Read the CySEC Circular C736
Memo #59-2025
CySEC Circular No: C736
Date: 27/10/2025
Subject: Observations and recommendations on the implementation of the prudential framework of Investment Firms
Purpose: To bring to the attention of the CIFs of a number of key observations arising from the CySEC's desk-based reviews and monitoring of compliance with the Law 165(I)/2021 and the Regulation (EU) 2019/2033.
In Summary:
CySEC has issued the Circular C736 on 24/10/2025 to bring to the attention of the Cyprus Investment Firms (CIFs), a number of key observations arising from the CySEC’s desk-based reviews and monitoring of compliance with the Prudential Supervision of Investment Firms Law (the ‘Law 165(I)/2021’) and the Regulation (EU) 2019/2033 on the prudential requirements of investment firms (the ‘IFR’).
The Circular C736 refers to key observations regarding:
A. Timely submission of prudential reporting.
B. Ongoing compliance with prudential requirements.
C. Inconsistencies of data.
D. Remuneration policies.
E. Establishment of Risk Committee and Remuneration Committee.
F. Internal governance.
G. Liquid assets.
H. Prudential consolidation.
I. Completion of Form 165-03.
Among others it refers to a number of inconsistencies identified, failure to comply with a number of requirements and policies implementation and not accurately complete a Section of the Form 165-03.
The CySEC notes that the CIFs are advised to undertake a comprehensive review of their practices in relation to the prudential framework, including reporting and governance processes, to ensure full compliance with the requirements laid down in Law 165(I)/2021, the IFR, the applicable Delegated Regulations and the EBA’s Guidelines.
The CySEC further notes that it will continue its supervisory monitoring and will take appropriate measures, including administrative sanctions, or implement other supervisory measures, as deemed necessary, in the event of non-compliance.
Read the CySEC Circular C736
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