New AIFM reporting obligation

New AIFM reporting obligation – CRE-IF Form to CySEC

On January 24th 2024, the Cyprus Securities and Exchange Commission (CySEC) issued Circular C617 to inform Investment Fund Managers like Alternative Investment Fund Managers (AIFM) about Recommendation 2022/9. The recommendation was published by the European Systemic Risk Board (ESRB) on the vulnerabilities in the commercial real estate sector in the European Economic Area (EEA) in December 2022.

The Recommendation aims to enhance the EEA financial sector’s resilience by overseeing, recognising and mitigating the vulnerabilities related to Commercial Real Estate (CRE) in institutions. Consequently, CySEC is tasked with:

  1. Identifying investment funds that have significant exposures in the CRE market.
  2. Observing and evaluating their current level of readiness for unexpected rises in redemptions or increased uncertainty in valuation.
  3. Developing an understanding of how these investment funds might react to potential adverse shocks.

Due to the above, CySEC introduces a new reporting requirement. All investment fund managers are required to complete and submit the newly introduced Form CRE – IF, via the CySEC Transaction Reporting System (TRS) by the below deadline:

Regulated entityDeadlineForm version
AIFM23rd of FebruaryForm CRE-IF

File naming convention:


Regarding the naming convention, the below are applicable:

  • ReferenceDate: denotes the end of the reporting period of the Form. In this case, the Form should have a 20230630 format yyyymmdd. Future forms will have different reporting periods.
  • OrgShortName: is the TRS code of the sub-fund/fund and should be the same as in cell D10 of Section Index of the Form.
  • SubmissionBasis: shall be empty.
  • FlowName: CRE-IF, the coding of the Form that remains unchanged and should be inserted exactly as it appears.
  • SubmissionDate: is the date of submission and should be of the format yyyymmdd.
  • SubmissionTime: is the time of the submission and should be of the format HHmm.
  • SubmissionNumber: shall have value 0 (zero).

As an Example of Name Convention:  20230630_AIF1__CRE-IF_20231213_1520_0.xlsx

It is highlighted that all investment fund managers are obliged to submit a separate Form CRE-IF for every sub-fund/fund under their management, authorised/registered by CySEC until the 30th of June 2023. The reference period for the completion of the Form is set to be between the 1st of January 2023 and the 30th of June 2023.

Further details for future submissions will be provided through another Circular.

For more regulatory obligations AIFM entities must meet in 2024, please visit the SALVUS Regulatory Reporting Obligations Calendar™.

Please contact us at compliance@salvusfunds.com if you require additional information or support with the submission of the CRE – IF Form; our Regulatory Compliance team is ready to support you.


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