Cyprus AIFMD Passport 2026 — Marketing Your Cyprus AIF Across the EEA in 30 Days

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

1. 1Cyprus AIFM prepares the marketing-notification file: AIF rules / OM, KIID-equivalent disclosure, depositary contract, AIFM authorisation reference.
2. 2Submission to CySEC (the home-state competent authority).
3. 3CySEC has 20 working days from receipt of a complete file to notify the host-state competent authority (in the destination state).
4. 4Host-state authority's role is acknowledgment, not approval — they record the passport notification.
5. 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.

5. Marketing pre-marketing distinction

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.

6. Practical Cyprus AIFM workflow

1. 1Identify target investor jurisdictions (DE, FR, IT, ES, NL etc.).
2. 2Prepare marketing-notification file per jurisdiction (typically uniform across EU).
3. 3Submit to CySEC; respond to any clarification requests.
4. 4Receive CySEC notification + commence marketing.
5. 5Track local-language marketing requirements per host state — some require local translations of KIID-equivalent documents.
6. 6Maintain marketing records for AIFMD-compliance reporting.

Official verification starting points

CySEC regulated entities and guidance and ESMA investment-management guidance publish the controlling material for this topic. Check the current law, form, circular or portal instructions before acting; this article is general information and the live official material prevails.

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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.