The IFA Law applies to all persons offering fund administration services from or in Cyprus following the delegation of such duties by an investment fund or its manager.

UCITS Management Companies and Alternative Investment Fund Managers (AIFMs), established in Cyprus, are exempt from the provisions of the IFA Law. Persons providing valuation services in the course of their professional activities are also exempt, provided that they do not provide any other fund administration services.

• All IFAs must be licensed for the provision of fund administration services by the Cyprus Securities and Exchange Commission (CySEC).
• The provision of fund administration services or the use of certain terms (e.g. “fund administrator”) suggesting that a person is licensed as an IFA is prohibited without an IFA licence.
• The application process is heavily influenced by similar procedures under the existing regulatory regimes for AIFMs and Cyprus Investment Firms (CIFs).
• CySEC is required to inform applicants of its decision within six (6) months of the submission of a complete licensing application.
• Persons that, as of 18 June 2025 (i.e. the date of entry into effect of the IFA Law), exercised activities from or in Cyprus which fall within the subject to regulation under the IFA Law, were required to apply for a licence within two (2) months of such date, i.e. by 18 August 2025. Tied to this, persons that, as of 18 June 2027, do not have an IFA licence must cease providing fund administration services within two (2) months of such date

• IFAs are subject to strict regulatory requirements, in areas such as economic substance, governance, internal control and other related matters.
• IFAs must maintain their head office in Cyprus and at least two natural persons, who are permanent residents of Cyprus, must act as executive directors on the board of directors of the IFA.
• Screening and fitness and probity requirements apply with respect to the IFA’s directors and shareholders.
• Minimum initial capital requirements range between EUR 50,000 and EUR 125,000.
• A requirement for mandatory Professional indemnity insurance applies.
• Detailed requirements apply in the areas of governance, risk management, compliance and internal control, segregation of duties, conflicts of interest, business continuity, outsourcing, record keeping, reporting to CySEC, conduct of business rules and standards for providing specific fund administration services.

• CySEC is vested with oversight authority, including powers to collect information, carry out investigations and inspects, impose administrative measures and cooperate with other foreign authorities.
• CySEC may impose fines of up to EUR 350,000 per instance (or EUR 700,000 for repeat offenders) and may suspend or revoke an IFA’s licence.
• Separately, the provision of fund administration services without an IFA licence and non-compliance with certain other requirements under the IFA Law amount to criminal offences, punishable by a term of imprisonment of up to five (5) years or a fine up to EUR 700,000 or both.

The Investment Fund Administrators Law (only in Greek) can be found here

You can find our previous post on the enactment of the Law here