- with readers working within the Securities & Investment industries
Welcome to the Q1 2026 funds newsletter. This edition covers the topics below. We hope you will find this newsletter of interest.
- Cayman Islands Publishes Tokenised Funds Amendments
- CARF Registration Deadline Extended to 2027
- VASP, Mutual & Private Funds Amendment Acts Enacted
- Tokenised Funds in Cayman: Legal and Regulatory Framework
- Extension of Penalties for Revised Cayman Fund Fees
- CIMA Updates VASP Regulatory Measures
- Updates to Annual Fees for Cayman Regulated Funds
- Private Credit Funds: Governance and Liquidity Considerations
- CIMA Introduces Prudential Survey for SIBA Registered Persons
- Companies (Amendment) Act 2024 Now in Force
- 2026 Regulatory Filing Deadlines
- Latest Investments and Securities Figures
- AML & Compliance Training
- Stuarts Humphries Recognised in Chambers Global 2026
- Funds Publications, Podcasts and Videos
- Events
Cayman Islands Publishes Tokenised Funds Amendments
Legislative amendments to the Mutual Funds Act, Private Funds Act and Virtual Asset (Service Providers) Act establish a clarified framework for tokenised fund interests, confirming their regulatory treatment and delineating when VASP registration or licensing is required. The changes align treatment across open and closed-ended funds and reduce classification uncertainty. Fund operators should reassess existing structures, disclosures and governance to ensure compliance and determine whether any activities fall within the amended VASP regime.
CARF Registration Deadline Extended to 2027
The Tax Information Authority has extended the registration deadline under the Tax Information Authority (International Tax Compliance) (Crypto-Asset Reporting Framework) Regulations, 2025 to 31 January 2027 for Cayman Reporting Crypto-Asset Service Providers, deferring the prior 30 April 2026 deadline pending portal readiness. In-scope entities must prepare to submit prescribed information via the DITC Portal and appoint a Cayman Islands based principal point of contact meeting local presence requirements. Funds and managers should assess classification, update governance and ensure readiness for registration and ongoing reporting compliance.
VASP, Mutual & Private Funds Amendment Acts Enacted
Parliament has enacted amendments to the Virtual Asset (Service Providers) Act (2024 Revision), the Mutual Funds Act and the Private Funds Act, with publication in the Legislation Gazette on 24 March 2026. The reforms confirm that the issuance of digital equity or digital investment tokens by regulated funds does not constitute "virtual asset issuance" for VASP purposes and align key definitions across the statutes. For sponsors and managers, this clarifies regulatory scope, supports AML and supervisory certainty, and enables tokenised fund structures within the existing Cayman funds framework.
Tokenised Funds in Cayman: Legal and Regulatory Framework
Tokenised fund interests in the Cayman Islands are accommodated within the existing framework under the Mutual Funds Act and Private Funds Act, with the Cayman Islands Monetary Authority maintaining that tokenisation does not alter a fund's legal classification or core obligations. Regulatory focus remains on applying established governance, AML and operational requirements to digital structures, with potential implications under the Virtual Asset (Service Providers) Act where relevant activities arise. Sponsors should ensure alignment between legal documentation and technology, and maintain oversight of service providers to address operational and compliance risks.
Extension of Penalties for Revised Cayman Fund Fees
The Cayman Islands Monetary Authority extended the deadline for payment of revised 2026 annual fees for regulated mutual funds and private funds to 15 March 2026; that deadline has now passed. Any outstanding incremental balances, including sub-fund and AIV fees, may result in non-compliance and exposure to penalties under the Mutual Funds Act and Private Funds Act. Funds and operators should urgently confirm that all revised fees have been settled via REEFS and address any deficiencies to mitigate regulatory and enforcement risk.
CIMA Updates VASP Regulatory Measures
The Cayman Islands Monetary Authority has issued a binding market conduct Rule and accompanying Statement of Guidance for virtual asset service providers under the Virtual Asset (Service Providers) Act and the Monetary Authority Act (2021 Revision), consolidating and updating conduct standards. The measures introduce enhanced expectations on conflicts, disclosures and client treatment, and rationalise existing rules by repealing duplicative provisions. VASPs and related groups should review and update governance, disclosure and compliance frameworks to align with the Authority's clarified supervisory approach and consolidated regulatory instruments.
Updates to Annual Fees for Cayman Regulated Funds
The Cayman Islands Monetary Authority clarified the revised annual fee framework effective 1 January 2026 for regulated mutual funds and private funds under the Mutual Funds Act and Private Funds Act, including updated fees for funds, sub-funds and AIVs and revised REEFS presentation. As at mid-March 2026, the statutory payment deadlines of 15 January and 15 February have passed; any unpaid incremental balances may result in non-compliance and penalties. Fund operators should confirm all revised fees have been fully settled and that internal processes reflect the updated fee structure.
Private Credit Funds: Governance and Liquidity Considerations
Private credit funds established in the Cayman Islands, typically structured as exempted limited partnerships, remain subject to governance, valuation and liquidity requirements under the Private Funds Act (as Revised) and supervision by the Cayman Islands Monetary Authority. Illiquid assets necessitate robust valuation methodologies and carefully calibrated liquidity terms to avoid mismatches with investor rights. Boards and sponsors are expected to maintain effective oversight, particularly in relation to conflicts, valuation processes and disclosure, with documentation and controls aligned to the fund's strategy and regulatory expectations.
CIMA Introduces Prudential Survey for SIBA Registered Persons
The Cayman Islands Monetary Authority has introduced a mandatory Prudential Information Survey for Registered Persons under the Securities Investment Business Act (as Revised), to be filed via REEFS by 31 March 2026 alongside the existing Annual Declaration. While not directly applicable to regulated funds, the requirement is relevant to fund managers and advisers operating as Registered Persons, increasing regulatory reporting obligations and supervisory scrutiny. Firms should ensure systems and controls support accurate and timely submissions, reflecting CIMA's focus on prudential oversight and risk assessment.
Companies (Amendment) Act 2024 Now in Force
The Companies (Amendment) Act, 2024, in force since 1 January 2026, amends the Companies Act (as Revised) to introduce a non-court procedure for solvent reductions of share capital by special resolution and director solvency declaration, streamlining corporate actions for Cayman fund vehicles and holding entities. Additional reforms, including new conversion routes and expanded continuation provisions, increase structuring flexibility. Fund sponsors and managers should consider these changes when undertaking restructurings, distributions or reorganisations, with reduced execution time and cost but continued director responsibility for solvency assessments.
2026 Regulatory Filing Deadlines
Please be aware of the 2026 regulatory filing deadlines and the 2026 FATCA and CRS Reporting Deadlines for Cayman-domiciled entities – including funds, registered companies, and financial institutions – under the CRS, FATCA, and Economic Substance regimes with the Cayman Islands' Department for International Tax Cooperation (DITC).
The deadline for Economic Substance Return filings (for entities with a financial year end of 31 December) and CIMA de-registrations is 31 December 2026.
The beneficial ownership regime took effect on 1 January 2025, requiring immediate compliance to avoid penalties. Director registration renewals or cancellations must be completed via CIMA's online portal using existing credentials. Additionally, the CRS list of Reportable Jurisdictions has been updated. Regularly reviewing the DITC Updates Bulletin is advised.
The Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 has been published. See our legal update on how CRS 2.0 may affect your organisation.
For support, contact your usual Stuarts Humphries attorney or Jon McLean, Head of Banking & Regulatory.
Latest Investments and Securities Figures
Most regulated sectors in the Cayman Islands have remained stable over the past year, with Private Funds increasing by approximately 2.5% and Mutual Funds remaining broadly flat. Private Funds peaked at 17,741 in Q3 2025 and closed the year at 17,722, reflecting continued strength in the jurisdiction's funds market. While economic substance requirements have influenced structuring decisions for some sponsors, practical solutions are available to support Cayman-based management structures, and these should be considered in the context of sustained market stability and investor familiarity.
Stay Compliant with our AML & Compliance Training
Stuarts offers CIMA-compliant AML and compliance training for financial services professionals in the Cayman Islands. This annual training covers anti-money laundering (AML), counter-terrorism financing (CTF), proliferation financing (PF) and sanctions, as required by CIMA for directors, AML officers, senior management and relevant staff. Sessions are led by Reuben Foster, former CIMA Chief Analyst and now Head of Group Compliance at Stuarts. To book your training, contact Jon McLean or Reuben Foster today.
Stuarts Humphries Recognised in Chambers Global 2026
Stuarts Humphries has been recognised in the Chambers Global Guide 2026, with rankings in Corporate and Finance and Investment Funds, and inpidual recognition for Chris Humphries. The Investment Funds practice maintains their ranking, reflecting sustained advisory work on Cayman funds under the Mutual Funds Act and Private Funds Act. Chambers notes that the firm "stands out for its deep experience in Cayman Islands funds matters", underscoring the value of experienced counsel in navigating regulatory and transactional complexities.
Funds Publications
- Chambers Global Guide 2026: Cayman Islands: An Investment Funds Overview
- Chambers FinTech Guide 2026: Cayman Islands: An Introduction to Fintech Legal
- Legal500 Alternative Investment Funds Comparative Guide 2026 (Cayman Islands): Establishing Your Cayman Fund, Investment Manager, Fintech Business or Web3 Venture
- Chambers Global Guide 2025: In Depth Overview of Investment Funds in the Cayman Islands
- Chambers FinTech Guide 2025: Introduction to FinTech in the Cayman Islands
- Mondaq Comparative Guide 2025: Capital Markets in the Cayman Islands
- Legal500 Fintech Country Comparative Guide 2025: Alternative Investments: Crypto Funds and Digital Assets Thrive Under Innovative Legislation
- Mondaq Comparative Guide 2023: Securitisation in the Cayman Islands
- Business Reporter 2024: Empowering Web3 through Innovative Legislation in the Cayman Islands
- Lexology Panoramic 2024 Chapters: Private Equity: Fund Formation in the Cayman Islands
- Lexology Panoramic 2024 Chapters: Private Equity: Transactions in the Cayman Islands
- Chambers Practice Guide 2023: Doing Business in the Cayman Islands: Digital Assets, Trends and Developments
- Hedge Week Cayman Report 2023: Powers of the Founder of Foundation Companies
- Legal500 Alternative Investments Guide 2022: Rise in Fintech Funds in the Cayman Islands
- ICLG Corporate Governance 2021: Corporate Governance in the Cayman Islands
- Cayman Structures for Crypto, Web3 and Blockchain Entities
Our Podcasts on Mutual Funds & Private Funds
Stuarts released podcasts on the Registration of Private Funds and Mutual Funds in the Cayman Islands. The podcasts include a brief summary on; the types of private funds (including non-fund arrangements) and mutual funds in the Cayman Islands and their registration requirements.
Podcast - Mutual Fund Registration in the Cayman Islands
Podcast - Private Fund Registration in the Cayman Islands (Part 1)
Podcast - Private Fund Registration in the Cayman Islands (Part 2)
Our Videos on Investment Funds
View our recently released videos on the registration of private funds, mutual funds and crypto funds in the Cayman Islands. The videos include a brief summary on the types of funds (including non-fund arrangements) and their registration requirements.
Video - Private Funds in the Cayman Islands
Video - Mutual Funds in the Cayman Islands
Video - Crypto Funds in the Cayman Islands
Upcoming Events
- 10 April, 8 May and 5 June (virtual): We're proud to support the work of the Central Caribbean Marine Institute and will attend their series of "Reefs Go Live" broadcasts from Little Cayman's coral reefs. Register here to attend.
- 16-17 April: Our team will attend ReConnect 2026, a Cayman Islands reinsurance conference bringing together global industry participants to discuss market trends, structuring and risk transfer developments.
- 18 April: We will participate in the Cayman Islands Chamber of Commerce Earth Day Cleanup.
- 19-22 April: GAIM Ops Cayman, a leading alternative investment operations conference bringing together global managers, investors and service providers to discuss compliance, governance and operational developments in the funds industry.
- 1-5 June: Chris Humphries and Megan Wright will be in New York. Reach out if you would like to connect.
Recent Events
- 16 January: We were delighted to play in the Putt Fore Paws golf fundraiser in aid of the Cayman Islands Humane Society.
- 23 January: Chris Humphries, Megan Wright and Jonathan McLean spoke to students at the Truman Bodden Law School Employability Fair.
- 31 January 2026: We were delighted to attend the Blue Tie Dinner in aid of the National Trust Cayman Islands' Blue Iguana Conservation Programme.
- 9-13 February: Our team attended Cayman Crypto Week, hosted by the Blockchain Association of the Cayman Islands.
- 13 March: We were delighted to attend the Enhancing Compliance Excellence in the DNFBP Sector session, hosted by the Legal Services Supervisory Authority, Department of Commerce & Investment, Cayman Islands Institute of Professional Accountants, and the Office for Strategic Action on Illicit Finance.
- 20 March: Our Team attended the first "Reefs Go Live" broadcast, hosted by the Central Caribbean Marine Institute.
- 21 March: Megan Wright and Adam Russell-Knee were delighted to attend the Green Tie Gala, alongside Nicole Fleury, who has volunteered for the event since its inception.This year's chosen charities include the Cayman Islands Red Cross and The Bridge Foundation.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
