Nicosia, Cyprus. The Cyprus Securities and Exchange Commission (CySEC) issued a circular requiring certain Cyprus Investment Firms (CIFs) to complete a new electronic cross-border reporting form for their 2025 activities across the European Economic Area.
ESMA exercise and scope
The circular forms part of an exercise initiated by the European Securities and Markets Authority (ESMA). It is addressed to all investment firms providing services in member states of the European Economic Area, including Norway, Iceland and Liechtenstein, other than their home Member State during 2025.
Reporting process and template changes
As in the previous year, the process will be conducted through an EU online platform in the format of an electronic questionnaire. ESMA introduced technical improvements to this year’s reporting template, particularly regarding the collection of data on cross-border activity carried out under the freedom to provide investment services and activities.
Focus on retail clients and host member state data
The updated template places emphasis on services provided to retail clients, including clients treated as professionals on request under Section II of Annex II of MiFID II, with data to be analysed for each host Member State. For the purposes of the exercise, retail clients include those treated as professionals on request under the relevant MiFID II provisions.
Which firms must complete the questionnaire
CySEC said the cross-border online questionnaire must be completed by CIFs that were authorised by December 31, 2025 and that provided cross-border services to more than 50 active retail clients in at least one host Member State during the year.
Reporting period and inclusion criteria
The information to be submitted covers the reporting period from January 1, 2025 to December 31, 2025, with December 31, 2025 serving as the reference date where applicable. The circular clarifies that only services provided on a freedom to provide services basis must be reported, while services delivered through a branch or permanent presence in another country under the freedom of establishment framework must not be included.
Will your firm need to complete ESMA’s 2025 cross-border online questionnaire under the CySEC circular?
