Introduction
The Cyprus Securities and Exchange Commission (CySEC) issued Circular C798 on 2 September 2026, informing Cyprus Investment Firms (CIFs) about the European Banking Authority (EBA) Consultation Paper. This covers draft Regulatory Technical Standards (RTS) for reclassifying investment firms as credit institutions. This is a new obligation with a key submission deadline on 25 November 2026.
CySEC Circular C798 – At a Glance
- Issued date: 02/09/2026
- Applies to: Cyprus Investment Firms (CIFs)
- Deadline: 25/11/2026
- Key requirement: Comments submission on draft RTS
- Submission method: Submit comments directly to EBA
What Does This Circular Require?
What firms must do. CIFs should review the Consultation Paper, assess its impact, consider participating in the consultation, and monitor future regulatory developments.
Legal basis. CRD framework amendments
Regulatory objective. Promote a more proportionate, transparent, and risk-based approach to authorisation
Who Is in Scope?
The EBA’s Consultation Paper affects investment firms concerning their classification as credit institutions.
- Cyprus Investment Firms (CIFs)
This involves firms under the MiFID investment firm authorisation acting as potential credit institutions.
Edge cases and exceptions:
- Firms with total assets exceeding EUR 30 billion: Must obtain credit institution authorisation.
Key Requirements Breakdown
Reporting / Submission Requirements
Reporting requirements to monitor the EUR 30 billion threshold.
Data or Form Requirements
Methodology for calculating total assets; information to be submitted for monitoring.
Practical Implementation: What Firms Should Do
In practice, CIFs must review the Consultation Paper and assess the impact of proposed RTS. Participate in the consultation process by providing feedback. Ensure you stay informed on developments once the RTS is finalized to adjust business practices accordingly.
Key Dates and Deadlines
Step-by-Step Submission Process
- Review the Consultation Paper published by EBA.
- Assess how the proposed RTS could impact your firm’s operations.
- Submit your comments to EBA by the deadline, 25 November 2026.
Compliance Officer Checklist
- Review EBA draft RTS
- Assess business impact
- Participate in consultation
Evidence to Retain
- Copies of submitted comments
- Internal analysis on potential impact
Why This Matters
The consultation aims to ensure a more proportional and risk-based classification of investment firms. Non-compliance may lead to inappropriate regulatory classification, affecting operational permissions and legal compliance, potentially leading to penalties.
Frequently Asked Questions
What is the submission deadline for comments?
Comments must be submitted by 25 November 2026.
Who should submit feedback on the draft RTS?
Cyprus Investment Firms (CIFs) and other interested stakeholders should submit feedback.
What are firms required to monitor?
Firms need to monitor their total assets to determine if they meet the criteria for reclassification as credit institutions.
Is there an opportunity to clarify queries?
Yes, the EBA will hold a virtual public hearing on 30 September 2026 for stakeholders to discuss the draft RTS.
What regulatory framework does this consultation relate to?
It relates to the amended Capital Requirements Directive (CRD) framework.
How CX Financia Can Support You
CX Financia supports firms with Regulatory Compliance and Risk Management services. We can help assess the impact of the EBA’s RTS, guide the consultation process, and ensure alignment with future regulatory requirements. Contact us to learn more about how we can assist your firm.
Read the CySEC Circular C798
Read more at Regulatory Updates
Disclaimer
General information, not regulatory advice.