How much will GST cost for the civil service and businesses to implement?
It’s a simple question, and one you’d hope Policy and Resources (P&R) has looked at, given the last States voted to adopt it in 2024 and the current P&R committee has recommended GST as part of its latest tax reform package – with a States vote due in July.
So – in the spirit of doing robust journalism – Express asked them and sent in a Freedom of Information Act (FOI) request.
Nearly two months later we got an answer – effectively ‘look it up yourself’.
Specifically, the FOI response said: “The Policy & Resources Committee lodged the Tax Reform 2026 Policy Letter on 8th June 2026 which provides the information requested.”
However, after looking at the policy letter for a considerable amount of time – including with the assistance of AI to check we weren’t missing anything – we’re unconvinced it does fully answer the questions we posed.
In a nutshell
Express asked the States a series of questions about GST implementation costs and submitted an FOI request.
It responded nearly two months later, telling us the answers were in the tax reform policy letter published by P&R on Monday 8 June 2026 – in other words to look it up ourselves or ask our readers to.
We looked, and we don’t think all of them are.
For example, P&R’s letter does give overall costs for the civil service to implement GST, but not appear to do the same for businesses.
Likewise, it appears we haven’t been told how much was spent on external consultants to help prepare with the plans.
We believe it’s important to ask tough questions on behalf of our readers and to follow them up when we don’t get the answers we think you deserve.
So below we’ve set out:
- The questions we asked
- An overview of the States’ legal obligations under the FOI
- A timeline of events
- An overview of what the head of the civil service has said about transparency
- Why we haven’t gone through the formal FOI appeals process
- Questions we can answer – where can to using the tax letter or other publicly available information – including previous Express interviews
- The questions we believe are still unanswered
For more, READ ON…
What did we ask?
We asked questions to the States in 13 key areas:
1. Civil Service Implementation Costs
- Has any study, estimate, or internal assessment been conducted on the cost to the States of Guernsey of implementing GST?
- If so, what is the estimated total cost, including (but not limited to) IT systems, software upgrades, consultancy, additional staffing costs, and administrative changes?
- If so, please provide a high-level breakdown of the costs, by category.
2. IT and Systems Changes
- Has any study, estimate, or internal assessment been conducted regarding the cost of updating or replacing government IT systems to support GST?
- If so, please provide the estimated cost.
3. Staffing Requirements
- Has any study, estimate, or internal assessment been conducted regarding the number of additional Civil Service staff required to support and administer GST, including but to [sic] limited to additional Revenue Services staff?
- If so, how many additional staff are expected to be required within Revenue Services or other departments to administer GST?
- If so, what is the estimated ongoing annual staffing cost associated with these roles, including recruitment costs?
- If so, what is the estimated one-off recruitment and training cost, including averaged relocation packages?
4. Costs to Businesses
- Has any study or estimate been made of the cost to local businesses of implementing GST, including accounting systems, software updates, compliance, and administrative burden?
- If so, what is the estimated total cost to businesses?
5. Impact on Prices / Inflation
- Has any modelling or analysis been undertaken on the expected impact of GST on consumer prices?
- If so, what is the estimated percentage increase in prices or inflation attributable to GST?
6. Break-even Analysis
- Has any analysis been conducted on when GST revenues are expected to offset the full costs of implementation and administration?
- If so, what is the projected timeframe for GST to become net revenue-positive?
7. Ongoing Administrative Costs
- What are the projected annual operating costs of administering GST once fully implemented?
8. Economic Impact Assessments
- Have any wider economic impact assessments been conducted (e.g. effects on consumption, business activity, or competitiveness)?
- If so, please provide summaries or copies of these assessments.
9. Knock-on Costs to the Public Sector
- Has any assessment been made of indirect or secondary costs to the States arising from GST (for example increased procurement costs due to GST on goods/services purchased by the public sector, impacts on wages, pensions, or benefits linked to inflation)?
- If so, please provide estimated figures and any supporting analysis.
10. Knock-on Costs to the Wider Economy
- Has any analysis been conducted on secondary economic impacts, including reduced consumer spending, changes in tourism behaviour, cross-border or online purchasing, or business closures?
- If so, please provide details and estimates.
11. Compliance, Enforcement, and Non-Compliance Costs
- What estimates have been made regarding the cost of compliance monitoring, audits, enforcement activity, and potential revenue loss from evasion, avoidance, or bad debt?
12. Comparison with Other Jurisdictions
- Has any comparative analysis been conducted with jurisdictions of similar size or structure (e.g. Jersey, Isle of Man, or other small economies) regarding:
- Implementation costs
- Administrative burden
- Economic impact
- If so, please provide copies or summaries of this analysis.
13. Consultancy and External Advice
- What is the total estimated amount spent, or budgeted, on external consultants, advisers, or third parties in relation to the design, modelling, or implementation planning of GST?
Is the States allowed to respond this way?
Yes.
Guernsey has an FOI code which, according to the States website, “gives Bailiwick residents the right to access information held by the States of Guernsey”.
The website says the code is “designed to make government more accountable and transparent in the way it operates and makes decisions”.
However, while the site may claim residents – including journalists – have a “right” to access information, the code is “non-statutory” – meaning it’s not legally binding.
Additionally, within the code the States is allowed to refuse to answer all or part of the questions under certain limited circumstances.
Examples include if answering could:
- compromise confidential commercial arrangements
- break another law or international treaty
- compromise national security
- compromise legal proceedings
- impact the privacy of an individual
- or if the person asking for information has made “voluminous or vexatious” requests – eg. if the States thinks they’re sending too many requests or they’re sending frivolous or unreasonable FOIs
The States also doesn’t have to “provide information which is already published”.
The States has not refused to answer, but simply referred us to a published document.
However, as we’ve argued in this article we do not believe it fully answers our questions – and it certainly doesn’t do so in an easy to follow, accessible way.
Additionally, the document was published more than seven weeks after our original enquiry, and more than five weeks since we were asked to resubmit our FOI.
So – we would argue – there’s a question over the tax policy letter was “already published”.
Our unanswered questions could have been looked at while the tax policy letter was being prepared and either incorporated into it or given separately as supplemental answers.
The States’ website says anyone submitting an FOI “should typically receive a response within 20 working days” – however in 2024 this happened in just 42% of cases.
If the FOI can’t be completed within 20 days, the States should let the requestor know why the answer will take longer.
This did happen in our case, though only the day before the response was due.
Timeline of events
The States of Guernsey has a PR team within the civil service known to the media as States Comms (officially the States Communications Team).
It sends out press releases to the media on everything from new tax proposals to adult cycling courses – all of which are also published on the States website’s news section, as well as performing other duties like arranging ‘press calls’ and other events.
States Comms also deals with enquiries from the media, such as requests to interview Deputies, official comments from committees, and information and data.
While the members of the media do sometimes approach Deputies and senior civil servants directly, States Comms usually prefers we go through its team so it can co-ordinate things, provide guidance to them on messaging, and to ensure it’s aware of the stories we’re about to run.
On 18 April Express emailed our questions to States Comms.
This is something we – and our colleagues in other media outlets – have done many times before, we deal with States Comms on a daily basis – and it keeps them in the loop on stories we may run off the back of any questions.
Also, it gives States Comms the opportunity to answer the questions directly if they have the information readily available – saving other civil servants time.
States Comms will then often ask us to formally raise an FOI through a different email as this is the official process – though it is usually still involved in the process of compiling them and communicating with us.
Express replied all to our previous email, to check if somebody had picked it up.
A senior civil servant within States Comms responded to say: “Really sorry but this wasn’t picked up as FOIs aren’t accepted through the pressroom email.”
They added: “I normally advise media against submitting FOIs, as you can just ask the comms team via a normal media enquiry in the vast majority of cases.
“But having had a quick look at your questions there are so many and it’s largely data driven that an FOI is probably the right route.”
We forwarded the original FOI to the official FOI email address and got a response shortly afterwards, confirming they’d received it.
As we’d resubmitted the FOI, the 20 day period meant we should typically expect the response on or before 2 July.
We sent a follow-up email to the FOI request email address, checking if we were likely to receive the response by 2 July.
We didn’t receive a response by email.
Express received a phone call from the same senior civil servant who had replied on May 5, telling us that we would be receiving the FOI response 1 week late, on 9 June.
The reason given to us was that civil servants were busy preparing the Tax Reform Policy Letter, which was taking up their time.
The senior civil servant also explained that there was a large crossover with the work to prepare the policy letter and with our questions, so responding to the FOI after they’d finished the letter would save them significant amounts of work.
Express agreed that this was acceptable and made sense – as we don’t want to create unnecessary extra work for civil servants.
We asked for confirmation that we could expect the FOI response on 9 June, explaining that we needed to know to help plan our news output.
We were assured we would receive the response on that day, which would have meant a 25 working day turnaround from when the official FOI was sent, and 37 from when we first emailed States Comms.
On 9 June we didn’t get sent the FOI response, despite being told the week before we’d have it by this date.
We sent the following: “Hope you’re well. I realise it’s been a busy week with all the tax stuff, but just wanted to check the ETA on this FOI, as when we spoke last week I believe it was expected today.
“Just so we can plan the rest of the week.”
We had no response to this email.
We received an email with the FOI response, “on behalf of” P&R.
It simply said: “The Policy & Resources Committee lodged the Tax Reform 2026 Policy Letter on 8th June 2026 which provides the information requested.
“The policy letter can be accessed by the following link Tax Reform 2026.”
The States had not published the response on the FOI section of its website at the date this article was published, but you can read the FOI response here.
As you’d expect we looked over the Tax Reform Policy Letter in detail to see if we could find the answers to our questions.
We also used AI to help us find the answers, in case we’d missed anything.
Based on this analysis, we believe our questions were not fully answered.
We would also argue that the information in the letter that did help partially answer our questions was not in an easy-to-follow format that a layperson could readily understand.
Head of civil service pledges transparency
Last week the head of Guernsey’s civil service told a Chamber of Commerce event that more openness and scrutiny would be key to rebuilding public trust, as he promised a “warts and all” assessment of government projects.
Boley Smillie, Chief Executive & Head of the Public Service, argued that greater transparency would help prevent problems escalating, adding that “sunlight” was often the best way to drive improvement.
Speaking to Express after the event, he said: “My experience tells me that scrutiny – that sunlight we apply to the challenges – generally results in actions that deal with issues much sooner before they become bigger problems.”
Express showed him the FOI request – which we had received two days earlier – and asked him if he felt it demonstrated “transparency”.
He told us that he wasn’t aware of the FOI and hadn’t had a chance to read the questions or understand whether the tax policy letter answered them.
However, he promised to “take that away and have a look and get back to you with a proper response”.
Why haven’t we gone through the FOI appeals process?
Time.
The States is due to debate and vote on the latest proposals in July – so a decision could be made in fewer than 5 weeks.
If we go through the official FOI appeals process it is likely our answer would come after the debate in July.
Getting the actual answers is likely to take longer still.
This would mean neither Deputies nor members of the public would get the answers to our questions before it matters.
Which wouldn’t give the public the “transparency” Mr Smillie has called for.
That’s why we’re publishing the response ‘as is’ – and it’s why we’re going to do our best to pull together some answers for you anyway.
What questions can we answer?
While we don’t believe the tax policy letter adequately answers our questions, we still owe it to our readers to try to answer them where we can – either from the letter or elsewhere.
Here’s what we can say:
1. Civil Service Implementation Costs
P&R has clearly undertaken implementation planning and cost estimation work.
The policy letter does not make clear whether this was based on a standalone formal study, internal modelling, or both.
The policy letter puts total implementation costs at between £8.65m and £12.2m, with £1.6m already spent. Deputy Lindsay de Sausmarez, P&R President, told Express the upfront cost would be about £10m.
These costs are broken down into broad categories across two tables in the report—covering one-off implementation projects like GST setup (£3.6m–£6.1m) and Tax/Social Security changes (£1.3m–£1.85m).
2. IT and Systems Changes
There is evidence that work has been done to scope government systems, suggesting some level of IT assessment.
However, no standalone IT assessment or business case appears to be published.
A standalone estimate for ongoing IT systems licensing, support and development is provided at £200,000 to £600,000 per year
3. Staffing Requirements
Revenue Services will need six more people and Customs and Immigration Service will need 10.
This will cost an extra £1.1m to £1.7m a year.
4. Costs to Businesses
The policy letter recognises that GST will create costs and complexity for local businesses.
It includes a £1.1m support package for businesses to adopt new systems and processes, but we have been unable to identify any estimate of the total cost to businesses of implementing GST.
5. Impact on Prices / Inflation
P&R has modelled the impact of GST on inflation at a headline level.
It estimates a 3% GST would increase inflation by around 1.9%, compared to an earlier estimate of 3.2% with GST at 5%.
6. Break-even Analysis
The letter explains how GST would contribute to closing the funding gap.
The wider reform package is expected to raise around £39m a year in net ongoing revenue against the structural deficit, meaning GST would break even within 4 months.
7. Ongoing Administrative Costs
The policy letter estimates ongoing administration will cost around £2.5m a year, the same figure given by Deputy de Sausmarez.
8. Economic Impact Assessments
P&R says it has undertaken analysis of how GST could affect the economy, including impacts on consumption, business activity and competitiveness.
It provides some high-level figures, including overall revenue estimates – such as around £30m net from GST and around £50m from the wider tax package – as well as the inflation estimate of 1.9%.
However, this is presented as headline modelling rather than a detailed assessment. Most wider economic impacts are described in broad terms, without sector-by-sector figures.
9. Knock-on Costs to the Public Sector
P&R acknowledges wider public-sector impacts and includes provision for higher benefits and pensions to reflect GST-related inflation.
However, we have not identified quantified estimates for indirect costs such as procurement inflation or public-sector wage pressures.
However, it does not quantify the full knock-on costs to the public sector.
10. Knock-on Costs to the Wider Economy
The letter considers potential impacts like changes in spending, competitiveness and business behaviour.
But it does not provide firm estimates of effects such as reduced demand or business closures.
11. Compliance, Enforcement, and Non-Compliance Costs
There is recognition that GST will create compliance and administrative burdens.
However, there are no clear estimates for enforcement costs or revenue loss from non-compliance.
12. Comparison with Other Jurisdictions
The policy letter makes some comparisons with places like Jersey and OECD countries, including how tax systems differ.
But it does not provide a structured comparison of costs and impacts across jurisdictions.
13. Consultancy and External Advice
Modelling and analysis have clearly taken place to put together the letter.
The policy letter refers to analysis undertaken during the tax review process and references work by Deloitte and input from external experts.
However, we have not identified any figure showing how much was spent on consultants, advisers or third parties.
Which questions remain unanswered?
We believe several of our questions were either answered or can be inferred from the policy letter, there are many more that are only partially answered or are not answered at all.
| Question | Status | Have | Don’t have |
|---|---|---|---|
| 1. Civil Service Implementation Costs | |||
| 1a. Study/assessment on implementation costs? | Answered | ||
| 1b. Total implementation cost? | Answered | ||
| 1c. Cost breakdown by category? | Partly Answered | High-level breakdown across programme areas with cost ranges | Category-level breakdown (‘IT’, ‘Staffing’, ‘Consultancy’ etc) |
| 2. IT and Systems Changes | |||
| 2a. IT/system assessment? | Partly Answered / Inferred | System scoping, procurement prep | Formal IT study, findings, recommendations |
| 2b. IT cost estimate? | Answered | ||
| 3. Staffing Requirements | |||
| 3a. Staffing assessment? | Answered | ||
| 3b. Number of staff required? | Answered | ||
| 3c. Annual staffing cost? | Answered | ||
| 3d. Recruitment/training costs? | Not Answered | ||
| 4. Costs to Businesses | |||
| 4a. Business cost assessment? | Partly Answered | Business burden recognised, £1.1m support package | Formal study, quantified costs |
| 4b. Total business cost? | Not Answered | ||
| 5. Impact on Prices / Inflation | |||
| 5a. Inflation modelling? | Answered | Headline modelling, GST impact (~1.9%), policy adjustments | |
| 5b. % inflation impact? | Answered | Estimated inflation effect (~1.9%) | |
| 6. Break-even Analysis | |||
| 6a. Break-even analysis? | Answered | ||
| 6b. Time to net positive? | Answered | ||
| 7. Ongoing Administrative Costs | |||
| 7a. Ongoing admin costs? | Answered | ~£2.5m annual cost identified | |
| 8. Economic Impact Assessments | |||
| 8a. Economic impact assessment? | Answered | High-level modelling (such as inflation and revenue figures) and discussion of impacts on consumption and competitiveness | |
| 8b. Copies/summaries? | Partly Answered | Policy letter contains summaries of some economic modelling. | Does not provide full summary coverage. |
| 9. Knock-on Costs to the Public Sector | |||
| 9a. Public sector knock-on costs? | Partly Answered | The letter promises £1m annual provision to cover inflation-linked benefit and pension increases. But it doesn’t have information on indirect costs of higher government procurement or public sector wage pressures. | Quantified indirect costs |
| 9b. Supporting analysis? | Not Answered | ||
| 10. Knock-on Costs to the Wider Economy | |||
| 10a. Wider economy knock-on costs? | Partly Answered | Behavioural impacts, competitiveness risks | Quantified estimates (closures, spending changes) |
| 10b. Details / estimates? | Not Answered | ||
| 11. Compliance, Enforcement and Non-Compliance Costs | |||
| 11a. Compliance/enforcement costs? | Not Answered | Compliance burden, admin implications discussed | Audit/enforcement cost, tax gap estimates |
| 12. Comparison with Other Jurisdictions | |||
| 12a. Comparisons with other jurisdictions? | Partly Answered | Jersey/OECD comparisons, structural context | Full structured comparative analysis |
| 12b. Copies/summaries? | Not Answered | ||
| 13. Consultancy and External Advice | |||
| 13a. Consultancy/external spend? | Not Answered | Expert input, consultation, modelling implied | Confirmation or total consultancy spend figure |
