What must an AIFM report to investors and to CySEC?
The annual report and its deadline, contents and audit, what investors are told before and after investing, and regular reporting to CySEC, including for funds using substantial leverage.
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Short answer
For each EU AIF it manages and each AIF it markets in the EU, an AIFM prepares an audited annual report within six months of the financial year-end, available to investors on request and to CySEC; where the items go into a published annual financial report, that report is due within four months. Before investing, investors receive information on strategy, leverage, fees, valuation, liquidity and more, and they learn without delay of changes to depositary liability. Investors and CySEC also receive regular data on illiquid assets, risk profile and leverage.
Transparency at a glance
| Point | Rule |
|---|---|
| Annual report | Each EU AIF managed and each AIF marketed in the EU; within six months of year-end; to investors on request and to CySEC |
| Published annual financial report | Only the extra items given, separately or added to that report, which is then due within four months |
| Contents | Statement of assets and liabilities; income and expenditure account; report on activities; material changes; total pay split fixed and variable, beneficiaries, carried interest; aggregate pay of senior management and material risk takers |
| Audit | Home-state (or third-country) accounting standards and the fund rules; audited, with the full audit report |
| Before investing | Sixteen items, from strategy and leverage to fees, valuation, liquidity, fair treatment, latest NAV, prime broker and periodic disclosures |
| Depositary liability | Contractual discharge disclosed before investing; any change notified without delay |
| Periodic to investors | Illiquid share, new liquidity arrangements, risk profile and systems; for leveraged funds managed or marketed in the EU, leverage limits, reuse rights and total leverage |
| To CySEC | Instruments, markets, exposures, concentrations; per fund, liquidity, risk profile, asset categories and stress tests |
| Substantial leverage | Exposure above three times NAV (commitment method): overall leverage, borrowing versus derivatives, reuse, five biggest lenders |
| Fund's own reports (AIF Law) | Annual within six months (IFRS, audited); half-yearly within two months (IFRS, unaudited); both filed with CySEC |
Source: Law 56(I)/2013, Articles 29–31; Law 124(I)/2018, Articles 76–78; Delegated Regulation (EU) No 231/2013, Articles 103–111; CySEC Circular C768.
In the exam
The exam is written from the exam material, which predates the changes below. Expect its answer. If that answer is not among the options and the current rule is, choose the current rule.
Non-EU AIFM reporting test
Exam material: The limited reporting applies where a non-EU manager has a Cyprus branch.
Current law (since 5 July 2013 (Law 56(I)/2013)): It applies to a non-EU AIFM whose Member State of reference is Cyprus.
Pre-investment disclosure list
Exam material: Fifteen items must be disclosed before investing.
Current law (since 5 July 2013 (Law 56(I)/2013)): Sixteen items: the law adds how and when periodic information on the fund will be disclosed.
What must the annual report contain, and when is it due?
For every EU AIF under its management, and every AIF it markets in the EU, an annual report covering each financial year is produced no later than six months after that year ends, available to investors on request and to CySEC and, where relevant, the fund's home supervisor. If the fund already publishes an annual financial report under EU transparency rules, only the extra items go to investors on request, separately or added to that report, which must then be out within four months.
The report contains at least a balance sheet or a statement of assets and liabilities, an income and expenditure account, a report on activities, material changes in the information investors receive before investing, total pay for the year split into fixed and variable with the number of beneficiaries and any carried interest, and aggregate pay broken down between senior management and staff whose actions materially affect the fund's risk profile. Pay figures are required in aggregate, by category, not per person. Accounts follow the home state's (or third country's) standards and the fund rules, and are audited, with the audit report reproduced in full. Separately, the AIF Law requires every Cypriot AIF to file with CySEC an audited IFRS annual report within six months and an unaudited half-yearly report within two months; CySEC's circular C768 of 2 April 2026 restated the annual-report duties.
Terms used in this note
- Commitment method
- A way of measuring exposure that converts derivatives into equivalent positions in the underlying assets, allowing for netting and hedging.
- Member State of reference
- The EU Member State whose supervisor oversees a non-EU AIFM under the AIFMD.
- Carried interest
- A share of the fund's profits paid to the AIFM as compensation for managing it.
What must investors be told before and after they invest?
Before anyone invests, and after any material change, the AIFM makes sixteen items available as the fund rules provide. They cover the strategy, objectives, asset types, techniques, risks, restrictions and leverage rules, including the maximum; how strategy can change; the legal effects of investing; the identity and duties of the AIFM, depositary, auditor and other providers; cover for professional liability; delegation and resulting conflicts; valuation methods, including for hard-to-value assets; liquidity management and redemption rights in normal and stressed conditions; all fees and their maximum amounts; fair and any preferential treatment; the latest annual report and NAV; the issue and sale procedure; past performance; the prime broker; and how and when periodic information will be disclosed. The exam material lists fifteen items and omits the last, which the law has required since 2013.
Investors also learn before investing of any contractual discharge of the depositary's liability, and of any change to that liability without delay. Where a prospectus is required, only what it lacks is added. Periodically, the AIFM discloses the share of assets under special arrangements because they are illiquid, any new liquidity arrangements, and the fund's current risk profile and the systems used to manage it; for leveraged funds it manages or markets in the EU, also any change in maximum leverage or reuse rights and the total leverage used.
What does the AIFM report to CySEC?
CySEC receives regular reports on the main instruments traded for the funds, the markets where the AIFM is a member or trades actively, and each fund's principal exposures and concentrations; and, for each EU AIF managed and AIF marketed in the EU, the illiquid share, new liquidity arrangements, the risk profile and the systems for managing market, counterparty, liquidity, operational and other risks, the main asset categories and stress-test results. Frequency is half-yearly for managers above the thresholds with up to €1 billion under management, quarterly above €1 billion and for any fund above €500 million, and yearly for unleveraged funds that buy control of unlisted companies. On request CySEC also gets the annual reports and a detailed list of all funds managed at each quarter-end.
Leverage is substantial when exposure under the commitment method exceeds three times net asset value. The AIFM then reports overall leverage, how much of it comes from borrowed cash or securities and how much from derivatives, how far assets have been reused, and the five biggest lenders of cash or securities with the amount from each. A non-EU AIFM whose Member State of reference is Cyprus reports this only for the EU AIFs under its management and the non-EU AIFs it markets in the Union; the exam material frames this as a Cyprus branch of a non-EU manager, but since 2013 the test has been the Member State of reference. CySEC may ask for more to monitor systemic risk and informs ESMA.
How to think about it
Sort by audience and clock. Investors: before investing, the sixteen-item pack; afterwards, the annual report on request (six months, or four inside a published financial report) and periodic updates on illiquid assets, risk and leverage, with depositary-liability changes without delay. CySEC: regular data on markets, exposures, liquidity, risk and stress tests, more for funds leveraged above three times NAV, and reports and quarterly lists on request. Everything stays at fund level and in aggregate.
Common mistakes
Mixing up the deadlines. Six months for the annual report, four inside a published annual financial report, two for a Cypriot AIF's half-yearly report.
Expecting each named person's pay to be disclosed. Pay is shown in aggregate, split by senior management and material risk takers.
Holding depositary-liability changes for the next report. They are notified without delay.
Reporting investor identities to CySEC. Leverage reporting names the five biggest lenders, not investors.
Forgetting the leverage test. Substantial means exposure above three times NAV under the commitment method.
Legal references
- The Alternative Investment Fund Managers Law of 2013 (Law 56(I)/2013), consolidated Greek text on CyLaw (amendments up to Law 9(I)/2025) (opens in a new tab)
Article 29 (annual report) · Article 30 (disclosure to investors) · Article 31 (reporting to CySEC)
- The Alternative Investment Funds Law of 2018 (Law 124(I)/2018), consolidated Greek text on CyLaw (no amending laws) (opens in a new tab)
Articles 76–78 (annual and half-yearly reports)
- Commission Delegated Regulation (EU) No 231/2013 supplementing the AIFMD, as amended (opens in a new tab)
Articles 103–107 (annual report) · Articles 108–109 (periodic disclosure) · Articles 110–111 (reporting, substantial leverage)
- Directive 2011/61/EU on Alternative Investment Fund Managers (AIFMD), as amended (opens in a new tab)
Articles 22–24 (Articles 23–24 amended by Directive (EU) 2024/927, not transposed in Cyprus as at 28 September 2026)
- CySEC Circular C768 on the annual reports of AIFs and AIFLNPs (opens in a new tab)
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