CySEC Issues Circular C754: CIF – Cross-Border Data Collection Exercise
On 9th of February 2026, the Cyprus Securities and Exchange Commission (CySEC) released Circular C754, addressed to Cyprus Investment Firms (CIFs), relating to the Electronic Cross-Border Form and the reporting of investment services and activities provided on a freedom to provide services basis.
Key points of Circular C754:
1. Scope of the Cross-Border Data Collection Exercise
CySEC informs CIFs that the cross-border online questionnaire must be completed by firms that:
- Were authorised by 31 December 2025, and
- Provided cross-border investment services to more than 50 active retail clients in at least one host Member State of the European Economic Area (including Norway, Iceland, and Liechtenstein), during 2025.
For the purposes of this exercise, “retail clients” also include clients treated as professionals on request, in accordance with Section II of Annex II of MiFID II.
2. Reporting Period and Reference Date
The information to be reported through the electronic questionnaire refers to:
- Reporting period: 1 January 2025 – 31 December 2025
- Reference date: 31 December 2025
Only services provided on a freedom to provide investment services and activities basis should be included. CIFs must exclude services provided under a freedom of establishment basis.
3. Treatment of Inactive Clients
CIFs are required to exclude inactive clients from their reporting. Clients are considered inactive only if all of the following conditions are met:
- Inactivity lasted for at least one year,
- No investment or ancillary services were provided during that period, and
- The CIF no longer receives any form of revenue from the client.
If a CIF continues to receive remuneration from a client (e.g., account maintenance fees), such clients must be included in the reporting.
4. Assessment of Cross-Border Activity
CIFs may use the residence of clients to assess whether investment services and activities are provided in other Member States. Firms must consider all relevant criteria when determining whether they fall within the scope of the exercise.
5. Notification to CySEC and Submission Process
CIFs that fall within the scope of the exercise must provide a single valid company email address (e.g., compliance@…, info@…) to CySEC, by sending an email to riskstatistics.cifs@cysec.gov.cy by Wednesday, 18 February 2026.
CySEC will forward the link to the cross-border electronic form only to CIFs that meet the materiality threshold.
CIFs that do not meet the threshold of more than 50 active retail clients in at least one host EEA Member State must likewise inform CySEC by 18 February 2026 that they are not required to complete the form.
6. Further Instructions
CySEC notes that detailed instructions regarding the completion of the electronic form, as well as the submission deadline, will be communicated via a subsequent Circular.
Failure to comply promptly and duly with the requirements of Circular C754 may result in administrative penalties under section 37(5) of the CySEC Law. CySEC also clarifies that no reminders will be issued to CIFs that fail to comply.
Contact us at compliance@salvusfunds.com if you have any questions or require support to ensure compliance with Circular C754. We are always ready to answer your questions and support you in achieving regulatory compliance.
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The information provided in this article is for general information purposes only. You should always seek professional advice suitable to your needs.