Editorial Note: Andrew Rosindell MP, who is quoted below, was interviewed while in the Cayman Islands for the TCJ Forum in August 2026, a public forum funded and hosted by TCJ.

None of the Cayman Islands' 19 elected Members of Parliament has declared a gift, entertainment or hospitality on the Register of Interests, The Caymanian Journal (TCJ) found when it inspected the Register on 21 October.

The Register is kept by the Commission for Standards in Public Life. Under the Standards in Public Life Regulations, 2020, a member of the public may inspect it on request at the offices of the Commissions Secretariat in George Town, and may not photograph, photocopy, scan or otherwise reproduce any part of it, so TCJ's record of the inspection is a contemporaneous note. TCJ inspected the Register on the afternoon of Wednesday 21 October and checked the entries for the years covered by the current Parliament, which was elected in 2025. The declaration form prescribed by the Regulations asks each person in public life to complete the statement "I have received hospitality, gifts or entertainment each instance of which are set out below". That entry, Section J of the form, was blank or marked nil for every current elected member, on the Government and Opposition benches alike. The declarations of the Parliament's two ex officio members, the Attorney General and the Deputy Governor, which TCJ checked on the same visit, showed the same. TCJ first inspected the Register on 17 July and found the same position then.

Under section 11 of the Standards in Public Life Act, a person in public life must file a declaration within 90 days of taking office and a further declaration within 30 days after each 30 June, covering the previous year.

What the law requires

The Regulations set no value threshold. The threshold is in the Commission's Instructions for the Declaration of Interests, Assets, Income and Liabilities, published on its website as the 2025 instructions, which say under Section J: "Include any relevant gifts received during the reporting year." They continue: "Declarants shall include details of any gifts received which are valued at CI$100 or more", citing the Act and "the CIG Policy on Receiving Hospitality, Gifts and Entertainment". TCJ put the Instructions to the Commission on 2 September and asked for the statutory basis of the requirement and the consequences of failing to meet it.

In a written reply sent on 16 September by Lise Hurlstone, Acting Deputy Manager of the Commissions Secretariat, on the Commission's behalf, the Commission said the requirement rests on section 12(1)(k) of the Standards in Public Life Act, which requires a person in public life to include in a declaration "such other details as Cabinet may prescribe in regulations", and that the Standards in Public Life Regulations provide in section (j) of Schedule 1 and Schedule 2 "that declarants should provide details of hospitality, gifts and entertainment". The Commission said it "modelled the guidance for how to complete Section J from the Cayman Islands Government policy on receiving gifts, referred to as the Policy on Offering or Receiving Gifts and Hospitality, Personnel Circular 4 of 2017". Schedules 1 and 2 of the Regulations carry the hospitality, gifts and entertainment entry in the terms quoted above.

The Act does not itself list gifts or hospitality among the interests to be declared. Section 12(1) of the 2021 Revision covers shareholdings and directorships, contracts with public entities, investments, trusts, land, sources of income other than salary, loans and other substantial interests that raise or may appear to raise a conflict, and then, at paragraph (k), the details Cabinet prescribes by regulation. Section 16 makes it an offence for a person in public life to fail without reasonable cause to furnish a required declaration or to knowingly make a false one, punishable on summary conviction by a fine of CI$10,000, imprisonment for up to two years, or both, and no prosecution may be brought without the written consent of the Director of Public Prosecutions.

What the Commission says about omissions

A blank Section J shows only that nothing was declared under that heading. It does not by itself show that a declaration was required and withheld, and the Commission's reply draws that distinction. Asked whether an omission from an otherwise complete declaration could amount to an offence under section 16 of the Act, the Commission said: "Whether the omission of a detail from a Person in Public Life's (PiPL) declaration is considered to be an offence or not would depend on whether it is determined to have been done knowingly." The evidential or legal threshold it would apply, it said, "would be determined based on the circumstances of the matter at hand, and potentially any advice from an investigator or legal advisor engaged".

The Commission said it accepts complaints and reports of breaches of the Act from members of the public, usually on its complaint form, which may be submitted by hand or by email. The complainant's details are kept confidential unless the matter is referred onward. Initial assessment is done internally by the Commission's members, who may then conduct a confidential informal investigation or appoint an independent investigator. "In the event that the Commission is satisfied that a breach of the SPLA has occurred, or an offence has been committed, it will refer the matter to the RCIPS/DPP for determination of whether the matter will be pursued in the Courts," it said.

TCJ had asked the Commission to identify minutes that a member of the Secretariat's staff had referred to in an earlier conversation, which TCJ had understood to concern compliance by Members of Parliament. The Commission said the staff member's reference was to the general requirement for all persons in public life to comply with their Register obligations, and not to MPs specifically, and that the minutes in question were those of its meeting of 14 April 2026, which are published on its website.

Those minutes record that at the meeting, chaired by Mr Foster, the Commission's consultant, Sue Winspear, reviewed her analysis of Register of Interests declarations for the 2024 to 2025 period, and that members discussed writing to all Chief Officers "to remind them of their obligation to report gifts and hospitality in declarations", noting that the civil service circular on receiving hospitality, entertainment or gifts is available on the Government intranet. The same minutes record that members discussed "making access to the Register more public" against "rights of declarants to reasonable privacy", and agreed to retain the current access restrictions. The Manager also reported discussing with the Anti-Corruption Commission the use of one of its analysts "to assist with compliance reviews". The minutes do not refer to Members of Parliament.

The chairman and the review

The Commission's chairman, Woody Foster, was reported in October 2025 as telling a session on behaviour, ethics and standards at the Commonwealth Parliamentary Association's post-election seminar in the House of Parliament that the legislation needed "stronger teeth", that "I think the problem is there is no real accountability", that the Commission had "the power to fine people for not doing their register of interests, but the law, in fact, makes it difficult to do so", and that, "While I'm in the chair we are going to work to fix that." TCJ invited Mr Foster to say what shortcomings he had in mind and what had changed since.

The Commission replied that it "is currently in the process of considering amendments to the SPLA, and is in the public consultation stage", as announced in its Good Governance Campaign press release in July, and that, "Due to the current status of the potential amendments, Mr Foster has nothing further to add to the referenced comments at this time."

The press release, dated 14 July 2026 on the Commission's website, announced a year-long campaign and said that "a central feature of the campaign will be a public consultation on proposed amendments to the Standards in Public Life Act". The Commission's consultation page invites persons in public life and the public to give feedback on proposed amendments to the Act through an online survey. Neither the release nor the page gives a closing date, and neither publishes the text of the proposed amendments.

What the members say

TCJ put the position on the Register to more than one Cabinet minister in person in the course of its reporting. Each said they had not broken any rules and had nothing to declare under the gifts, entertainment and hospitality entry. TCJ has chosen not to name them. The entry is blank for members on both sides of the House, which makes this a cross-party matter rather than a partisan one, and naming the ministers who happened to be asked would single them out from colleagues whose declarations read the same.

Governor Jane Owen was asked about the Register at a press engagement on 18 September that TCJ attended on an unrelated matter and declined to comment.

What a seat at a gala costs

Tickets for the charity and business dinners held on Grand Cayman during the period covered by the inspected declarations were priced well above the CI$100 figure in the Commission's Instructions. The Cayman Islands Institute of Professional Accountants charged CI$225 a person, or CI$2,000 for a table of ten, for its awards gala at the Kimpton Seafire on 27 September 2025, according to its announcement carried by Radio Cayman. The Cayman Heart Foundation's Red Dress Ball at the Kimpton Seafire on 9 May 2026 was priced on the Foundation's website at CI$350 a person and CI$3,000 for a table of ten. The Cayman Islands Cancer Society's 30th anniversary casino night on 7 June 2025 was priced at CI$300 a person, the Cayman Heart Foundation's Heart Heroes brunch on 15 November 2025 at CI$400, and the Crisis Centre's Power of the Purse luncheon on 8 May 2026 at CI$325 to CI$350 a person, according to the organisers' own notices. Other organisers, including the Breast Cancer Foundation for its sold-out gala of 4 October 2025 at The Ritz-Carlton, the Green Tie committee and the Chamber of Commerce, did not publish a ticket price.

Members of the Government were at several of these events during the same period, according to the organisers and contemporaneous reports. Premier André Ebanks MP was "among the hundreds of attendees" at the Green Tie Gala at The Ritz-Carlton on 20 March 2026, which raised US$470,000 for the Cayman Islands Red Cross and The Bridge Foundation after matching by the R3 Cayman Foundation. The Premier spoke at the Chamber of Commerce's 60th anniversary Business Excellence Awards gala at the Kimpton Seafire on 15 November 2025, according to the Chamber's own account of the evening. Jay Ebanks MP presented an award at the Cayman Islands Tourism Association's Stingray Tourism Awards on 19 September 2025, Heather Bodden MP presented at the International Scuba Diving Hall of Fame dinner on 20 September 2025, the Premier addressed the Chamber's parliamentary luncheon on 23 October 2025, and Deputy Premier Gary Rutty MP spoke at the Stingray Tourism Awards on 9 May 2026, according to the organisers' accounts and contemporaneous reports. Those records show who was present and, in most cases, that the member was there to speak or to present an award. They do not show whether the member paid for a ticket, was the organiser's guest, or attended at the Government's expense, and none of those points can be read from the Register, which carries no entry under hospitality, gifts or entertainment for any of them. The Cabinet ministers TCJ spoke to said they had nothing to declare.

Two of the largest events of this autumn fall outside the inspected declarations. Premier André Ebanks MP and Deputy Premier Gary Rutty MP offered themselves for auction at the Breast Cancer Foundation's gala at The Ritz-Carlton on 3 October 2026, where the winning bidders will play pickleball against them, according to the Foundation's account carried by Radio Cayman, and the Premier appears in the accountants' institute's own photographs from its awards gala on 26 September 2026, which was priced at CI$275 a person on the institute's ticketing page. Under the Act, the declarations covering anything received after 30 June 2026 are not due until next July, so the absence of those events from the Register as inspected on 21 October shows nothing either way.

How other legislatures handle it

The Cayman Islands is one of several British Overseas Territories and Crown Dependencies with its own register, and the arrangements differ in two respects that matter here: the threshold and who can see the entries. The UK House of Commons requires Members to register "any gifts, benefits or hospitality with a value of over £300 which they receive from a UK source", within 28 days, in a register that is published electronically under the authority of the Committee on Standards. Bermuda's House of Assembly publishes its members' signed Register of Interests forms on the Parliament's website, with a section headed "Gifts, Benefits and Hospitality" that asks about any gift worth more than $500. In the Turks and Caicos Islands, a specified person in public life who receives a gift worth more than $1,000 must report it to the Integrity Commission under section 61(1) of the Integrity Commission Ordinance, and the members' register is made available for public inspection at the House of Assembly, the Office of the Premier, the Commission's offices and the District Commissioners' offices. Cayman's threshold of CI$100 is the lowest of the four, and its Register is the only one of the four that can be read solely in person and may not be copied.

The position at Westminster

TCJ asked the UK's Parliamentary Commissioner for Standards, Daniel Greenberg CB, for comment on the rules that apply to British MPs, and not on any Cayman case. He replied on 3 September on that understanding.

"Of the seven standards in public life (openness, accountability, honesty, integrity, objectivity, selflessness and leadership) openness is the pre-requisite without which none of the other principles can be applied; and it is the foundation-stone of trust between politicians and the public whom they serve," Mr Greenberg said. "The House of Commons Code of Conduct requires Members to register support and benefits that they receive, including gifts and hospitality, so that the public can make their own judgments about the objectivity and selflessness of individual politicians. The requirement to register benefits received, and to declare them in the course of relevant proceedings, ensures that any support is provided in a spirit of transparency and is not a covert attempt to buy influence or to exercise corruption."

Andrew Rosindell MP, who is registered as chair of the All-Party Parliamentary Group on the Crown Dependencies and British Overseas Territories, took a different view of the UK system when TCJ interviewed him during his visit for the TCJ Forum. Told that nothing had been declared under the gifts, entertainment and hospitality category of Cayman's Register, he said: "Well, this is news to me. I haven't studied the criteria that is used for declarations in the parliament of the Cayman Islands." He added: "Clearly, if the rules your parliament has adopted require members of parliament to declare certain amounts, visits, whatever it might be, then clearly if they should be declaring it by your own rules, then I don't know why that's not happening, but it's not something I'm able to comment on because I've not studied it or seen it."

On the UK's own regime, Mr Rosindell said it was right that MPs "should declare and not keep secrets" about international visits or anything that "costs money", but that the system had "got way over the top" and was being used "to personally attack and question the integrity of politicians". He said he would himself have to declare his visit to the Cayman Islands.

The Commission's reply of 16 September followed TCJ's questions of 2 September and a holding reply of 4 September, in which the Secretariat said four of the five questions "will require a bit more consideration on the part of the Secretariat/the CSPL".