Introduction
On 29 September 2026, the Cyprus Securities and Exchange Commission (CySEC) issued Circular C802 requiring all Management Companies and Internally Managed Funds to submit Form QST-MC Version 26 for the third quarter of 2026. This is a routine quarterly obligation under section 25(1)(c)(ii) & (iii) of the CySEC Law. The form must be submitted via CySEC’s Transaction Reporting System (TRS) by 30 October 2026. Failure to comply may result in administrative penalties.
CySEC Circular C802 – At a Glance
- Issued date: 29 September 2026
- Applies to: Alternative Investment Fund Managers (AIFMs), Internally Managed Alternative Investment Funds, UCITS Management Companies, Internally Managed UCITS, Internally Managed AIFLNPs, Companies with sole purpose the management of AIFLNPs, and Small AIFMs
- Deadline: 30 October 2026
- Key requirement: Submit Form QST-MC Version 26 via TRS with no errors and receive a NO ERROR feedback file
- Submission method: Electronically via CySEC’s Transaction Reporting System (TRS)
What Does This Circular Require?
What firms must do. You must complete and submit Form QST-MC Version 26 to CySEC by 30 October 2026 if you were authorised or appointed as an External Manager by 30 September 2026. This includes entities that have not exercised their authorisation. You must ensure the form is error-free, digitally signed (if applicable), and that you receive a NO ERROR feedback file from TRS.
Legal basis. Section 25(1)(c)(ii) & (iii) of the Cyprus Securities and Exchange Commission Law
Regulatory objective. To collect accurate and timely quarterly statistical data from Management Companies and Internally Managed Funds for supervisory and regulatory purposes
Who Is in Scope?
The obligation applies to all entities authorised or appointed to act as External Managers, including those that have not exercised their authorisation by the reference date.
- Alternative Investment Fund Managers (AIFMs)
- Internally Managed Alternative Investment Funds
- UCITS Management Companies
- Internally Managed UCITS
- Internally Managed Alternative Investment Funds with Limited Number of Persons (AIFLNP)
- Companies with sole purpose the management of AIFLNPs
- Small AIFMs
This requirement maps to all entities falling under the categories of Management Companies and Internally Managed Funds regulated by CySEC.
Edge cases and exceptions:
- Entities authorised or appointed by 30 September 2026 but not active: Must still submit Form QST-MC
- Entities without prior TRS credentials: Must request credentials before submission
Key Requirements Breakdown
Reporting / Submission Requirements
You must report data in Euro, rounded to the nearest unit. The form is available only in English and must be completed in accordance with the instructions provided in the ‘General_instructions’ and ‘How_to_complete_the_form’ worksheets.
Data or Form Requirements
Form QST-MC Version 26 must be used. Ensure all validation tests within the form return TRUE (Green Colour) before submission.
Technical / System Requirements
The Excel file must be named using the convention: Username_yyyymmdd_QST-MC. The file must be in Excel 2007 version or later, with the .xlsx extension added automatically by Excel. Do not manually insert the extension.
Validation or Approval Process
Before submission, ensure all validation tests in the form are TRUE (Green Colour). After submission, review the feedback file for errors. If errors are present, correct them and resubmit until a NO ERROR feedback file is received.
Practical Implementation: What Firms Should Do
In practice, you should start by downloading Form QST-MC Version 26 from CySEC’s website and carefully follow the completion instructions. Common mistakes include incorrect file naming, manual insertion of the .xlsx extension, and failure to validate all form fields before submission. CySEC expects all regulated entities to submit the form by the deadline and to proactively address any errors identified in the feedback file.
Ensure you request TRS credentials well in advance if you have not previously submitted any electronic files to the TRS system. Queries regarding form completion must be submitted in writing by 23 October 2026.
Key Dates and Deadlines
Step-by-Step Submission Process
- Download Form QST-MC Version 26 from CySEC’s website and review the ‘General_instructions’ and ‘How_to_complete_the_form’ worksheets.
- Complete the form in English, ensuring all data is reported in Euro and rounded to the nearest unit.
- Run all validation tests within the form and ensure all return TRUE (Green Colour).
- Save the Excel file using the naming convention: Username_20260930_QST-MC. Ensure the file is in Excel 2007 version or later and the .xlsx extension is added automatically.
- Submit the form via CySEC’s Transaction Reporting System (TRS).
- Review the feedback file received from TRS. If errors are present, correct them and resubmit the form until a NO ERROR feedback file is received.
Compliance Officer Checklist
- Form QST-MC Version 26 downloaded and reviewed
- All data entered in Euro and rounded to the nearest unit
- All validation tests in the form return TRUE (Green Colour)
- File named correctly using the convention: Username_20260930_QST-MC
- TRS credentials obtained (if not already in possession)
- Form submitted via TRS and NO ERROR feedback file received
Evidence to Retain
- Copy of the submitted Form QST-MC Version 26
- NO ERROR feedback file received from TRS
- Email confirmation of TRS credentials request (if applicable)
- Written correspondence with CySEC regarding form completion queries (if applicable)
Why This Matters
Timely and accurate submission of Form QST-MC is critical for maintaining compliance with CySEC’s regulatory framework. Non-compliance may result in administrative penalties under section 37(5) of the CySEC Law. Additionally, failure to submit the form or address errors promptly may attract supervisory scrutiny and impact your firm’s regulatory standing.
Frequently Asked Questions
Who must submit Form QST-MC?
All Management Companies and Internally Managed Funds authorised or appointed as External Managers by 30 September 2026, including those that have not exercised their authorisation, must submit the form.
What version of Form QST-MC should be used?
You must use Form QST-MC Version 26, available in the appendix of Circular C802. Always ensure you have the latest version.
What is the deadline for submission?
The form must be successfully submitted via TRS by 30 October 2026. No extensions or reminders will be provided.
How should the Excel file be named?
The file must be named using the convention: Username_20260930_QST-MC, where ‘Username’ is your TRS credentials username in capital letters.
What happens if errors are found in the feedback file?
If errors are detected, you must correct them, digitally sign the form (if applicable), and resubmit until a NO ERROR feedback file is received.
Can queries about form completion be submitted after 23 October 2026?
No. Queries must be submitted in writing by 23 October 2026 to riskstatistics.fundmgrs@cysec.gov.cy.
How CX Financia Can Support You
At CX Financia, we help firms navigate CySEC’s regulatory requirements with confidence. Our services include Regulatory Compliance to ensure your submissions meet all legal obligations, Risk Management to address potential errors and validation issues, and Internal Audit to verify the accuracy and completeness of your reporting. If you need assistance with Form QST-MC or any other regulatory filings, contact us to discuss how we can support your compliance needs.
Read the CySEC Circular C802
Read more at Regulatory Updates
Disclaimer
This article provides general information based on CySEC Circular C802 and is not intended as regulatory or legal advice. For specific compliance matters, you should consult a qualified professional or directly contact CySEC.