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Significant changes to trademark law in Jersey will come into effect on 1 August 2026. This reform alters the way trademark rights can be obtained and protected on the island of Jersey, a self-governing British Crown Dependency in the English Channel, as Volha Parfenchyk explains.
Located between England and France, the island of Jersey (the largest of the Channel Islands) maintains its own distinct identity, despite its historical and constitutional links to the British Crown. For that reason, trademark law and practice in Jersey has traditionally been linked closely to that of the UK. However, this is all set to change as of 1 August 2026.
Trademark protection in Jersey today
Typically, a trademark is protected in Jersey via:
- A national UK trademark registration, extended to Jersey through the existing registration system (“re-registration"); or
- An international registration (IR) designating the UK, which automatically extends protection to Jersey.
What changes on 1 August 2026?
This arrangement will end on 1 August 2026 with the entry into force of the Trade Marks (Jersey) Law 2026.
The new law represents a major modernisation of IP law in Jersey. Instead of relying on UK trademark registrations, Jersey will establish its own fully independent trademark system. From 1 August 2026, trademark applications will be examined and registered under Jersey law, creating an independent registration system separate from UK trademark law.
The most significant practical consequence of the reform is that trademark protection in Jersey will no longer be obtained through new national UK trademark registrations. Instead, businesses seeking to secure trademark rights in both territories will need to apply for protection separately in each jurisdiction.
The reform also affects users of the Madrid System for the international registration of trademarks. From 1 August 2026, an International Registration (IR) designating the UK will no longer automatically provide protection in Jersey. Therefore, applicants wishing to obtain protection in Jersey will need to designate Jersey separately.
Implications for existing trademark rights
The transition to the new system is designed to ensure that existing rights are preserved. UK trademarks already registered in Jersey prior to the new law coming into effect will be automatically transferred to Jersey’s new national trademark register.
The same applies to international registrations designating the UK. The World Intellectual Property Organization (WIPO) will automatically record a separate designation of Jersey for the relevant international registration. From that point on, the designations for the UK and Jersey will coexist as independent territorial designations.
As a result, trademark holders who already have protection in Jersey do not need to take any action.
What does this news mean for future trademark applicants?
For companies with commercial activities or interests in both the UK and Jersey, it may be advantageous to extend their existing UK registrations to Jersey before 1 August 2026. Doing so allows trademark owners to avoid the substantive examination, opposition proceedings and official fees that will apply under the new system for Jersey. They may also consider designating the UK in an existing International Registration (IR) before 1 August 2026.
From 1 August 2026, Jersey will be considered a separate jurisdiction for trademark protection. When developing an international filing and enforcement strategy, Jersey will need to be assessed separately, distinct from both the UK and the EU.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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