Chris Humphries
Jonathan McLean
From 1 April 2025, Phase 2 of the Virtual Asset Service Providers (“ VASP ”) Regulatory Framework (Licensing Phase) comes into effect in the Cayman Islands pursuant to the introduction of the Virtual Asset (Service Providers) Amendment Act, 2024...
The scope of regulatory requirements in the Cayman Islands has increased significantly in recent years and requires Cayman-domiciled entities to meet ongoing regulatory filing requirements, in addition to other obligations as set out by the regulatory bodies of the Cayman Islands.
By staying informed and seeking guidance from experts, Cayman entities can navigate the complexities of the regulatory landscape with clarity and ease.
We have provided a summary of the regulatory filing dates for Cayman-domiciled entities (including regulated funds), for 2024 below.
2024 Regulatory Deadline: | Regulatory Filings: | Legal Entity Type: | Authority: |
|---|---|---|---|
Ongoing | Beneficial Ownership information or exemption to be submitted to the Registrar of Companies on a monthly basis. | All Cayman companies, Limited Liability Companies, Limited Liability Partnerships (and those registered by way of continuation in Cayman), including ordinary companies, exempted companies and exempted segregated portfolio companies. | RoC |
12 months following the previous financial year end | Economic Substance Returns due to the Department for International Tax Cooperation (‘DITC’) for “relevant entities” carrying on a “relevant activity”. Entities must complete their Economic Substance Return within 12 months of the applicable year-end (e.g. 31 March, 30 June, 30 September or 31 December). | Relevant entities, which includes all Cayman Islands companies, LLCs, LLPs, registered foreign companies and partnerships (including exempted limited partnerships, general partnerships, limited partnerships and foreign limited partnerships) and also foundation companies. | DITC |
15 January | Annual licence fee renewals due to the Cayman Islands Monetary Authority (“CIMA”) for regulated entities. | Mutual Funds, Private Funds, Money Services Businesses, Securities Investment Business Operators, Company Managers, Corporate Service Providers, Banks, Trust Companies, Building and Cooperative Societies, Insurance Companies, Company Managers, Corporate Service Providers, Virtual Asset Service Providers, entities regulated under the Directors Registration and Licensing Act. | CIMA |
15 January | Annual declaration for directors registered with CIMA under the Directors Registration and Licensing Act. | All Directors registered with CIMA under the Directors Registration and Licensing Act. | CIMA |
15 January | Annual declaration for entities registered as a Registered Person under the Securities Investment Business Act. | Securities Investment Business Operators. | CIMA |
31 January | Economic Substance Notification due to the DITC via the Registrar of Companies. | All Cayman companies (including foundation companies), LLCs, LLPs, and partnerships (including exempted limited partnerships, general partnerships and limited partnerships). | DITC |
31 January | Annual Return and annual fees due to the Registrar of Companies for all Cayman Islands entity types. | All Cayman companies (including foundation companies), LLCs, LLPs, registered foreign companies and partnerships (including exempted limited partnerships, general partnerships, limited partnerships and foreign limited partnerships). | RoC |
31 March | Economic Substance Notification due to the Registrar for foreign companies. | All foreign companies and foreign limited partnerships. | DITC |
30 April | Registration deadline for entities defined as Financial Institutions under Common Reporting Standard (‘CRS’) and Foreign Account Tax Compliance Act (‘FATCA’) legislation for the prior year ending 31 December. | Any Cayman-domiciled entity which has been defined as a “Financial Institution” for AEOI purposes. | DITC |
30 June | Audited Financial Statements and Fund Annual Return due for all CIMA-registered funds for the prior year ending 31 December. | Mutual Funds and Private Funds. | CIMA |
31 July
| CRS and FATCA reporting due to the DITC for all Reporting Financial Institutions for the prior year ending 31 December. | Any Cayman-domiciled entity which has been defined as a “Financial Institution” for AEOI purposes. | DITC |
31 July | CRS Filing Declaration (Nil return) | Any Cayman-domiciled entity which has been defined as a “Financial Institution” for CRS purposes. | DITC |
16 September* | CRS Compliance Form due for the prior year ending 31 December. | Any Cayman-domiciled entity which has been defined as a “Financial Institution” for AEOI purposes. | DITC |
31 December | De-registration deadline to avoid next year’s fees for CIMA registered entities and Directors | Any CIMA-registered entity. | CIMA |
| Within 30 days of commencing business | Where an FI has reporting obligations under FATCA it will also be required to obtain a GIIN (and enter this information when it registers on the TIA Portal). | FI that has reporting obligations under FATCA. | IRS |
* Extended to 16 September (due to 15 September falling on a Sunday).
It is recommended to review the Updates Bulletin regularly, on the website for the Cayman Islands Department for International Tax Cooperation (DITC).
Renewals and cancellations should be made and paid for through CIMA’s portal by using the login credentials previously supplied upon registration.
Forms and Online Portal Access can be viewed on the DITC website.
The CRS has updated the list of Reportable Jurisdictions to include Georgia, Kenya, Moldova, Ukraine and others as of April and June 2024. The list can be viewed on the DITC website here.
How Stuarts Can Help
Stuarts Investment Funds and Regulatory teams have extensive experience advising funds and other regulated entities in the Cayman Islands on corporate governance and compliance matters. Through our subsidiaries, Stuarts Corporate Services and Southern Management Services our team of experienced corporate professionals can provide you with a full suite of governance and directorship services including Cayman resident directors and corporate secretarial services, to assist in meeting the ongoing regulatory obligations of your fund and regulated entities in the Cayman Islands.
Please contact Chris Humphries or Jonathan McLean for assistance with your entities’ regulatory compliance obligations or contact us for more information.
