Securitisation Jurisdiction Scorecard

JURISDICTION SCORECARD

Jurisdiction Scorecard – Gilderstone

A structured comparison of leading securitisation jurisdictions across the dimensions that matter most to originators, arrangers, and institutional investors.

Criterion —	Recommended 🇱🇺 Luxembourg EU securitisation hub	🇮🇪 Ireland EMEA CLO centre	🇰🇾 Cayman Islands Offshore classic	🇯🇪 🇬🇬 Jersey & Guernsey Crown dependencies	🇨🇭 Switzerland Private banking / EAM
Regulatory Framework	9.7	8.6	7.0	6.1	5.2
Rationale Luxembourg Dedicated 2004 Law with 2022 modernisation, purpose-built for securitisation Statutory compartmentalisation and non-petition rights codified in law CSSF provides regulatory certainty and Simple Transparent Standard competent authority status Ireland Section 110 framework is tax-driven rather than structurally purpose-built CBI as competent authority; strong EU regulatory standing Less flexible than Luxembourg for complex or esoteric structures Cayman Islands No dedicated securitisation statute; relies on general common law No statutory investor protections, segregation is contractual only Flexible but carries third-country friction for EU-facing mandates Jersey & Guernsey Common law frameworks with limited securitisation-specific legislation Not subject to EU Securitisation Regulation; NPPR required for EU access Separate legal systems (JFSC / GFSC) add complexity for cross-border work Switzerland No dedicated securitisation statute; SPVs use general company law Outside EU SecReg entirely, full third-country friction for EU investors 35% anticipatory WHT on note interest is a structural impediment
Investor Acceptance	9.7	9.0	7.6	6.5	6.2
Rationale Luxembourg One of the leading and most widely accepted jurisdictions for EU institutional investors LuxSE / Euro MTF listing; straightforward Euroclear and DTC eligibility CSSF framework provides a highly recognised and trusted regulatory backdrop among EU institutional investors Ireland Highly accepted by EU and global investors, with market-leading strength in CLOs and securitisation (ABS) structures Euronext Dublin is a leading venue for debt listings, supported by strong regulatory credibility from the Central Bank of Ireland Marginally lower than Luxembourg for non-CLO structures Cayman Islands Accepted for rated ABS; as a non EU jurisdiction, some EU investors may apply additional internal due diligence DTC eligibility requires additional legal analysis case by case Strong acceptance from US and Asia-Pacific investors Jersey & Guernsey Comfortable for UK and Crown dependency investors; EU acceptance variable TISE or LSE listing; DTC eligibility assessed case by case As non EU jurisdictions, Jersey and Guernsey sit outside EU regulatory passporting frameworks Switzerland Strong niche acceptance among Swiss private banks and EAMs Limited EU institutional appetite due to non-EU status SIX Swiss Exchange listing well-developed domestically only
Structural Flexibility	9.3	7.4	8.6	7.1	7.4
Rationale Luxembourg Statutory compartmentalisation enables unlimited multi-deal vehicles Draft legislation has been proposed in relation to Active Management of all asset classes (Jun-26) Broadest asset class scope: loans, RE, derivatives, digital assets etc Ireland Section 110 regimes are typically structured for income-generating assets; highly active trading strategies can introduce tax and substance challenges Contractual segregation only no statutory compartmentalisation Strong for vanilla financial assets; less common for highly bespoke or emerging asset classes Cayman Islands Highly flexible no regulatory constraints on active management SPC structure provides statutory segregation via separate cells Preferred for discretionary strategy referencing; EU overlay required Jersey & Guernsey Locally unconstrained, but AIFMD applies where EU marketing or investors are involved Protected Cell Companies available Well-established in structured finance and alternative assets Switzerland No AIFMD applicability; discretionary management readily available Leading hub for structured products and derivatives issuance No statutory compartmentalisation each deal needs a separate SPV
Operational Ease	8.0	8.6	9.0	7.9	6.6
Rationale Luxembourg Deepest global ecosystem: specialist law firms, trustees, paying agents New SPV takes 3–6 weeks depending on complexity; subsequent compartments deployed in days CSSF experienced and predictable; no WHT on interest to non-residents Ireland Strong CLO administration ecosystem; 2–4 week formation timeline No Irish withholding tax on interest paid to qualifying non-resident investors, subject to standard Section 110 conditions Excellent service provider depth, particularly strong in CLOs and structured credit transactions Cayman Islands Fastest formation, 1–3 weeks; lightest regulatory overhead No WHT; well-developed offshore provider infrastructure EU distribution requires structural overlay, adding cost and time Jersey & Guernsey 2–4 week formation; no WHT on note interest Good service provider depth across both funds and structured finance NPPR registration adds operational overhead for EU distribution Switzerland 3–6 week formation; timelines often driven by bank account opening and structuring complexity 35% anticipatory WHT creates significant cash flow friction on notes Securitisation SPV administration thinner than Zurich private banking depth
Product Breadth	9.7	7.4	7.0	5.6	6.8
Rationale Luxembourg Widest asset class coverage: corporate loans, RE, trade receivables, digital assets 2022 law reform clarified and enhanced flexibility, Bill of Law No. 8761 should provide further benefits (Jun 2026) Most comprehensive recent legislative refresh among European securitisation hubs Ireland Strong for financial assets and leveraged loans; dominant in CLOs Less used on equity-linked and esoteric asset classes due to tax and structuring complexity Less commonly used than Luxembourg for multi-asset or hybrid strategies Cayman Islands Very broad asset class acceptance with no statutory restrictions Preferred for discretionary and fund-linked strategies EU-facing distribution requires more complex structuring Jersey & Guernsey Broad asset class capability with strong use in alternative credit, infrastructure and insurance-linked structures Best suited to UK-facing mandates; more operationally complex for EU distribution No direct access to EU AIFMD marketing or loan origination frameworks without an EU AIFM structure Switzerland Strong track record in structured products and equity derivatives Natural fit for EAM-linked AMC notes via Swiss bank channels EU distribution and passporting require parallel EU-compliant structures or AIFM arrangements
Overall Score	46 / 50	41 / 50	39 / 50	33 / 50	32 / 50

Overall Assessment

Scored across five dimensions: regulatory framework, investor acceptance, structural flexibility, operational ease, and product breadth. Maximum 10 per criterion, 50 total.

Scores reflect Gilderstone’s assessment based on current regulatory position and market practice.

Jersey & Guernsey presented as a combined Crown dependency score (average of individual assessments).

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