CySEC C783: The AMLA Eligibility Template Is Due on 26 June: What Every Regulated Firm Needs to Do
At a glance
Circular: CySEC C783, dated 9 June 2026, issued under section 25(1)(c)(ii) and (iii) of the CySEC Law.
What it is:
A short, one-off reporting exercise. CySEC is collecting AMLA eligibility data through a standard Excel Template that each in-scope firm must complete and submit by the deadline.
Who must file:
Every CySEC-regulated firm that held an authorisation on 31 December 2025: CIFs, CASPs, AIFMs and internally managed AIFs, including small AIFMs and AIFLNPs, UCITS management companies, internally managed UCITS and companies managing AIFLNPs. Dormant or unused licences are not exempt.
Reference period:
1 January 2025 to 31 December 2025, with a cut-off date of 31 December 2025. Amounts must be reported in EUR, rounded to the nearest unit.
Deadline: Friday, 26 June 2026.
Submission:
By email to risk.statistics@cysec.gov.cy, using the file name USERNAME_20251231_AMLAEOE, where USERNAME is the firm’s TRS username in capital letters.
Penalties:
CySEC has stated it will send no reminders. Failure to submit promptly and duly may engage administrative penalties under section 37(5) of the CySEC Law.
First step:
Confirm that the firm is in scope, gather the 2025 reference data, complete the Template in line with the Interpretative Note, submit on time, and keep proof of delivery.
If a firm is regulated by CySEC and was authorised by 31 December 2025, the AMLA eligibility Template should now be treated as an immediate action item for this week.
CySEC Circular C783, issued on 9 June 2026, requires all in-scope firms, including CIFs, CASPs, AIFMs, UCITS management companies and others, to complete AMLA’s standard Excel Template and send it to CySEC by email by Friday, 26 June 2026. CySEC is clear that there will be no reminders and that late or incomplete submission may trigger administrative penalties.
This is not a background compliance item. It is a dated, one-off reporting obligation that should be closed out and evidenced now.
What C783 is really about
The AMLA Template is part of the EU’s preparation for bringing the new Anti-Money Laundering Authority into operation. The data reported through the Template feeds AMLA’s identification of provisionally eligible obliged entities, which is the pool from which firms may later be selected for direct AMLA supervision.
Under the AMLA framework, direct supervision is aimed at certain credit and financial institutions and groups operating across at least six Member States above defined thresholds. For most Cyprus firms, that ultimate question is secondary. The immediate compliance question under C783 is whether the firm is in scope for the reporting exercise and can evidence a complete, timely submission.
Treating C783 as “not relevant to us” without a written in-scope assessment is itself a governance weakness.
The AMLA reporting package
AMLA has published a reporting package consisting of a standard Excel workbook, Template_identification_eligible_obliged_entities_Art_153_AMLAR.xlsx, and an accompanying Interpretative Note. The Template gathers eligibility information tied to the 2025 calendar year, with a cut-off date of 31 December 2025.
Several completion points matter in practice:
- The Template is in English only and is protected; worksheet names, formulas, formatting and structure should not be changed.
- Some sheets are relevant only in specific cases and may not apply to every firm.
- Where there is a justified data gap, the comments mechanism should be used rather than leaving fields incorrect or guessing figures.
- All amounts must be reported in EUR, rounded to the nearest unit. Where conversion is needed, the official exchange rate for the relevant transaction date should be used as indicated in the Interpretative Note.
Who is in scope
C783 applies to all regulated entities authorised by 31 December 2025 across a broad category list, including CIFs, CASPs, AIFMs, internally managed AIFs, small AIFMs, AIFLNPs, UCITS management companies, internally managed UCITS and companies whose sole purpose is the management of AIFLNPs. This also captures firms that hold an authorisation they have not yet used.
For governance purposes, each firm should prepare a short dated note confirming that it is in scope and will submit, or clearly recording the basis for any out-of-scope conclusion. A silent assumption is not enough.
Group reporting
Where a firm sits within a group, the Interpretative Note distinguishes between the reporting obliged entity and a designated reporting obliged entity that may report on a consolidated basis for the group. If several group entities received C783, the group should decide which entity will report, document that decision, and ensure there is neither double-reporting nor a gap caused by everyone assuming another entity has filed.
Even where a consolidated approach is used, each entity that received the circular should still document its own position and its reliance on the agreed group submission route.
Submission mechanics
Three items must be correct:
- File naming: Use USERNAME_20251231_AMLAEOE, where USERNAME is the firm’s TRS credentials username in capital letters.
- Submission channel: Email the completed Template to risk.statistics@cysec.gov.cy.
- Deadline: Ensure the email is sent by Friday, 26 June 2026.
A copy of the completed Template, the sent email and any delivery or read acknowledgements should be kept in the regulatory correspondence file. That is the firm’s proof of compliance if CySEC, internal audit or external auditors ask later.
Where reviews will focus
In practice, the weakness in exercises like C783 is rarely a misunderstanding of the rule. The real issue is usually the evidence trail and the absence of clear ownership.
A robust response should allow the firm to demonstrate that a named individual owned the submission, the firm documented that it was in scope, the 2025 data was sourced and reconciled to internal records, the Template was completed in line with the Interpretative Note, the file naming and email instructions were followed, and proof of submission was retained.
The most common gaps are organisational rather than technical: no named owner; a dormant licence treated as out of scope without analysis; several group entities assuming someone else would file; or no retained proof that the file was actually submitted. Given CySEC’s express reference to possible penalties and no reminders, these are avoidable control failures.
Compliance checklist
Actions before the deadline
- Confirm scope: Record that the firm held a CySEC authorisation on 31 December 2025 and is therefore required to file, including where the authorisation has not been used.
- Assign ownership: Nominate the individual responsible for the submission and note management awareness of the deadline.
- Obtain the latest Template and Interpretative Note: Download the current version and avoid using outdated materials.
- Source and reconcile 2025 data: Extract the figures for 1 January 2025 to 31 December 2025, convert to EUR where required, round to the nearest unit and keep working papers.
- Agree group reporting where relevant: Decide whether a designated reporting obliged entity will report on a consolidated basis and document that decision.
- Complete the Template: Populate the relevant sheets only, use the comments facility for justified gaps and do not alter the protected structure.
- Name and submit the file: Save as USERNAME_20251231_AMLAEOE and email it to risk.statistics@cysec.gov.cy before the deadline.
- Retain proof: Keep the submitted file, sent email and any acknowledgement in the regulatory correspondence file.
- Update compliance records: Note the date, owner and completion status in the compliance monitoring plan.
Evidence to retain
Dated in-scope determination: Compliance or governance file.
Named owner and management awareness: Compliance records or committee minutes.
Working papers supporting 2025 data: Reporting or finance file.
Final completed Template: Reporting file.
Sent email and delivery/read acknowledgement: Regulatory correspondence file.
Compliance monitoring plan update: Compliance monitoring records.
Frequently asked questions
Is C783 a new obligation or just a clarification?
It is a one-off reporting obligation with a fixed deadline. CySEC is gathering AMLA eligibility data through a standard Template, and every in-scope firm authorised by 31 December 2025 must complete and submit it by 26 June 2026.
Do dormant or unused licences still have to file?
Yes. Firms that held an authorisation on 31 December 2025 are in scope even if they have not yet used that licence. Dormant status affects the content reported, not the obligation to submit.
What period must the data cover?
The Template covers the period from 1 January 2025 to 31 December 2025, with a cut-off date of 31 December 2025. Amounts are reported in EUR and rounded to the nearest unit.
How do we submit the Template?
Submission is by email to risk.statistics@cysec.gov.cy. The file name must follow the required format USERNAME_20251231_AMLAEOE, using the firm’s TRS username in capital letters.
What are the consequences of not submitting on time?
CySEC has said it will not send reminders and has referred to the administrative penalties available under section 37(5) of the CySEC Law. A late or missing submission may therefore attract supervisory attention, especially where the firm cannot show an in-scope analysis or remedial action.
What does “provisionally eligible obliged entity” actually mean?
It refers to entities that, based on the Template data, fall within the pool considered for AMLA’s direct supervision. Filing the Template does not mean that a firm will automatically be selected; it is an input into AMLA’s later selection process.
How CX Financia supports firms with C783
With the deadline close, the immediate priority is a clean and defensible submission: a clear in-scope decision, reliable 2025 data, a correctly completed Template and proof of timely delivery.
CX Financia supports firms through regulatory compliance services including:
- in-scope assessments and governance notes;
- Template completion reviews against the Interpretative Note;
- group reporting coordination; and
- support in structuring the evidence pack for later supervisory review.
The objective is straightforward: meet the obligation accurately, on time and with a submission the firm can stand behind.
Related reading
AML, CFT & Sanctions
The EU AML Package and AMLA: what regulated firms should prepare for
CySEC regulatory reporting: building a defensible submission and evidence trail
CASPs under MiCA and the EU AML framework: overlapping obligations