Introduction
On 27 October 2026, the Cyprus Securities and Exchange Commission (CySEC) issued Circular C810 to inform regulated entities of Commission Implementing Regulation (EU) 2026/2354. This EU regulation introduces common formats for submitting beneficial ownership information to central registers, aiming to improve data quality, consistency, and interoperability across the EU. This is a clarification and reminder of an existing obligation, with the regulation applying from 10 July 2027.
CySEC Circular C810 – At a Glance
- Issued date: 27 October 2026
- Applies to: Crypto Asset Service Providers (CASPs), Cyprus Investment Firms (CIFs), Administrative Service Providers (ASPs), UCITS Management Companies, Self-Managed UCITS, Alternative Investment Fund Managers (AIFMs), Self-Managed Alternative Investment Funds (SM AIFs), Self-Managed Alternative Investment Funds with Limited Number of Persons (SM AIFLNP), Companies with sole purpose the management of AIFLNPs, and Small Alternative Investment Fund Managers (Small AIFMs)
- Deadline: 10 July 2027 (application date of the Implementing Regulation)
- Key requirement: Adopt the common formats for submitting beneficial ownership information as specified in Commission Implementing Regulation (EU) 2026/2354
What Does This Circular Require?
What firms must do. You are encouraged to take into consideration the provisions of Commission Implementing Regulation (EU) 2026/2354, which lays down common formats for submitting beneficial ownership information to central registers.
Legal basis. Commission Implementing Regulation (EU) 2026/2354 of 16 October 2026
Regulatory objective. Enhancing data quality, consistency, and interoperability among central registers of beneficial owners across the European Union
Who Is in Scope?
The circular applies to all regulated entities required to submit beneficial ownership information to central registers under EU anti-money laundering frameworks.
- Crypto Asset Service Providers (CASPs)
- Cyprus Investment Firms (CIFs)
- Administrative Service Providers (ASPs)
- UCITS Management Companies (UCITS MC)
- Self-Managed UCITS (SM UCITS)
- Alternative Investment Fund Managers (AIFMs)
- Self-Managed Alternative Investment Funds (SM AIFs)
- Self-Managed Alternative Investment Funds with Limited Number of Persons (SM AIFLNP)
- Companies with sole purpose the management of AIFLNPs
- Small Alternative Investment Fund Managers (Small AIFMs)
These entities are mapped to sectors under the EU Anti-Money Laundering Directive (AMLD) and related Cypriot legislation.
Edge cases and exceptions:
- Self-Managed AIFs: Must comply if they have reporting obligations under beneficial ownership frameworks
- Small AIFMs: Included if they fall under the scope of beneficial ownership reporting requirements
Key Requirements Breakdown
Reporting / Submission Requirements
The Implementing Regulation specifies the formats for submitting beneficial ownership information to central registers, ensuring uniformity across EU Member States.
Data or Form Requirements
Common formats for beneficial ownership data submission are introduced, replacing any previous national variations.
Practical Implementation: What Firms Should Do
In practice, you should review the formats outlined in Commission Implementing Regulation (EU) 2026/2354 and align your internal systems and processes with these requirements by 10 July 2027. This may involve updating data collection templates, IT systems, and reporting workflows to ensure compliance with the new formats.
CySEC expects regulated entities to proactively adapt to these changes to avoid discrepancies in data submission and potential supervisory scrutiny. Common mistakes include delays in system updates or misalignment with the new formats, which could lead to incomplete or inconsistent submissions.
Key Dates and Deadlines
How to Apply This Correctly
- Review the text of Commission Implementing Regulation (EU) 2026/2354, available on the Official Journal of the European Union or via the link provided in Circular C810.
- Assess your current beneficial ownership data collection and submission processes to identify gaps or misalignments with the new formats.
- Update internal systems, templates, and workflows to ensure compliance with the common formats specified in the regulation.
- Train relevant staff on the new formats and any changes to reporting procedures.
- Monitor CySEC and EU communications for any further clarifications or updates related to beneficial ownership reporting.
Compliance Officer Checklist
- Obtain and review Commission Implementing Regulation (EU) 2026/2354
- Map current beneficial ownership data fields to the new formats
- Update IT systems and data collection templates
- Conduct staff training on the new formats
- Test updated systems to ensure compliance with the regulation
- Document all changes made to align with the new formats
Evidence to Retain
- Copies of updated internal policies or procedures reflecting the new formats
- Training records for staff on the new beneficial ownership submission requirements
- System logs or test results demonstrating compliance with the new formats
- Documentation of any consultations with IT vendors or compliance advisors regarding system updates
Why This Matters
Compliance with the common formats for beneficial ownership submission is critical to ensuring data consistency and interoperability across EU central registers. Non-compliance may result in incomplete or inaccurate submissions, leading to potential supervisory actions, reputational damage, or operational disruptions. CySEC and other EU regulators will likely monitor adherence to these formats closely.
Frequently Asked Questions
Is this a new obligation for regulated entities?
No, this is a clarification and reminder of an existing obligation under Commission Implementing Regulation (EU) 2026/2354, which introduces common formats for beneficial ownership submissions.
What is the deadline for compliance with the new formats?
The regulation applies from 10 July 2027. Regulated entities must ensure their systems and processes align with the new formats by this date.
Do all regulated entities listed in the circular need to comply?
Yes, all entities listed in Circular C810 that are required to submit beneficial ownership information must comply with the new formats.
What happens if my firm does not update its systems by the deadline?
Failure to comply may result in incomplete or inconsistent submissions, potentially leading to supervisory scrutiny or other regulatory actions.
Where can I find the text of the Implementing Regulation?
The text is available in the Official Journal of the European Union and via the link provided in CySEC Circular C810.
Does this regulation replace national beneficial ownership reporting requirements?
It introduces common formats for submission but does not replace the underlying national or EU reporting obligations. You must still comply with all applicable laws.
How CX Financia Can Support You
At CX Financia, we help firms navigate regulatory changes like those introduced by Commission Implementing Regulation (EU) 2026/2354. Our services include Regulatory Compliance reviews, AML/CFT framework assessments, and Risk Management support to ensure your systems and processes align with new requirements. Contact us to discuss how we can assist your firm in preparing for these changes.
Read the CySEC Circular C810
Read more at Regulatory Updates
Disclaimer
This article provides general information and is not intended as regulatory advice. While every effort has been made to ensure accuracy, you should consult the official text of Commission Implementing Regulation (EU) 2026/2354 and seek professional advice for specific compliance matters.