CySEC Circular 703: Reminder on website and marketing compliance obligations of CyIFMs
As digital platforms increasingly shape investor engagement, CySEC emphasises that CyIFMs must ensure their websites are transparent, accurate, and compliant with regulatory standards.
Key highlights
Requirement to maintain a website: UCITS Management Companies, Alternative Investment Fund Managers (AIFMs), or sub-threshold AIFMs—are generally required to maintain an official website. The content within the website must be fair, clear, non-misleading, and regularly updated with key investor documentation (KID).
Tailored obligations by investor type: The CyIFMs obligations will depend on the category of investor to which the funds they manage are addressed.
- Retail investors: Require the highest level of transparency, including detailed disclosures of packaged retail and insurance-based investment products (PRIIPs) KIDs and documentation regarding funds.
- Professional investors: Subject to exemptions which are applicable on specific disclosure requirements, marketing materials (including communications) must still meet fairness and clarity standards.
- Well-informed investors: Must be treated as retail clients for the purposes of marketing communications.
Regulatory disclosure requirements: CyIFMs must comply with multiple EU and national regulations, which include:
- Regulation (EU) No 1286/2014 on packaged retail and insurance-based investment products (PRIIPs Regulation)
- Regulation (EU) 2019/2088 on sustainability‐related disclosures (SFDR Regulation)
- Undertakings for Collective Investment in Transferable Securities Law of 2012 (UCITS Law)
- Alternative Investment Fund Managers Law of 2018 (AIFM Law)
Accountability for third-party websites: Where separate fund websites are used, the CyIFM remains fully responsible for compliance and must retain full administrative control.
Immediate actions required: CyIFMs are expected to:
- Review and update their websites for compliance by end of May 2025
- Ensure direct access to KIDs
- Establish an internal compliance process for ongoing review
- Report any website changes to CySEC via the Funds Portal within 10 days
For further clarification or assistance, CySEC invites firms to reach out via email at supervision.uci@cysec.gov.cy.
CySEC’s Circular 703 can be found here.
