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Regulatory Alert: CySEC Circular C729 – QST-MC Quarterly Statistics (Q3 2025 Submission)

  • Antonis Hadjicostas
  • Sep 26
  • 1 min read
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Date of Issue: 26 September 2025


Applies to:

  • AIFMs (including Small AIFMs)

  • UCITS Management Companies & Internally Managed UCITS

  • Internally Managed AIFs (including AIFLNPs)

  • Companies managing AIFLNPs


📌 Key Points


  1. Form to Submit

    • Latest version of the form QST-MC Version 23 must be completed and submitted via the Transaction Reporting System (TRS).

    • Applies also to entities authorised/appointed as External Managers even if they have not yet used their authorisation.


  2. Deadline

    • Submission must be completed by 31 October 2025.

    • CySEC emphasises strict adherence – no reminders will be sent.


  3. Validation & Confirmation

    • Submissions are deemed successful only once a NO ERROR feedback file is received from TRS.

    • Entities must review and correct any errors before digitally signing and re-submitting.


  4. Counting UCIs & Sub-Funds

    • For reporting purposes, sub-funds count as separate UCIs.

    • Example: 1 UCI with 3 sub-funds = report as 3 UCIs.


  5. Technical Notes

    • Reporting must be in EUR (rounded to nearest unit).

    • File naming: USERNAME_20250930_QST-MC.xlsx

    • Only Excel 2007+ versions accepted.

    • Validation tests in all sections (A–M) must show TRUE (green).


  6. Support & Queries

⚠️ Implications for Regulated Entities


  • Non-compliance risk: Late or incorrect submission may trigger administrative penalties under section 37(5) of the CySEC Law.

  • Operational adjustments: Entities should ensure their reporting teams are aligned on the updated version (QST-MC v23) and validate files early to avoid last-minute technical issues.

  • Governance note: Boards and senior management should be aware of the deadlines and internal readiness to prevent regulatory breaches.


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