry of Justice lawyers were not necessarily confining themselves to the constitutional grounds for review and “were questioning the form and policy content of insular legislation on other grounds”, such as “congruence with UK policy”. This the Committee considered constitutionally “inappropriate”. Later, Lord McNally, then Minister of State for Justice, acknowledged this “second-guessing” had been “paternalistic and unnecessary”.29
1.5	Nationality
Nationality is generally acknowledged as a UK responsibility. The British Nationality Act 1981 conferred British citizenship on all those with close connections with the UK, the Channel Islands and the Isle of Man. The Lieutenant Governor is the passport-issuing authority on each island. Each Crown Dependency issues its own “variant” passports with different front covers from the standard UK version.30
Jersey, Guernsey, the Isle of Man and the Republic of Ireland, together with the UK, comprise the Common Travel Area. There are no immigration controls between the UK and the Islands or between the Islands themselves.
27 Royal Commission on the Constitution, para 1361.
28 Justice Committee, Crown Dependencies, p23.
29 Commons Justice Committee, Crown Dependencies: developments since 2010, 10 December 2013, p16.
30 See, for example, Jersey variant British passports, Government of Jersey website.
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1.6	The Crown
Each Crown Dependency has traditional ceremonial associated with the visit of a reigning monarch.
Jersey
There is usually a Special States Sitting and Sitting of the Royal Court as well as a public homage at Royal Square in St Helier.31 When Queen Elizabeth II visited in 2001, she was presented with two dead mallards on a silver tray, part of an ancient tradition dating back to the Middle Ages when seigneurs (lords of the manor) would pay homage to the sovereign as the Duke of Normandy.32 When the King visited in July 2024 he was instead gifted locally laid duck eggs. He touched the bowl containing the eggs before they were accepted on his behalf by the Receiver General, the King’s representative on the islands.33
Guernsey
There is usually a special sitting of the States of Guernsey and a ceremony of homage (historically observed on the first visit of a new monarch) at St Peter Port seafront. The ceremony is held in French and historic title holders, Seigneurs and Dames of small parcels of land known as “Fiefs”, pay homage to the King.34
Isle of Man
King Charles III has yet to visit the Isle of Man following his Accession in September 2022, although Queen Camilla did so in March 2024 to celebrate the conferral of city status on Douglas.35
King George VI presided at Tynwald Day in 1946, as did Queen Elizabeth II in 1979 (its millennial) and 2003.36 Occasionally another member of the Royal Family has presided, including Prince Edward in 1986, the then Prince of Wales in 2000 and the Princess Royal in 2021.37
31 Events taking place during the Royal Visit, Government of Jersey website. On arrival to the Royal Square on 15 July, the King and Queen will be led by the Royal Mace of 1663, gifted to the Iisland by King Charles II in recognition of its loyalty to the Crown.
32 This custom was dispensed with in 2005 (Duck is off, Jersey Evening Post, 30 April 2005).
33 King and Queen duck out of ancient tradition in tour of Channel Islands, Telegraph, 8 July 2024. His Majesty was also presented with seven Jersey heifers.
34 The Visit of His Majesty King Charles III and Her Majesty Queen Camilla, States of Guernsey website.
35 The Queen visits the Isle of Man, Royal Family website, 21 March 2024.
36 Tynwald Day 2003, Isle of Man Guide website.
37 The Isle of Man celebrate Tynwald Day in Royal company, ITV News Granada website.
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The Isle of Man’s Accession Proclamation for King Charles III in September 2022 included a local title for the first time.38 During a ceremony at Government House in Onchan, Lieutenant-Governor General Sir John Lorimer proclaimed the King:
Charles III by the grace of God of the United Kingdom of Great Britain and Northern Ireland and of his other realms and territories King, Lord of Mann, head of the Commonwealth, Defender of the Faith, to whom we
do acknowledge all faith and constant obedience […] God save the King, Lord of Mann.39
1.7	Judicial systems
Each Crown Dependency has its own legal system and courts of law, many of which have a legislative basis:40
•	Isle of Man Courts of Justice – Staff of Government (Appeals), High Court (Civil Division and Court of General Gaol Delivery) and the Lower Courts
•	Jersey Courts Service – Royal Court (including the Family Division) the Court of Appeal, Magistrate’s Court, Petty Debts Court, Youth Court, Youth Appeal Court and Tribunals
•	Guernsey Court System – Royal Court, Magistrate’s Court, Contracts Court, Guernsey Court of Appeal, Court of Chief Pleas and the Ecclesiastical Court (and, separately, the Court of Alderney and the Court of the Seneschal of Sark)
The judiciary and law officers of the Crown Dependencies are appointed under the royal prerogative by the King on the advice of the Lord Chancellor. The Lord Chancellor can also advise the King, if necessary, to remove a member of a Crown Dependency judiciary.41
38 See The Proclamation of Charles III, Edge_Law blog, 24 September 2022. For the texts of previous Isle of Man proclamations see Office of the Clerk of Tynwald, Proclaiming the new monarch in the Isle of Man, 1765-1952, 14 September 2022.
39 Proclamation of the Lord of Mann at St. John’s, 16 September 2022. A second Proclamation took place on Tynwald Hill in St John’s on 16 September, this time in English and in Manx Gaelic.
40 Information Notes on the Jersey and Guernsey Courts of Appeal, Courts and Tribunals Judiciary website.
41 HC Deb 19 May 1992 Vol 208 cc93-4W [Jersey Bailiff (Dismissal)]. The advisory role was previously the responsibility of the Home Secretary.
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2
UK Government relations with the
Crown Dependencies
The Ministry of Justice – through its Crown Dependencies Unit – is responsible for managing the UK’s constitutional relationship with the Crown Dependencies.42 The Ministry of Justice “plays a vital role as an interlocutor and facilitator for the Crown Dependencies in their engagement with the rest of the [UK] Government”.43
That relationship involves a variety of different responsibilities, including involvement in Crown Appointments,44 processing legislation for Royal Assent and issuing “Letters of Entrustment”. These authorise Crown Dependency governments to negotiate and conclude certain international agreements (see Section 4).45
Other major aspects of this relationship involve:
•	the Ministry of Justice reminding other Whitehall departments of their obligations in relation to the Crown Dependencies and mediating contact with the Islands where necessary;
•	processing insular (or local) legislation prior to Royal Assent;
•	keeping the Crown Dependencies informed in relation to any UK legislation or international treaties intended to apply to or affect them;
•	representing the interests of the Crown Dependencies on the international stage as appropriate;
•	defence; and
•	advising the Sovereign if there is any threat to the good government of a Dependency which would justify intervention.46
The Lord Chancellor and Secretary of State for Justice is the Privy Counsellor with responsibility for advising the Crown on matters relating to the Crown Dependencies.
42 Previously, the responsible UK Government department was the Home Office.
43 Justice Committee, The constitutional relationship with the Crown Dependencies: Government Response, HC 582, 19 December 2024, para 2.
44 See Ministry of Justice, Background briefing on the Crown Dependencies: Jersey, Guernsey and the Isle of Man, p4, for a full list of Crown Appointments.
45 See Ministry of Justice, Government Response to the Justice Select Committee Report ‘Crown Dependencies: developments since 2010, March 2014, p15.
46 Justice Committee, Crown Dependencies, p3.
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Although the Ministry of Justice issued “how to” notes in 2013, there is no Act of Parliament or other document clearly setting out the relationship between the UK Government and the Crown Dependencies. As a group of Jersey lawyers observed, as with “so much on our constitutional map”:
the relationship between the Crown Dependencies […] and the United Kingdom is not clearly delineated [and] rest largely on the common law, ancient Royal Charters and constitutional convention about which there is not always agreement.47
In December 2024, the UK government observed that the constitutional relationship had “evolved organically over time and is based on mutual respect and cooperation”:
Any attempt to codify or prescribe the relationship could risk undermining the flexibility and adaptability that has been beneficial to the relationship. We should be wary of unintended consequences and of the potential to damage a relationship that the Committee has found to be in good health.48
By convention, the Isle of Man’s Chief Minister usually leads on external engagement with Westminster and further afield, aided by the Crown and External Relations Directorate of the Isle of Man Cabinet Office. This differs from Jersey, which has a dedicated Minister for External Relations, and Guernsey, where the Lead Member of the Policy and Resources Committee has responsibility for External Relations.
The House of Commons Justice Committee regularly examines the relationship between the Crown Dependencies and the UK government, “taking an in depth look at issues as they arise”.49
In February 2024, the House of Commons Health and Social Care Committee recommended that:
The UK Government must consider how to respond to another jurisdiction in the UK, or the Crown Dependencies, legislating to allow [Assisted Dying/Assisted Suicide], and how it may impact jurisdictions which do not allow it. Following the recommendation by the Jersey Citizens’ Assembly, it looks increasingly likely that at least one jurisdiction among the UK and Crown Dependencies will allow AD/AS in the near future and Ministers should be actively involved in discussions on how to approach the divergence in legislation.50
47 Jeffrey Jowell et al, The Barclay Cases: Beyond Kilbrandon, Jersey Legal Information Board, March 2018.
48 Justice Committee, The constitutional relationship with the Crown Dependencies: Government Response, para 23.
49 For the most recent report, see House of Commons Justice Committee, The constitutional relationship with the Crown Dependencies, HC 30, 28 March 2024.
50 House of Commons Health and Social Care Committee, Assisted Dying/Assisted Suicide, HC 321, 29 February 2024, p23.
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2.1
Intergovernmental relations
The three Crown Dependencies also take part in several statutory and non-statutory intergovernmental forums, alongside other governments in the British Isles.51
British-Irish Council
The 1998 Belfast/Good Friday Agreement established the British-Irish Council (BIC) with a secretariat based (since 2012) in Edinburgh. According to the BIC’s website, its purpose is:
to promote the harmonious and mutually beneficial development of the totality of relationships among the peoples of these islands [...] the BIC will exchange information, discuss, consult and use best endeavours to reach agreement on co-operation on matters of mutual interest within the competence of the relevant administrations.52
The BIC consists of representatives from the:
•	UK Government
•	Irish Government
•	Northern Ireland Executive (when fully functioning)53
•	Scottish Government
•	Welsh Government
•	Isle of Man Government
•	States of Guernsey
•	Government of Jersey54
The BIC usually meets twice a year at ministerial summits, as well as more frequently via “work sector” meetings, which include ministers and officials from specific policy areas. Work sectors cover a wide range of policy areas, including energy, creative industries, transport and the misuse of substances, all areas where there are common challenges across all member administrations.
51 The 1973 report of the Royal Commission on the Constitution had proposed a “Council of the Isles” to facilitate relations between the UK and Crown Dependencies, but that proposal was not taken up by the UK Government (see para 1508).
52 British-Irish Council website, About the Council.
53 When the Executive and Northern Ireland Assembly are suspended or not fully functioning, then in practice officials from the Northern Ireland Civil Service represent Northern Ireland.
54 The Council of Ministers adopted the “Government of Jersey” identity in February 2019.
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2.2
The three Crown Dependencies host BIC summit meetings, as do the other member governments, on rotation.
Contact between UK and Crown Dependency officials
Following the UK’s Brexit referendum in June 2016, quarterly meetings took place between the UK Government’s Minister for Exiting the European Union and the Chief Ministers of Guernsey, Jersey and the Isle of Man. This formed part of a programme of engagement concerning the UK’s departure from the EU.55 This Chief Ministers’ Quarterly was later replaced with a quarterly meeting of officials.56
Regular “contact group” meetings between the UK Ministry of Justice and Crown Dependency officials take place either fortnightly or monthly, serving what Jersey Deputy Ian Gorst has called a “clearing house” role.57 Separately, regular meetings take place between the Crown Dependencies and the UK Cabinet Office in relation to the “UK-EU reset”.58 The UK minister with responsibility for the Crown Dependencies usually meets with representatives of Guernsey, Jersey and the Isle of Man and visits each of the Crown Dependencies from time to time.
Judicial Committee of the Privy Council
While each Crown Dependency has its own legal system and courts of law (see Section 1.7), the Judicial Committee of the Privy Council in London remains the highest court of appeal for the Crown Dependencies as well as the Overseas Territories and many members of the Commonwealth.
On a recommendation from the Stonham Working Party in 1969, more formal machinery for consultation between the UK and the Isle of Man was established. The “Standing Committee on the Common Interests of the Isle of Man and the United Kingdom” consisted of three members elected by Tynwald and three representatives of the UK Government with a joint secretariat. It met throughout the 1970s but appears to have lapsed thereafter.59
Financial relations
Under long-standing agreement, the Isle of Man makes an annual contribution to the UK for defence and common services, including overseas
55 See UK Government press release, Minister gives Brexit update to the Channel Islands and Isle of Man, 5 March 2018.
56 Justice Committee, Oral evidence: Constitutional relationship with the Crown Dependencies, HC 595, 7 September 2021.
57 As above.
58 See, for example, Jersey ministers in Downing Street as UK and EU agree major post-Brexit reset, Jersey Evening Post, 20 May 2025.
59 See Royal Commission on the Constitution, para 1415.
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representation. The amount is determined in accordance with the 1994 Contribution Agreement between the UK and Isle of Man governments.60
There is no equivalent contribution from the Channel Islands, although Jersey maintains the Jersey Field Squadron (The Royal Militia Island of Jersey), a Territorial Army Regiment, and Guernsey the Alderney Breakwater.61
After the First World War an attempt was made by the UK Government to require an “imperial contribution” from Jersey and Guernsey, but this was successfully resisted by the islands on the basis that any contribution had to be voluntary.62
In accordance with the Jersey and Guernsey (Financial Provisions) Act 1947, Jersey and Guernsey occasionally surrender hereditary revenues of the Crown to the UK Consolidated Fund, with each payment being returned to Jersey and Guernsey within ten working days. In recent years, His Majesty’s Receiver General for Jersey has sent the Treasurer of the States of Jersey both a cheque and a set of accounts in respect of hereditary revenues, thereby avoiding the need for a “circular” transaction between Jersey and the UK Exchequer.63
All three Crown Dependencies neither receive grants from nor pay contributions to the UK, and nor do their inhabitants pay UK taxes. Rather each Crown Dependency pays for their needs out of their own revenues via taxation, the rates of which are decided by the respective legislatures. There have, however, been arrangements under which the Crown Dependencies pay for or reciprocate benefits in education and other social services received from the UK.
In 2008, the UK Department of Health decided to terminate long-standing Reciprocal Health Agreements with the Crown Dependencies under which Island visitors to the UK and UK visitors to the Islands received free health care. This was on the basis that the Agreements did not represent value for money for the UK taxpayer.64 The decision was subsequently reversed, with a new agreement coming into force on 1 October 2010.65
Revenue sharing arrangement
In 1979 the UK and Isle of Man governments agreed to a revenue sharing arrangement (RSA) which removed the need for customs barriers between the
60 The Isle of Man’s payment was introduced under the Isle of Man Customs, Harbours, and Public Purposes Act 1866. Previously, the UK Treasury had retained all surplus Manx revenue.
61 Guernsey also makes part of its contribution in the form of payment of passport fees, which are passed to the UK Ministry of Justice.
62 Guernsey and Jersey did make a voluntary contribution to the UK Exchequer as a contribution to the cost of the First World War.
63 Information provided by the Law Officers’ Department, St Helier, Jersey.
64 Justice Committee, Crown Dependencies, p13.
65 Islanders requiring with more complex medical needs, which cannot be met on-Island, typically receive treatment at UK hospitals. The governments of the Crown Dependencies purchase such treatment from the NHS.
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Island, the UK and the European Union, and made the Island part of the EU’s Customs Union and VAT territory. This replaced what had been known as the “Common Purse Agreement”.66
Under the RSA, the Isle of Man and UK pooled VAT and most other indirect tax revenues and share them according to the agreement. Pooled revenues can be reviewed at the request of either party at any time, although termination requires a two-year notice period. In 2011, the RSA was renegotiated to take account of the “size and composition of the IOM economy”.67
See Section 4.2 for the Crown Dependencies’ post-Brexit arrangements with the UK.
2.3
Disputes
Constitutional disputes between the Crown Dependencies and the UK Government are rare but not unprecedented.
In 1960 a prayer appeared on the House of Commons Order Paper:
That an humble Address be presented to Her Majesty, praying her graciously to withhold her Assent from the Summary Jurisdiction Bill, lately passed in the Legislative Council and the House of Keys, which gives magistrates in the Isle of Man wider powers of imposing corporal punishment on children and young persons.
Asked about this in Parliament, the then Home Secretary Rab Butler said he had:
information that the House of Keys has passed a Resolution on this matter and I have information, also, from the Member of the House of Keys who raised this matter that there is not a general desire that there should be a major conflict between the House of Keys and the House of Commons, which, I think, we should all deplore […] Subject to that, various matters of very great constitutional interest arise on this subject […] but, provided we all keep cool, we may resolve this issue.68
The constitutional implications were debated in the House of Commons on 8 April 1960.69 The Summary Jurisdiction Act 1960 subsequently became law on the Isle of Man.
Another disagreement concerned responsibility for broadcasting. Until the early 1960s, it seems not to have been in dispute that this was a matter for the UK Parliament and Government, both the Wireless Telegraphy Act 1904 the Television Act 1954 having been extended to the Isle of Man.
66 Unlike the Isle of Man, Jersey and Guernsey were not subject to EU VAT and excise directives.
67 See Isle of Man Treasury, Customs and Excise Agreement, 5 August 2011.
68 HC Deb 24 March 1960 Vol 620 c678 [Business Of The House].
69 HC Deb 8 April 1960 Vol 621 cc844-54 [Summary Jurisdiction Bill (Isle Of Man), 1960].
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In 1961 Radio Manx Limited (or “Manx Radio”), a company sponsored by the Isle of Man Government, applied to the UK Postmaster General for a frequency and a transmission licence. The application was refused. Tynwald then requested the revocation of the Order in Council extending the relevant Act to the island, while enacting legislation conferring powers to license broadcasting in the Island on the Lieutenant Governor. The requests for revocation of the Order in Council and for Royal Assent to the Bill were both refused, partly on the grounds that it conflicted with the UK’s international obligations.
A 1962 proposal to license a television and radio station to transmit to the “British Islands” only was also refused by the UK. Only when the Isle of Man submitted proposals for a radio station to broadcast to the Island alone were they approved. A licence was issued in 1965 and a commercial broadcasting station was established in the Island.
When the Marine etc Broadcasting (Offences) Bill was introduced to the UK Parliament, it contained a clause permitting it to be extended by Order in Council to the Isle of Man. The Isle of Man Government indicated its preference for legislating in Tynwald for as much of the subject matter (pirate broadcasting) as was within its constitutional competence, for example criminal law. The Tynwald appealed to the Queen in Council (the Privy Council) against extension, but this was rejected.70
These disputes led to both the Stonham Working Party (see Section 2.1 above) and the Isle of Man seeking a new procedure for Royal Assent of Manx legislation, which remains in place (see Section 1.4 above).
Relations since 2010
A 2013 Commons Justice Committee report found that on a number of occasions since 2010 the UK had:
acted in ways which the Crown Dependencies judged to be inappropriate, wrong or unfair, and which have strained the relationship. These include instances where the UK has made decisions which impacted on the Islands without prior consultation.71
However, the Committee also concluded that compared with the situation prior to 2010, the relationship had:
improved considerably. The process for granting Royal Assent for Crown Dependency legislation is much quicker; and the Islands are, in general, better consulted about UK legislation and international measures affecting them. Where tensions do arise, the Ministry of Justice works effectively to facilitate resolution as far as possible.72
70 See Royal Commission on the Constitution, paras 1421-29.
71 Justice Committee, Crown Dependencies: developments since 2010, p11.
72 Justice Committee, Crown Dependencies: developments since 2010, p3.
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In evidence, Lord McNally said that:
As long as the Westminster Government appreciate and understand the nature of that relationship—that they are not colonies and cannot be browbeaten and bullied but have to be taken into account and discussed with— […] it is a solid relationship and one that I do not see needs any tinkering with in any fundamental way.73
73 Justice Committee, Crown Dependencies: developments since 2010, p14.
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3
3.1
Extension of UK legislation to the Crown Dependencies
In contrast with the British Overseas Territories, for which the UK Parliament has unlimited power to legislate,74 UK primary legislation does not ordinarily apply to the Crown Dependencies. Following prior consultation and consent it can, however, be extended to them if:
•	UK Government departments consider that primary UK legislation in whole or in part needs to have effect in any of the Crown Dependencies; or
•	UK Government departments have received a request from a Crown Dependency seeking to extend provisions of a UK Act (with or without modifications) to their jurisdiction by activation of a Permissive Extent Clause (PEC).
This can happen either by “direct application” (expressly or by necessary implication) or via an Order in Council. According to the Ministry of Justice, “for an Act to extend otherwise than by an Order in Council is now very unusual”.75
A PEC in a UK Bill could take the following form:
His Majesty may by Order in Council provide for any of the provisions of this Act to extend, with or without modifications, to any of the Channel Islands or the Isle of Man.76
Ministry of Justice guidance also states that UK departments:
must consult the Crown Dependencies at the earliest opportunity in the event that extension is under consideration and a PEC should not be included in a Bill without the prior agreement of the Islands.77
Constitutional convention
The 1973 Royal Commission on the Constitution observed that, by convention, the UK Parliament did “not legislate for the Islands without their consent in matters of taxation or other matters of purely domestic concern”. It also
74	See UK Government White	Paper,	The Overseas Territories, 28 June 2012.
75	Ministry of Justice,	How To	Note:	Extension	of UK primary legislation to	the	Crown	Dependencies.
76	Ministry of Justice,	How To	Note:	Extension	of UK primary legislation to	the	Crown	Dependencies.
77	Ministry of Justice,	How To	Note:	Extension	of UK primary legislation to	the	Crown	Dependencies.
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3.2
noted that the last time the UK made use of prerogative Orders in Council to legislate for a Crown Dependency was the Court of Appeal (Channel Islands) Order 1949, although this had been based on a scheme which had prior approval.78
But this is a convention rather than a matter of law.79 The Royal Commission also concluded “that in the eyes of the courts [the UK] Parliament has a paramount power to legislate for the Islands in any circumstances”:
This does not, of course, mean that Parliament should be any more ready than in the past to interfere in the Islands’ domestic affairs and any less mindful of the need to preserve their autonomy […] If, exceptionally, circumstances should demand the application to the Islands without their consent of measures of a kind hitherto regarded as domestic, then Parliament would, in our view, have the power to enact the necessary legislation.80
The UK last activated a Permissive Extent Clause without a Crown Dependency’s consent in 1967. This was on the grounds of the UK’s responsibility for the international affairs of Isle of Man.81
In 2014, Lady Hale, the then president of the Supreme Court, noted the Royal Commission’s view but added that it was “the practice to consult the Islands before any United Kingdom legislation is extended to them”.82
When, for example, the European Convention on Human Rights was incorporated into UK law through the Human Rights Act 1998, there was discussion as to whether that Act should be extended to the Crown Dependencies. In the end, it was decided they would pass their own human rights legislation.83
Fisheries Act 2020
Unusually, the UK Government included a Permissive Extent Clause in the Fisheries Act 2020 despite explicit opposition from Jersey and Guernsey. This states that:
His Majesty may by Order in Council provide for the following provisions of this Act to extend, with or without modifications, to any of the Channel Islands or the Isle of Man.84
78 Royal Commission on the Constitution, para 1362.
79 As is the case with the Sewel Convention in its application to devolved areas in Scotland, Wales and Northern Ireland.
80 Royal Commission on the Constitution, para 1473.
81 Justice Committee, The constitutional relationship with the Crown Dependencies: Government Response, para 59.
82 See Jowell et al, The Barclay Cases: Beyond Kilbrandon.
83 Jowell et al, The Barclay Cases: Beyond Kilbrandon. A similar arrangement exists regarding Brexit (see Section 4.2).
84 See section 53(6) on “Extent”.
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Giving evidence to the Commons Justice Committee in September 2021, Deputy Jonathan Le Tocq, a former Chief Minister of Guernsey, said the process had “started in the right way, in the sense that we were consulted months before and asked if we wanted to be included in a PEC”:
We thought about it and said, “No, we can legislate domestically for that as and when it comes to it, and we will consider the issues at stake each time and produce appropriate legislation where necessary.” That was all we heard for many months, until a few weeks before the amendment [to the Fisheries Bill] was put in. In terms of process, that left us with a bad feeling of why ask us if the answer is, “We’re going to do this anyway”? On engagement, we felt the reasons given were unreasonable […] and it did not seem to us to be, in this particular instance, such an important, crucial and risky area that required that sort of heavyhandedness. We made that clear.85
The UK Government said the PEC would only be enacted as “a last resort”, but during Commons consideration of the amendment the Conservative MP Sir Bob Neill protested that it was:
truly unprecedented for the Government to insist upon a permissive extent clause without the agreement of the relevant Crown dependencies. Why, even in an emergency, go down this rather provocative step? Why not wait until such time as an emergency arises and let them legislate, as they have indicated they would?86
Primary legislation passed in the UK and extended to the Channel Islands requires the resulting Order in Council to be registered in the islands’ respective courts following a vote.87
Deputy Jonathan Le Tocq told the Commons Justice Committee that if the Fisheries Act PEC was ever enacted then “there would be huge problems in it being registered in our [Royal] courts. In Guernsey’s case, three Assemblies would need to pass it, and that would be quite hard now.” Jersey’s Minister for External Affairs, Ian Gorst, agreed:
You can see if you have already got to a confrontational situation and Her Majesty signs an order in council, and it is dispatched to a territory in Jersey, you are in a situation that you never want to get into.88
If legislation is not registered in this way in Jersey and Guernsey, then it is “not enforceable” and would not be regarded as constitutionally valid (see Section 3.5 below).
85 Justice Committee, Oral evidence: Constitutional relationship with the Crown Dependencies, HC 595, 7 September 2021.
86 HC Deb 13 Oct 2020 Vol 682 c265
87 This is not the case in the Isle of Man.
88 Justice Committee, Oral evidence: Constitutional relationship with the Crown Dependencies, HC 595, 7 September 2021.
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In December 2024 the UK government said it did not agree that the inclusion of a PEC in the Fisheries Act 2020 had been “contrary to the constitutional relationship” between the UK and the Crown Dependencies.89 It argued that:
The inclusion of a PEC in UK legislation does not constitute legislating for the Crown Dependencies as the mere fact of a PEC’s inclusion does not have a material effect in the Crown Dependencies. A PEC is a mechanism that enables UK provisions to be extended to the Crown Dependencies in the future if either a Crown Dependency or, in exceptional circumstances, the UK thinks it necessary.90
In March 2024, Guernsey and Jersey expressed frustration at the Channel Islands’ inclusion in a draft UK law aimed at deterring boat crossings across the English Channel by sending asylum seekers to Rwanda.91
3.3	The Crown Dependencies and “good
government”
The Royal Commission on the Constitution also believed the UK could legislate on behalf of the Crown Dependencies on the basis of what it called “good government”. In 2010, the Commons Justice Committee found “a high degree of consensus amongst academics, legal advisors, politicians and officials” as to the meaning of this term:
They agree that good government would only be called into question in the most serious of circumstances, exemplified by the recent events in Turks and Caicos which did, indeed, lead to UK Government intervention. Such circumstances are likely to include a fundamental breakdown in public order or endemic corruption in the government, legislature or judiciary.92
Consideration of “good government” appears to have formed the basis for the Justice Secretary’s initial rejection of Royal Assent for the first formulation of a new democratic legislature for Sark in 2008. He declined to recommend the proposed law for Assent on the basis that it was “inconsistent with basic democratic principles, some of which were set out in the European Convention on Human Rights”. When a revised law was resubmitted by Sark, the Justice Secretary judged it to be acceptable and recommended it for Royal Assent, which it duly received.93
89 Justice Committee, The constitutional relationship with the Crown Dependencies: Government Response, para 71.
90 Justice Committee, The constitutional relationship with the Crown Dependencies: Government Response, paras 55 & 58.
91 Jersey and Guernsey's governments reiterate independence after being included in UK Rwanda bill, ITV News online, 14 March 2024.
92 Justice Committee, Crown Dependencies, p16.
93 Justice Committee, Crown Dependencies, p18.
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3.4
In its 2010 report, the Justice Committee recommended that the “independence and powers of self-determination of the Crown Dependencies” should “only to be set aside in the most serious circumstances”, used only:
in the event of a fundamental breakdown in public order or of the rule of law, endemic corruption in the government or the judiciary or other extreme circumstance.94
Giving evidence to a later inquiry, Lord McNally confirmed the UK Government’s view that “unless there is real evidence of a breakdown either in the policing or the integrity of the judiciary or general law and order”, it would not intervene.95
Beneficial ownership registers
Questions of “good government” also arose in the context of published registers of beneficial interest and their possible adoption by the Crown Dependencies. A register of beneficial ownership lists who ultimately owns a company or entity, which may or may not be published.
The UK has registers of beneficial ownership for assets and trusts. The beneficial (or ultimate) ownership of companies (but not trusts) is publicly available. 96 In April 2014, the then Prime Minister David Cameron wrote to the Crown Dependencies and British Overseas Territories (BOTs) encouraging them to follow the UK’s example.
At the Commons Report Stage of the Sanctions and Anti Money Laundering Bill 2017-19, the UK Government agreed to a new clause requiring it to prepare a draft Order in Council which would compel the BOTs to establish public registers of beneficial ownership. But it did not agree a second amendment extending this to the Crown Dependencies given their distinct constitutional status. This became section 51 of the Sanctions and Anti-Money Laundering Act 2018. The Order in Council has not yet been made.
Later, during Parliamentary consideration of the Financial Services Bill 201719, a cross-party group of MPs proposed a similar amendment requiring public registers with details of anyone owning more than 25% of a company based in a Crown Dependency by 2020. The MPs cited the 1973 Royal Commission on “good government”, although the Crown Dependencies argued that their systems for combating money laundering already represented this.
In response, the Chief Ministers of Guernsey, Jersey and the Isle of Man argued that Westminster could not impose legislation without consent. Lyndon Trott, Guernsey’s then Deputy Chief Minister, added that the
94 Justice Committee, Crown Dependencies, p18.
95 Justice Committee, Crown Dependencies: developments since 2010, p30.
96 See the Small Business, Enterprise & Employment Act 2015.
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imposition of a public register would “seriously undermine our longstanding and close relationship with the UK and the crown”.97 On 4 March 2019, the Government withdrew the Financial Services Bill, saying the amendment would be considered later on.98
In a joint statement, the Crown Dependencies announced on 19 June 2019 that they would initially grant access to certain financial services businesses for corporate due diligence purposes; and then implement their own publicly accessible registers of company beneficial ownership in line with EU norms, but some years later. The Crown Dependencies pointed out that their own registers of beneficial ownership were already made readily available to UK authorities upon request.99
However, the Sovim judgment (November 2022) triggered a fundamental shift in context.100 The Court of Justice of the European Union ruled that public access under the EU’s Fifth Anti Money Laundering Directive (AMLD5) was invalid on the basis that it was not a proportionate to the interference with fundamental rights.
As a result, the Crown Dependencies made a new commitment in December 2023 which replaced that from 2019. The Crown Dependencies collectively committed that:
Subject to necessary approvals in the Crown Dependencies’ legislatures, we will provide access to the information on our registers of beneficial ownership to those who can demonstrate that they have a legitimate interest.101
This stopped short of full public access but nevertheless made registers accessible to those demonstrating a legitimate interest.
Meanwhile, during 2024, MONEYVAL independently assessed Jersey and Guernsey for compliance with international standards in respect of transparency of beneficial ownership, finding them to be both compliant and substantially effective.102 The Isle of Man is due to be assessed during 2026.
Nevertheless, the UK Government’s position remains that:
It remains our expectation that the Overseas Territories (OTs) and Crown Dependencies will ultimately implement fully public registers.103
97 Crown dependencies set for transparency clash with Westminster, Financial Times, 3 March 2019. According to the Financial Times report, Andrew Mitchell and Dame Margaret Hodge claimed in a letter to supportive MPs that the Crown Dependencies acted as “secret tax havens facilitating economic crime, tax avoidance and tax evasion”.
98 Ministers halt discussion of tax transparency bill, BBC News Online, 4 March 2019.
99 See Statutory review of the exchange of notes arrangements, Home Office, 27 June 2019.
100 EUR-Lex – 62020CJ0037 – EN – EUR-Lex.
101 Joint commitment by Guernsey, the Isle of Man and Jersey: Registers of beneficial ownership of companies, Government of Jersey website, 13 December 2023.
102 See Jersey – Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism and Guernsey – Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism.
103 British Overseas Territories: Companies, UIN 66099, 8 July 2025.
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3.5	Response in the Crown Dependencies
In response to the debate concerning registers of beneficial ownership, the States of Guernsey’s Policy and Resources Committee proposed changes to the Reform (Guernsey) Law 1948 to require that UK:
Acts of Parliament and Orders in Council which seek to apply to Guernsey will be referred to the States of Deliberation for approval and consent before such an Act of Parliament or Order in Council […] is registered in Guernsey’s Royal Court.
This proposal was similar to a legal requirement already in place in Jersey, where UK legislation is not law until it has been approved by the States of Jersey.104
In 1968 the UK Government assured Guernsey that there was no question of it seeking to legislate for the Island “in any taxation matter or in any other matter which had long been accepted as the responsibility and concern of the insular authorities”.105
3.6	Proposals for reform
In their evidence to the Royal Commission on the Constitution, the States of Jersey and Tynwald proposed “an Act of Parliament making a formal division of legislative and executive responsibilities between the United Kingdom and the Islands”. This was rejected by the UK Government on the basis that it would leave it:
with responsibility both for the good government of the Islands and for their external relations, but without the power needed to exercise that responsibility.106
In 2013, the Commons Justice Committee also noted pressure towards “redefining the constitutional relationship in a way that allows the Islands even greater independence from the UK”. But it concluded that while:
the relationship has evolved over time and will rightly continue to do so, its very nature imposes certain responsibilities on the UK which it cannot ignore. We are therefore not convinced that any attempt to achieve a fundamental rebalancing would be fruitful.107
104 See section 31 of the States of Jersey Law 2005.
105 Royal Commission on the Constitution, para 1477.
106 Royal Commission on the Constitution, para 1480. The Government of Ireland Act 1920 was cited as a possible model.
107 Justice Committee, Crown Dependencies: developments since 2010, pp36-37.
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4
4.1
Crown Dependencies and external relations
The Crown Dependencies are not recognised internationally as sovereign states in their own right but as “territories for which the United Kingdom is responsible”.108 As such they cannot sign up to international agreements without a Letter of Entrustment (see Section 4.3 below) but can have the UK’s ratification of such instruments extended to them.
The 1950 declaration
For the purposes of international agreements, until 1950 the Crown Dependencies were regarded as part of the “metropolitan territory” of the UK. In recognition of the fact that this might be inconsistent with their constitutional status as self-governing territories, a declaration was made to the effect that, in future, any international treaty agreed by the UK would “not extend to the Island unless they were expressly included”.109
Process for extension of international treaties
When the UK ratifies, accedes to, or accepts a treaty, convention or agreement, by long-standing practice it does so on behalf of the United Kingdom of Great Britain and Northern Ireland and any of the Crown Dependencies or Overseas Territories that wish the treaty to apply. The UK’s ratification, accession or acceptance can also be extended to Crown Dependencies or Overseas Territories at a later date.
This means that when the UK is planning to ratify International Conventions, Treaties, Protocols or Agreements (“International Instruments”) it consults the Crown Dependencies concerning their extension. The Ministry of Justice states that consultation regarding extension is a matter of:
essential policy and administration. International instruments which propose provisions relating directly to the Crown Dependencies should not be negotiated unless consultation in good time in advance has taken place with the Islands in question. Where applicable, the views of each Crown Dependency may also be required to formulate the UK negotiating position on an International Instrument.
108 See Ministry of Justice, Fact sheet on the UK’s relationship with the Crown Dependencies.
109 Royal Commission on the Constitution, para 1381.
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Normal practice is for initial UK consultation with the Crown Dependencies to occur during the course of negotiating an International Instrument if the subject of that Instrument might be relevant to the Crown Dependencies.110
If a treaty is extended to one or all the Crown Dependencies, the UK is responsible under international law for compliance with that treaty, for example by ensuring there is appropriate “insular” legislation in place.111
4.2	Brexit and the Crown Dependencies
The relationship between the Crown Dependencies and the European Union (EU) was based upon provisions in the EU Treaties and Protocol 3 (on the Channel Islands and the Isle of Man) of the UK’s 1972 Treaty of Accession.112
Under Protocol 3, the Crown Dependencies were part of the customs territory of the EU and the common customs tariff, levies and agricultural import measures applied to trade between the Islands and non-member countries. Crown Dependencies used their domestic legislation to implement EU legislation falling within the parameters of this Protocol. Most other EU legislation did not apply.113
The Transition period ended on 31 December 2020, and Protocol 3 no longer applies. Observing standard Government policy on international treaties, the UK Government worked closely with the Crown Dependencies during the Brexit process.
As Lord Callanan explained in the House of Lords on 13 December 2018, although the UK Government was responsible for the Crown Dependencies’ international relations, Guernsey, Jersey and the Isle of Man would be responsible for passing their own Exit legislation:
This includes legislation which may be required to implement the Withdrawal Agreement in their jurisdictions. As the Prime Minister has made clear, the longstanding constitutional relationships between the UK and the Crown Dependencies will not change as a result of the UK’s decision to leave the EU.114
110 Ministry of Justice, Fact sheet on the UK’s relationship with the Crown Dependencies. The Isle of Man government told the Commons Justice Committee that the UK Government had, on occasion, “failed to leave adequate time for consultation on international treaties which are to be applied to it” (Justice Committee, Crown Dependencies, p10).
111 Justice Committee, Crown Dependencies, p10.
112 The Royal Commission on the Constitution heard serious concerns from the Crown Dependencies regarding the prospect of full membership of the then European Economic Community (see paras 1389-92).
113 Justice Committee, Crown Dependencies: developments since 2010, p10.
114 Lord Callanan, Brexit: Written question – HL11872, 13 December 2018.
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Managing the transition
A Lords European Union Committee report on Brexit and the Crown Dependencies noted “three intertwined, and potentially conflicting, priorities for the Crown Dependencies in the context of the Brexit negotiations”:
•	maintenance of their centuries-old constitutional relationship with the
UK;
•	retention so far as possible of the benefits of the existing relationship between the Crown Dependencies and the EU; and
•	the evolution of the Crown Dependencies’ international identities, while respecting the UK’s constitutional obligation to represent them in matters of defence and international relations.
The Committee also urged the Government “to support Guernsey and Jersey in their efforts to ensure that the UK’s [World Trade Organisation] membership is extended to cover them, as it already does the Isle of Man”.115 The UK’s WTO membership was extended to the Crown Dependencies with effect from 1 January 2021.
Customs arrangements
Each Crown Dependency also signed separate customs arrangements with the UK, which also took effect as of 1 January 2021.
The Customs and Excise (Amendment) Arrangement 2018 gave effect to specific provisions in customs arrangements between the UK and the Isle of Man to maintain a long-standing relationship once the Transition Period ended. This was given effect by the Crown Dependencies Customs Union (Isle of Man) (EU Exit) Order 2018. Similar agreements were negotiated and signed by Jersey and Guernsey.
Ian Gorst, Jersey’s Minister for External Relations, told the Commons Justice Committee that these arrangements helped ensure that a “constitutional relationship” built on “privileges, protocols and royal charters” continued “to be understood, respected and enhanced”.116
Trade and Co-operation Agreement
On 24 December 2020 the UK Prime Minister and the President of the European Union Commission announced agreement on a Trade and Cooperation Agreement (TCA) to take effect from 1 January 2021.
The Agreement included the Crown Dependencies in respect of goods and fisheries. In essence, EU vessels with a qualifying track record were to enjoy
115 Lords European Union Committee, Brexit: the Crown Dependencies, 23 March 2017, pp31-32.
116 Justice Committee, Oral evidence: Constitutional relationship with the Crown Dependencies, HC 595, 7 September 2021.
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continued access to Crown Dependency waters and vice versa. The TCA included a 90-day “cooling-off period” which would have allowed any of the Crown Dependencies to exit the Treaty if it wished.117
Subsequent Free Trade Agreements agreed between the UK and other states generally only included the Crown Dependencies for goods aspects, albeit with the possibility of later inclusion in services aspects.118
4.3	Letters of Entrustment
Guernsey, Jersey and the Isle of Man can sign specific international agreements if they have been authorised to do so by the UK, a process known as “Entrustment”. Letters of Entrustment have been issued in the case of Tax Information Exchange Agreements and other agreements relating to taxation that provide for exchange of information on tax matters between the Crown Dependencies and third countries.
A 2013 report from the Justice Committee proposed greater use of Letters of Entrustment. It said this:
could help mitigate the potential difficulties on occasions where the Crown Dependencies need to pursue interests which are separate from those of the UK.119
The same Committee urged the Ministry of Justice to:
work with the Crown Dependencies to develop expeditious arrangements to deal with Dependency access to Bilateral Investment Treaties, now that the UK has ceded competence for these to the EU.120
In September 2020, an Agreement on social security was agreed between the States of Guernsey and the Government of the Republic of Latvia. The Agreement was the first of its type to be negotiated and concluded by the States under entrustment from the UK.
4.4	International representation
In 2007-08, the then UK Secretary of State for Constitutional Affairs agreed “International Identity Frameworks” with each Crown Dependency. These
117 See Statement to be made by the Minister for External Relations on Sunday 27th December 2020
118 See, for example, the UK/Japan Agreement for a Comprehensive Economic Partnership which was presented to the UK Parliament in October 2021. This has been contentious. See Justice Committee, The constitutional relationship with the Crown Dependencies, para 41.
119 Justice Committee, Crown Dependencies: developments since 2010, p28. See also Justice Committee, The constitutional relationship with the Crown Dependencies, para 61.
120 Justice Committee, Crown Dependencies: developments since 2010, p29.
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were intended to clarify the constitutional relationship with regard to international relations.
The Frameworks include express acknowledgement that, in the context of the UK’s responsibility for the international relations of the Crown Dependencies, it is understood that:
•	the UK will not act internationally on behalf of the Crown Dependencies without prior consultation;
•	the UK recognises that the interests of the Crown Dependencies may differ from those of the UK, particularly in respect of the parties’ relationship with the EU;
•	the UK will seek to represent any differing interests when acting in an international capacity; and
•	the UK supports the principle of the Crown Dependencies developing further their international identities.121
The Justice Committee’s 2010 report observed that where the interests of the UK and the Crown Dependencies conflicted in international terms, “the insular governments have a sense that their interests will always be subordinate to those of the UK”.122 It therefore recommended that in:
cases of conflict, the Ministry of Justice must endeavour to find a mechanism for representation which will faithfully present and serve the interests of both parties.123
The UK Government, however, rejected this proposal, arguing that the Crown Dependencies were “not sovereign States and cannot represent themselves”:
We do not think that it would be appropriate for the Crown Dependencies’ position to be separately represented in international negotiations. It would be unrealistic to expect a UK official to put the interest of a Crown Dependency above that of the UK and in extreme circumstances this may hamper the ability of the UK to operate effectively on the international stage. Where international issues do engage the Crown Dependencies’ interests their views can be taken on board as the UK line is developed.124
Crown Dependencies, however, went on to engage in extensive bilateral and multilateral international activity. The Government of Jersey, for example, published a Global Markets Strategy for the 2020-23 period. This outlined its efforts “to broaden and deepen Jersey’s governmental, political and commercial relationships with priorityjurisdictions” outside the European Union.
121 See, for example, Framework for developing the international identity of Jersey.
122 Justice Committee, Crown Dependencies, p12. An earlier Justice Committee inquiry had examined UK representation of the Crown Dependencies during the Icelandic banking crisis.
123 Justice Committee, Crown Dependencies, p31.
124 Justice Committee, Crown Dependencies: developments since 2010, p25.
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4.5	Overseas offices
The Channel Islands Brussels Office was opened in 2011 to:
promote the interests of the Channel Islands in Europe, to represent the Channel Islands to the EU institutions, and to advise the governments of Guernsey and Jersey on EU policy issues.
The Isle of Man Government Brussels Office also opened in 2011 with a similar remit, while the Bureau des Îles Anglo-Normandes promotes the interests of the Channel Islands in France, especially regionally in Normandy and Brittany.
There is also a Government of Jersey London Office, but no equivalent for Guernsey or the Isle of Man.
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5
Useful websites and further reading
Isle of Man Government: www.gov.im
Isle of Man Parliament: www.tynwald.org.im
The States of Jersey: Jersey’s Constitution (Policy Centre Jersey)
Government of Guernsey: www.gov.gg
The States of Alderney: www.alderney.gov.gg
Sark Chief Pleas: www.gov.sark.gg
Royal Family: https://www.royal.uk/crown-dependencies
UK Government:
Crown Dependencies Team
International and Rights Directorate
Ministry of Justice
102 Petty France
London SW1H 9AJ
Email: crown.dependencies@justice.gov.uk
Publications
Darryl Ogier, The Government and Law of Guernsey, St Peter Port: States of Guernsey (3rd edition), 2025
Derek Winterbottom, Governors of the Isle of Man, Douglas: Manx Heritage Foundation, 1999
HMSO, Part XI: The Channel Islands and the Isle of Man, in Royal Commission on the Constitution 1969-1973 Volume I Report, Cmnd 5460, October 1973, pp405-66
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