
Introduction
On 2 October 2026, the Cyprus Securities and Exchange Commission (CySEC) issued Circular C804 requiring all Administrative Service Providers (ASPs) authorised by 30 September 2026 to submit the quarterly statistics Form QST-ASP (Version 13) via the Transaction Reporting System (TRS). This is an existing obligation with a strict deadline of 30 October 2026. Failure to comply may result in administrative penalties under section 37(5) of the CySEC Law.
CySEC Circular C804 – At a Glance
- Issued date: 2 October 2026
- Applies to: All Administrative Service Providers (ASPs) authorised by CySEC by 30 September 2026, including those that have not made use of their authorisation
- Deadline: 30 October 2026
- Key requirement: Submit Form QST-ASP (Version 13) electronically via the TRS with a NO ERROR feedback file
- Submission method: CySEC’s Transaction Reporting System (TRS)
What Does This Circular Require?
What firms must do. You must complete and submit Form QST-ASP (Version 13) by 30 October 2026. You must ensure the form is error-free, digitally signed (where applicable), and that you receive a NO ERROR feedback file from the TRS. You must report data in Euro, rounded to the nearest unit, and follow the naming convention for the Excel file.
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 ASPs for supervisory and monitoring purposes
Who Is in Scope?
The obligation applies to all ASPs authorised by CySEC by the end of the reporting period, regardless of whether they have actively used their authorisation.
- Administrative Service Providers (ASPs)
Edge cases and exceptions:
- Non-active ASPs: ASPs authorised by 30 September 2026 but not using their authorisation must still submit the form
- New ASPs: Only those authorised by 30 September 2026 are in scope for this submission
Key Requirements Breakdown
Reporting / Submission Requirements
You must report quarterly financial and operational data for the period ending 30 September 2026. The form includes sections on general information, income statement, and validation tests. Data must be reported in Euro, rounded to the nearest unit.
Data or Form Requirements
Form QST-ASP (Version 13), available in English only. The form includes distinct columns for Reporting Period (Column D) and Cumulative Reporting Period (Column E) in Section F (Income Statement). Both columns refer to the ASP only, not subsidiaries.
Technical / System Requirements
The form must be submitted electronically via the TRS. You must name the Excel file using the convention: Username_yyyymmdd_QST-ASP (e.g., TRSUSER_20260930_QST-ASP). The file must be in Excel 2007 or later format and digitally signed where applicable.
Validation or Approval Process
Before submission, ensure all validation tests in the form (Sections General Information, A, B, C, D, E, F, G, and Validation Tests Worksheet) return TRUE (Green Colour). The TRS will provide a feedback file indicating NO ERROR or describing errors. You must correct any errors and resubmit until a NO ERROR feedback is received.
Practical Implementation: What Firms Should Do
In practice, you should begin by downloading Form QST-ASP (Version 13) from the CySEC website and reviewing the instructions in the ‘Instructions’ worksheet. Pay close attention to the distinction between the Reporting Period and Cumulative Reporting Period columns in Section F, as errors here are common. Ensure all data is reported in Euro and rounded correctly, and that the form passes all validation tests before submission.
CySEC expects strict adherence to the naming convention for the Excel file and timely submission. Do not manually add the .xlsx extension, and ensure the file is submitted during CySEC’s regular hours to receive the feedback file. If errors are detected, address them immediately and resubmit the form before the deadline. CySEC will not grant extensions or send reminders for non-compliance.
Key Dates and Deadlines
Step-by-Step Submission Process
- Download Form QST-ASP (Version 13) from the CySEC website and review the ‘Instructions’ worksheet.
- Complete all required fields in the form, ensuring data is reported in Euro and rounded to the nearest unit. Pay special attention to the Reporting Period and Cumulative Reporting Period columns in Section F.
- Run all validation tests in the form and ensure they return TRUE (Green Colour). Correct any errors before proceeding.
- Name the Excel file using the convention: Username_yyyymmdd_QST-ASP (e.g., TRSUSER_20260930_QST-ASP). Do not manually add the .xlsx extension.
- Digitally sign the form (where applicable) and submit it electronically via the TRS during CySEC’s regular hours.
- Check the Outgoing directory in the TRS for the feedback file. If errors are indicated, correct them and resubmit the form until a NO ERROR feedback is received.
- Retain the NO ERROR feedback file as proof of successful submission.
Compliance Officer Checklist
- Form QST-ASP (Version 13) downloaded and reviewed
- All required fields completed with data in Euro, rounded to the nearest unit
- Validation tests passed (TRUE/Green Colour) in all sections
- Excel file named correctly (Username_yyyymmdd_QST-ASP)
- Form digitally signed (where applicable)
- Form submitted via TRS during CySEC’s regular hours
- NO ERROR feedback file received and retained
Evidence to Retain
- NO ERROR feedback file from the TRS
- Copy of the submitted Form QST-ASP (Version 13) with digital signature (where applicable)
- Email confirmation or timestamp of submission via the TRS
Why This Matters
Timely and accurate submission of Form QST-ASP is critical for maintaining compliance with CySEC’s regulatory requirements. Failure to submit the form by the deadline or submitting an incomplete or erroneous form may result in administrative penalties under section 37(5) of the CySEC Law. CySEC will not grant extensions or send reminders, so non-compliance could lead to enforcement action and reputational damage for your firm.
Frequently Asked Questions
Who must submit Form QST-ASP?
All Administrative Service Providers (ASPs) authorised by CySEC by 30 September 2026 must submit Form QST-ASP, including those that have not made use of their authorisation.
What is the deadline for submitting Form QST-ASP?
The form must be successfully submitted via the TRS by 30 October 2026. CySEC will not grant extensions to this deadline.
How should the Excel file be named?
The file must be named using the convention: Username_yyyymmdd_QST-ASP (e.g., TRSUSER_20260930_QST-ASP). The username is your TRS credentials, and the date reflects the end of the reporting period.
What happens if errors are detected in the form?
If errors are detected, the TRS will provide a feedback file describing them. You must correct the errors, digitally sign the form (where applicable), and resubmit until a NO ERROR feedback is received.
Can queries about form completion be submitted after 23 October 2026?
No. Queries on form completion must be submitted in writing to riskstatistics.asps@cysec.gov.cy by 23 October 2026. Technical queries can be submitted after this date to information.technology@cysec.gov.cy.
What data should be reported in the Reporting Period and Cumulative Reporting Period columns?
The Reporting Period (Column D) covers the quarter (e.g., 1 July–30 September 2026), while the Cumulative Reporting Period (Column E) covers the year-to-date (e.g., 1 January–30 September 2026). Both columns refer to the ASP only, not subsidiaries.
How CX Financia Can Support You
At CX Financia, we help firms navigate CySEC’s regulatory requirements with confidence. Our Regulatory Compliance services ensure your Form QST-ASP submission is accurate, timely, and fully compliant. We also provide AML/CFT advisory, Risk Management, and Internal Audit services to support your broader compliance needs. Contact us to discuss how we can assist your firm in meeting its obligations efficiently.
Read the CySEC Circular C804
Read more at Regulatory Updates
Disclaimer
This article provides general information based on CySEC Circular C804 and is not intended as regulatory advice. For specific guidance tailored to your firm’s circumstances, consult a qualified professional or contact CySEC directly.
