Cyprus AIFMD Passport 2026 — Marketing Your Cyprus AIF Across the EEA in 30 Days
How the AIFMD marketing + management passports work in practice for Cyprus-authorised AIFMs: notification procedure, host-state competent authority interaction, reverse-solicitation boundaries, and post-Brexit UK access via the Temporary Marketing Permission Regime (now closed).10 min read · By Nexora Cyprus editorial team · Reviewed by an ICPAC-registered Cyprus tax adviser engaged by Nexora
The 30-day rule
Once a Cyprus AIFM submits a complete marketing-notification file for an AIF to CySEC, the host-state competent authority has 20 working days to confirm receipt and the AIFM can typically commence marketing in that host state within ~30 calendar days. The Cyprus passport is the fastest practical EU fund-distribution channel available to Cyprus-authorised managers.
1. Two passports, not one
MARKETING passport (AIFMD Article 32) — lets a Cyprus AIFM market its EU-AIFs to professional investors in other EEA member states via notification (no host-state authorisation).
MANAGEMENT passport (AIFMD Article 33) — lets a Cyprus AIFM manage AIFs domiciled in other EEA member states (e.g., a Cyprus AIFM managing a Luxembourg-domiciled AIF).
Both passports work bidirectionally for incoming non-Cyprus AIFMs marketing into Cyprus or managing Cyprus AIFs.
2. The notification procedure
1Cyprus AIFM prepares the marketing-notification file: AIF rules / OM, KIID-equivalent disclosure, depositary contract, AIFM authorisation reference.
2Submission to CySEC (the home-state competent authority).
3CySEC has 20 working days from receipt of a complete file to notify the host-state competent authority (in the destination state).
4Host-state authority's role is acknowledgment, not approval — they record the passport notification.
5Cyprus AIFM can commence marketing in the destination state on or after CySEC's notification to the host authority.
3. What the passport allows — and what it doesn't
ALLOWS: marketing to PROFESSIONAL investors (per MiFID Annex II) across all 30 EEA states.
DOES NOT ALLOW: marketing to retail investors — that requires separate host-state retail-marketing approval (case-specific national rules).
DOES NOT ALLOW: marketing of NON-EU AIFs by an EU AIFM under the passport (still requires Article 36 NPPR — national private placement regime).
Reverse solicitation — investor-initiated approaches not 'marketed' by the AIFM are typically not in scope; preserve clean records of the solicitation channel.
4. Post-Brexit UK access
Post-Brexit (1 January 2021), the UK is outside the AIFMD passport. Cyprus AIFMs marketing into the UK use the UK's national private-placement regime (NPPR) — registration with the FCA. The UK's Temporary Marketing Permission Regime (TMPR) for pre-Brexit-passported funds closed on 31 December 2023; new entrants must use NPPR.
ESMA-aligned 2021 rules formalised PRE-MARKETING (informational outreach to test investor appetite for a potential future AIF) as a distinct activity from MARKETING. Pre-marketing has lighter requirements but must transition to formal marketing within 18 months of investor expression of interest, and the AIFM must notify CySEC of pre-marketing within 2 weeks of commencement.
AuthorNexora Cyprus editorial teamReviewed byAn ICPAC-member accountant or Cyprus Bar Association lawyer engaged by NexoraLast updatedMay 2026
Disclaimer: This article is for informational purposes only and does not constitute legal, tax, or financial advice. Tax laws change frequently. Consult a qualified Cyprus adviser for guidance specific to your situation. The information on this page is general guidance only and does not constitute legal, tax, accounting, immigration or financial advice. Specific advice should be obtained based on the facts of each case.