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CySEC Circular C754: What CIFs Need to Know About the 2025 Cross-Border Reporting Requirement

  • Antonis Hadjicostas
  • Feb 9
  • 1 min read

Updated: Feb 10

The Cyprus Securities and Exchange Commission (CySEC) issued today its Circular C754, introducing a targeted electronic cross-border reporting obligation for Cyprus Investment Firms (CIFs). The circular focuses on CIFs that provided cross-border investment services to retail clients in other EEA Member States during 2025.


This development aligns with broader EU supervisory efforts to strengthen oversight of cross-border activities and enhance data consistency across Member States.


Who Is in Scope?


The requirement applies to CIFs that, between 1 January and 31 December 2025, provided investment services on a freedom to provide services (FPS) basis to more than 50 active retail clients in at least one EEA Member State.

Important clarification:“Retail clients” also include clients treated as professionals on request under MiFID II (opt-up clients). This means some firms may fall within scope even if their client base is not traditionally retail-focused.

What Is Required?


In-scope CIFs must participate in an electronic questionnaire hosted on a dedicated EU reporting platform. The questionnaire will collect structured information on cross-border activities, enabling competent authorities to better assess scale, impact, and potential risks arising from such services.


Immediate Action Required & Deadlines


By Wednesday, 18 February 2026, all CIFs must take one of the following actions:


  • If in scope:Email riskstatistics.cifs@cysec.gov.cy with a generic company email address (e.g., compliance@, info@). CySEC will then send the link to the electronic questionnaire.

  • If not in scope: Formally notify CySEC at the same email address that the firm does not meet the threshold (i.e., fewer than 50 active retail clients in any EEA Member State).


Failure to respond whether in scope or not may be treated as non-compliance.

 
 

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