Cyprus · CySEC CIF route
The Cyprus CIF Route, From the Statute Up
A CIF is a Cyprus Investment Firm authorised by CySEC under Law 87(I)/2017, the Cypriot transposition of MiFID II. The licence is defined by the First Annex activities it carries - there are no named "CIF classes" - and a market maker is simply a CIF whose licence includes dealing on own account. This page lays the regime out from the statute, the prudential law and the published fee directive, then the two ways in: apply fresh, or acquire an authorised CIF through the section 12 change-of-control gate. SKY7 runs both.
- EUR 750,000
- Initial capital for dealing on own account - the market-maker tier under Article 9 of Law 165(I)/2021.
- EUR 7,000
- CIF application charge, one lump sum for Annex I Part I services 1 to 7 under Directive DI87-03.
- 60 working days
- Section 13 change-of-control assessment window - deemed approval if CySEC does not object in writing.
- Six months
- The only statutory determination clock (s.7(3)), and it runs from a complete application, not the date you file.
The route in short
Law 87(I)/2017, the Investment Services and Activities and Regulated Markets Law, makes CySEC the sole authorisation and supervision authority for a Cyprus Investment Firm. Prudential requirements come from Law 165(I)/2021 with the directly applicable IFR and IFD; all charges come from Directive DI87-03. One authorisation covers the First Annex activities named in it - dealing on own account is item 3, the permission that defines a market-maker CIF.
New to the instrument? The permission itself, priced, is in what the market-maker permission adds; the shelf-entity risk is in the dormant CIF trap; the wider picture sits in the Cyprus jurisdiction overview. CySEC's public register listed 258 CIF entries as of 4 May 2026 - a large ecosystem, though that figure is a list snapshot to re-check before you rely on it.
Read this first
Two myths this page kills on sight
First, there are no "CIF classes". Nothing in Law 87(I)/2017 creates a "CIF 1 / CIF 2" or "Class 1-2-3 licence" taxonomy. A CIF's licence is defined by which First Annex items it carries (s.6(1)). The only classes in the regime are prudential - Class 2 and Class 3 under the IFR - and they size your capital, not your permission scope.
Second, the market-maker capital figure is EUR 750,000, not EUR 730,000, and it is not a "frozen deposit". The EUR 730,000 number is a pre-IFD figure that pages still circulate; the current requirement flows from Article 9 of Law 165(I)/2021. There is no published rule requiring capital to be frozen in a Cypriot bank - initial capital is own funds (CET1, AT1, T2) under IFR Article 9, not an escrow.
What the licence is
The licence is its Annex items, not a class
When CySEC authorises a CIF under s.5(1), the authorisation specifies the investment services and activities granted (s.6(1)). The menu is the First Annex, Part I. A firm that only receives and transmits orders carries item 1; a firm that trades against its own book carries item 3. The permission set, not a label, tells you what a CIF may do - and under s.5(5) a CIF may not conduct business beyond the activities on its licence.
Part II of the same Annex lists seven ancillary services, such as safekeeping, margin lending and investment research. Each is priced and applied for separately. Reading a CIF's authorisation is therefore a matter of reading its Annex items, not decoding a class number that does not exist in the statute.
The defined term
Market maker: a definition, and why Class 3 is impossible
"Market maker" is a defined term in s.2, not a licence type. In a working translation of the binding Greek text, it means a person who holds himself out on the markets on a continuous basis as willing to deal on own account, buying and selling instruments against his own capital at prices he sets. Operationally, that is a CIF carrying Annex I Part I item 3.
That has a hard prudential consequence. The IFR splits investment firms into Class 2 and Class 3, and Class 3 - small and non-interconnected - requires, among other IFR Article 12 thresholds, zero daily trading flow and zero net position risk. A firm dealing on own account has non-zero daily trading flow and net position risk by definition, so a market-maker CIF cannot be Class 3. It is a Class 2 firm, with the full K-factor own-funds calculation that follows.
Article 9, Law 165(I)/2021
Initial capital by permission set
| Initial capital | Permission set (Annex I Part I) | For a market maker |
|---|---|---|
| Initial capital EUR 750,000 | Permission set (Annex I Part I) Dealing on own account (item 3); underwriting or placing on a firm commitment basis (item 6). | For a market maker The tier a market-maker CIF sits in. |
| Initial capital EUR 750,000 | Permission set (Annex I Part I) Operating an OTF that deals on own account. | For a market maker Same figure, different activity. |
| Initial capital EUR 150,000 | Permission set (Annex I Part I) Investment firms outside the EUR 75,000 and EUR 750,000 permission sets. | For a market maker Not enough to trade on own account. |
| Initial capital EUR 75,000 | Permission set (Annex I Part I) RTO, execution, portfolio management, advice or placing without firm commitment, holding no client money or securities. | For a market maker Excludes item 3 entirely. |
Ongoing own funds
The floor never drops below the entry figure
Initial capital is a gate, not a ceiling. Under the CySEC IFR and IFD Practical Guide, a Class 2 CIF must hold at all times the highest of three measures: the fixed-overheads requirement (one quarter of the preceding year's fixed overheads, IFR Article 13); the permanent minimum capital, which is at least the initial capital (IFR Article 14); and the K-factor requirement.
For a market maker, the permanent minimum means own funds never fall below EUR 750,000. The K-factors that switch on for own-account dealing are the trading-book ones: K-DTF on daily trading flow, K-NPR (or K-CMG) on net position risk, and K-TCD on trading counterparty default. What that costs a market maker in practice is unpacked in the market-maker permission guide.
People and substance
Two directors who actually run it, from a Cyprus head office
Section 9(16) sets the four-eyes rule: at least two persons meeting the fitness requirements of ss.9 and 10 must effectively direct the firm's business. CySEC must be notified of every board member and every change (s.9(15)), and it assesses the fitness of the whole board and of qualifying shareholders at authorisation (s.11), with power to refuse or to suspend voting rights where it is not satisfied.
Substance is not optional: s.5(4) requires every CIF to have its head office in the Republic. The fit-and-proper file runs on CySEC's own forms - the management-body list and questionnaire and the fit-and-proper form - all re-versioned 30 October 2025, so cite the current versions. A letterbox with a nameplate does not meet s.5(4).
The dossier
What a complete CIF application carries
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Programme of operations
The business plan and types of business, with the organisational structure CySEC assesses under s.7.
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Internal operations manual
Compliance, risk, product governance and safeguarding arrangements under s.17.
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Capital resolutions and forecasts
Board resolutions on capital plus forecast accounts and financial statements.
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Prudential classification form
Form 165-01 for a Class 2 firm, or 165-02 for Class 3 - a market maker files as Class 2.
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Personnel and fit-and-proper forms
The management-body list, the board questionnaire and the fit-and-proper form, all in their 30 October 2025 versions.
Timeline honesty
Six months from a complete file - and no official fast-track
The only published timeline is s.7(3): CySEC informs the applicant, within six months of the submission of a complete application, whether authorisation has been granted. The words that matter are "complete application" - the six-month clock does not start on an incomplete file, so application quality, not the regulator's diary, sets the real timetable.
There is no official fast-track. A site-restricted search of cysec.gov.cy returns no paid expedition scheme for CIF authorisation, and the "EUR 25,000 fast-track" that circulates on commercial pages has no basis in any CySEC document we could find. End-to-end estimates of nine to fourteen months are consultancy market colour, not a statutory or published figure - useful for planning, not something to quote as a rule.
Fees as published
One directive holds the whole cost surface
Directive DI87-03 sets every charge in one place. A CIF authorisation application is a single EUR 7,000 lump sum covering any of Annex I Part I services 1 to 7 - so dealing on own account costs the same EUR 7,000 whether or not you stack other Part I services onto it. Operating an MTF or OTF adds EUR 25,000; each ancillary service is EUR 500; engaging in algorithmic trading adds EUR 2,000.
Annual fees are keyed to the capital tier. A market-maker CIF sits in the top fixed band at EUR 10,000, plus a turnover increment above EUR 500,000 of income, plus EUR 3,000 if it deals in CFDs and EUR 2,000 if it trades algorithmically, capped at EUR 150,000 in total. The English consolidation on the CySEC fee page stops at 2020 and predates the 2023 re-tiering, so anyone reading only English gets stale numbers. SKY7 fees are quoted on request.
Directive DI87-03
The published charges that matter
| Charge | Amount | Basis |
|---|---|---|
| Charge CIF authorisation (services 1 to 7) | Amount EUR 7,000 | Basis One lump sum, however many Part I 1-7 services are stacked. |
| Charge MTF or OTF operation (items 8 to 9) | Amount EUR 25,000 | Basis On top of the base charge, if applied for. |
| Charge Each ancillary service (Part II) | Amount EUR 500 | Basis Per ancillary service. |
| Charge Algorithmic trading | Amount EUR 2,000 | Basis If the CIF will engage in it (s.18). |
| Charge Each proposed board member | Amount EUR 2,000 | Basis EUR 1,000 for a non-executive assessed in the prior two years. |
| Charge Change-of-control notification | Amount EUR 3,500 | Basis Per s.12(1) notification. |
| Charge Annual fee, market-maker tier | Amount EUR 10,000 | Basis Fixed, plus a turnover increment and CFD or algo add-ons; capped at EUR 150,000. |
The acquisition rail
Section 12: buying a CIF runs on a notify-first clock
The second way in is to acquire an authorised CIF. A qualifying holding is a direct or indirect holding of at least 10% of capital or voting rights, or one enabling significant influence over management (s.2). Under s.12(1)(a), anyone deciding to acquire or increase such a holding so that it reaches or exceeds 20%, 30% or 50%, or makes the CIF a subsidiary, must first notify CySEC in writing. The gates are therefore 10%, 20%, 30%, 50% and control.
Notification comes before the acquisition, on Forms 87-00-18, 87-00-19 or 87-00-20 by acquirer type, with a EUR 3,500 fee. This is not a "licence transfer": the licence stays with the entity, and CySEC assesses the incoming controller. How the mechanics compare with acquiring in other regimes is set out in buy a licence vs apply fresh.
Section 13
The change-of-control clock
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Acknowledge
CySEC acknowledges a complete notification in writing within two working days.
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Assess
A 60-working-day assessment period runs from that acknowledgment of the notification and all required documents.
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One interruption
CySEC may request further information no later than the 50th working day, pausing the clock for up to 20 working days.
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Non-EU extension
That interruption can extend to 30 working days where the acquirer sits or is regulated outside the EU.
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Deemed approval
If CySEC does not oppose in writing within the assessment period, the acquisition is treated as approved (s.13(5)).
Section 14(1)
The five things CySEC weighs on a controller
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Reputation of the acquirer
The standing and integrity of the proposed acquirer.
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Reputation and experience of new management
Anyone who will direct the CIF's business as a result.
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Financial soundness
The acquirer's financial strength relative to the CIF's business.
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Continued prudential compliance
Whether the CIF can keep meeting prudential rules, and whether the group structure allows effective supervision.
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Money-laundering grounds
Whether there are reasonable grounds to suspect money laundering or terrorist financing, or that the deal raises that risk.
The gun-jumping penalty
Notify before you close, or the votes do not count
The notify-first rule has teeth. Under s.12(4), acquiring or increasing a qualifying holding without prior notification triggers the s.11(3) measures; acquiring in the face of a CySEC objection can mean suspension of the associated voting rights or nullity of any votes cast, on top of other sanctions. There is no "close now, notify later" structure in the Cyprus regime.
The upside of the same clock is certainty. The 60-working-day window has a hard tacit-approval backstop, CySEC must give written reasons if it objects, and it may only assess against the five s.14(1) criteria. That combination - a bounded clock plus deemed approval - is what makes the acquisition rail attractive when a clean, operating entity is on offer.
The passport
A real MiFID single-market passport, not equivalence
A CIF carries a genuine EU passport. Under s.35, a CIF may provide its licensed services across the EEA under the MiFID II freedom to provide services by notifying CySEC with a per-state programme of operations, and under s.36 it may establish branches. This is single-market access under Directive 2014/65/EU - not an equivalence or memorandum arrangement, and it is one of the strongest commercial reasons buyers look at Cyprus.
State it precisely, though: the passport is a feature of the regime once a firm is authorised and has notified correctly. No adviser can promise the underlying CySEC authorisation or a change-of-control approval - that decision is CySEC's, and the passport follows the licence, not the other way round.
Live inventory
Available in Cyprus now
Availability changes - this is what is live today.
Shelf-CIF honesty
A dormant licence is a wasting asset the clock can kill
The market offers shelf CIFs as a shortcut. Read s.8(1)(a) first: CySEC may withdraw a CIF's authorisation where the firm does not make use of it within twelve months, expressly renounces it, or has provided no investment services in the preceding six months. A licence that has never traded is exactly what that ground targets.
The costs run whether or not the firm operates. Under DI87-03 a CIF that has not started operating still owes annual fees from the year of grant, pro-rated by month, and non-payment can suspend the authorisation under s.71(6)(c). What a buyer must verify - activity evidence, fee status, regulatory filings - before the 60-working-day clock even starts is set out in the dormant CIF trap. The honest alternative is an operating entity: our live lot, Turnkey CySEC CIF (Market Maker) for Sale, with pricing on request.
Enforcement colour
CySEC uses the powers, and the record is public
This is a supervised, actively policed market. CySEC announced a EUR 120,000 settlement with ZORIVO LTD on 30 January 2026, of which EUR 70,000 concerned a possible authorisation-perimeter breach under s.5(1) and EUR 50,000 concerned obstruction of an on-site investigation. A separate EUR 100,000 settlement with a CIF over the EU markets regulation was announced in early February 2026.
Through June 2026 the CySEC decisions page recorded a run of CIF licence suspensions and withdrawals. We name these as reported regulator actions, dated; the individual grounds of the June withdrawals were published as decision titles that we have not each read in full, so treat the wave as colour and verify any specific case on the CySEC decisions page before relying on it.
Moving target
What is changing, as of July 2026
Two shifts matter for a dealing-on-own-account CIF. Law 183(I)/2025, gazetted 17 October 2025, transposes the MiFID II review and introduces a new, qualitative "systematic internaliser" definition limited to equity instruments dealt on own account when executing client orders outside a venue on an organised, frequent and systematic basis - reshaping when an equities market maker becomes an SI. It is in Greek only for now.
Separately, the fee directive's 2023 re-tiering is not yet reflected in the English consolidation on the CySEC fee page, and all CIF forms were re-versioned 30 October 2025. Statements on this page are made as of July 2026 against CySEC's published texts; verify the current law, the fee directive and the register on cysec.gov.cy before you commit capital.
FAQ
CySEC CIF licence FAQ
Straight answers to what operators ask. If yours isn't here, ask us directly
01 Are there different "classes" of CySEC CIF licence?
No. Law 87(I)/2017 has no "CIF 1 / CIF 2" or "Class 1-2-3" licence taxonomy. A CIF's licence is defined by the First Annex items it carries (s.6(1)). The only classes are prudential - Class 2 and Class 3 under the IFR - and a market maker, which deals on own account, is always Class 2.
02 How much capital does a market-maker CIF need?
EUR 750,000 of initial capital under Article 9 of Law 165(I)/2021, because it carries the dealing-on-own-account permission. The permanent-minimum rule means own funds never fall below that figure. It is own funds, not a "frozen deposit", and the older EUR 730,000 number is a pre-IFD figure.
03 What does a CIF application cost at CySEC?
Under Directive DI87-03, a EUR 7,000 lump sum covers any of Annex I Part I services 1 to 7, so dealing on own account costs the same EUR 7,000. Add EUR 500 per ancillary service and EUR 2,000 for algorithmic trading. Annual fees for the market-maker tier start at EUR 10,000. SKY7 fees are quoted on request.
04 How long does CySEC authorisation take?
The only statutory timeline is s.7(3): six months from a complete application. The clock does not start on an incomplete file. There is no official paid fast-track, and the nine-to-fourteen-month figures circulating elsewhere are consultancy estimates, not a published rule.
05 Can I buy an existing CIF instead of applying?
Yes, through the s.12 to 14 qualifying-holding regime. You notify CySEC in writing before acquiring 10% or more, with fresh gates at 20%, 30%, 50% and control. CySEC has 60 working days from acknowledgment, and silence at expiry counts as approval (s.13(5)). Closing before notifying can void the votes.
06 Does a CySEC CIF passport into the EU?
Yes. A CIF carries a genuine MiFID II single-market passport under ss.35 and 36 - freedom to provide services and to branch across the EEA, not an equivalence arrangement. It is a feature of the licence, not an outcome any adviser can promise; the authorisation still depends on CySEC.
07 Is a dormant "shelf" CIF a safe purchase?
Treat it as a wasting asset. Section 8(1)(a) lets CySEC withdraw an authorisation unused for twelve months or with no services in the preceding six, annual fees accrue even before operations begin, and non-payment can suspend the licence. Verify activity and fee status before the change-of-control clock starts.
Go deeper
Guides for this route
What the market-maker permission adds
The item-3 permission, the EUR 750,000 jump and the K-factors, priced.
The dormant CIF trap
How a shelf CySEC CIF can die before you finish buying it.
Buy a licence vs apply fresh
The decision framework behind the acquisition rail.
Turnkey CySEC CIF (Market Maker) for sale
The live operating entity this rail leads to, pricing on request.
Cyprus jurisdiction overview
The full Cyprus route map, plus live inventory.
Reviewed by the SKY7 advisory team. Last reviewed: 12 July 2026. This page is general information only, not legal, regulatory, tax, investment or financial advice. The Cyprus regime is moving: Law 183(I)/2025 and its systematic-internaliser change are Greek-only, the English fee consolidation predates the 2023 re-tiering, and the CIF register is a dated snapshot. Statements are made as of July 2026 and must be verified against the primary sources - Law 87(I)/2017, Law 165(I)/2021, Directive DI87-03 and the register on cysec.gov.cy - before you rely on them. Nothing here promises authorisation, change-of-control approval or any other regulatory outcome; CySEC decides.
Tell us what you need
Get a straight answer on the Cyprus CIF route
Tell us what you want to trade, for whom, and on what timeline. We will tell you which First Annex items you need, whether the EUR 750,000 market-maker tier fits, what the statutory clocks mean for your plan, and whether to file fresh or bid for a live authorised CIF - before you spend anything.