CySEC CBRT Exercise & QST Form for CIF and ASP in Q4 2023
On December 22nd, 2023, the Cyprus Securities and Exchange Commission (CySEC) issued Circulars C610 and C611 to inform Administrative Service Providers (ASP) and Cyprus Investment Firms (CIF), respectively on the submission of the QST Form for the 4th quarter of 2023. On the same day, CySEC released Circular C612, to inform CIF regulated entities for the completion of the European Securities and Markets Authority’s (ESMA) Cross Border Data Collection Exercise, regarding cross border activity (CBRT) of investment firms for the year 2023.
All ASP and CIF regulated entities are required to complete and submit the latest versions of the QST Forms, via the CySEC Transaction Reporting System (TRS) of the below corresponding deadline
| Regulated entity | Deadline | Form version | Naming convention |
|---|---|---|---|
| ASP | 31st of January | QST-ASP Version 7 | Username_yyyymmdd_QST-ASP |
| CIF | 5th of February | QST-CIF Version 12 | Username_yyyymmdd_QST-CIF |
It is important to note that the definition of a client varies throughout the QST-CIF Form. CIF regulated entities should pay close attention to the instructions provided at the beginning of the form and in its various sections.
For each quarter, the cumulative reporting period begins at the start of the calendar year and ends at the final date of the reporting period.
Regarding the naming convention, the Username denotes the TRS credentials of the regulated entity and yyyymmdd the end date of the reporting period of the form.
QST forms are required to be completed in the English language and report data in Euro, rounded to the nearest unit. Regulated entities shall report the investment and ancillary services provided during the reporting period and not all the services prescribed in their license.
It is highlighted that the form must be submitted by all entities authorised by the 31st of December 2023, irrespective of whether they have made use or not of their authorisation.
Furthermore, in accordance with Circular C612, ESMA’s CBRT exercise is compulsory for all CIF entities authorised by the 31st of December 2023, which have at least 50 retail clients in at least one host member state.
It is emphasized that for this year, CIF entities must fulfil the exercise through the completion of an online questionnaire via EU’s online platform. For that purpose, at the current stage:
- CIF regulated entities that reach the materiality threshold of at least 50 retail clients, including clients categorised as elective professionals, in at least one host Member State except Cyprus, shall:
- provide a valid email address to riskstatistics.cifs@cysec.gov.cy, by the 29th of December 2023, and,
- ensure they receive an invitation link to the email provided to access and complete the online questionnaire.
- CIF entities that do not reach the materiality threshold, shall inform CySEC in riskstatistics.cifs@cysec.gov.cy by the 29th of December 2023, that shall be exempted from the exercise.
Further details on the completion of the online questionnaire, as well as the deadline of the CBRT exercise will be given through another Circular.
For more regulatory reporting obligations CIF regulated entities must meet in 2024, please visit the SALVUS Regulatory Reporting Obligations Calendar™.
Contact us via email at compliance@salvusfunds.com if you require additional information or support with the submission of the QST Form or the completion of the CBRT Exercise; our Regulatory Compliance team is ready to assist you.
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