- in United States
The scope of regulatory requirements in the Cayman Islands has increased significantly in recent years and requires Cayman-domiciled entities to meet ongoing regulatory filing requirements, in addition to other obligations as set out by the regulatory bodies of the Cayman Islands.
By staying informed and seeking guidance from legal experts, Cayman entities can navigate the complexities of the regulatory landscape with clarity and ease.
We have provided a summary of the regulatory filing dates for Cayman-domiciled entities (including regulated funds), for 2026 below.
|
2026 Deadline |
Regulatory Filings |
Legal Entity Type |
Authority |
|---|---|---|---|
|
Ongoing |
Beneficial Ownership information or exemption to be submitted to the Registrar of Companies on a monthly basis. |
All Cayman companies, Limited Liability Companies, Limited Liability Partnerships (and those registered by way of continuation in Cayman), including ordinary companies, exempted companies and exempted segregated portfolio companies. |
RoC |
|
Quarterly (31 March, 30 June, 30 September, 31 December) |
CIMA VASP Financial Returns submission due for the reporting period ending 30 September 2026, including required financial information, confirmations and supporting disclosures under the Virtual Asset (Service Providers) regime. | Virtual Asset Service Providers registered or licensed with CIMA. | CIMA |
| Within 30 days of commencing business | Where an FI has reporting obligations under FATCA it will also be required to obtain a GIIN (and enter this information when it registers on the TIA Portal). | FI that has reporting obligations under FATCA. | IRS |
| Within six months of entity's financial year end | Submission of audited financial statements and Fund Annual Return for the relevant financial year. | Mutual Funds and Private Funds regulated by CIMA with financial year ends other than 31 December. | CIMA |
| 1 January | CARF regime becomes effective: entities defined as "Cayman Reporting Crypto-Asset Services Providers" must assess whether they fall under CARF, register and begin record-keeping/reporting obligations. First reports are due in 2027 for 2026 reporting period. |
Cayman Reporting Crypto-Asset Service Providers. Entities incorporated, registered, established or regulated in the Cayman Islands (or with place of effective management in Cayman) which provide a service effectuating crypto-asset exchange/transactions for customers (platforms, exchanges, brokers/dealers, intermediaries, etc.). |
DITC |
|
15 January |
Annual licence fee renewals due to the Cayman Islands Monetary Authority ("CIMA") for regulated entities. |
Mutual Funds, Private Funds, Money Services Businesses, Securities Investment Business Operators, Company Managers, Corporate Service Providers, Banks, Trust Companies, Building and Cooperative Societies, Insurance Companies, Company Managers, Corporate Service Providers, Virtual Asset Service Providers, entities regulated under the Directors Registration and Licensing Act. |
CIMA |
|
15 January |
Annual declaration for directors registered with CIMA under the Directors Registration and Licensing Act. |
All Directors registered with CIMA under the Directors Registration and Licensing Act. |
CIMA |
|
15 January |
Annual declaration for entities registered as a Registered Person under the Securities Investment Business Act. |
Securities Investment Business Operators. |
CIMA |
|
31 January |
Economic Substance Notification ('ESN') due to the DITC via the Registrar of Companies. |
All Cayman companies (including foundation companies), LLCs, LLPs, and partnerships (including exempted limited partnerships, general partnerships and limited partnerships). |
DITC |
|
31 January |
Annual Return and annual fees due to the Registrar of Companies for all Cayman Islands entity types. |
All Cayman companies (including foundation companies), LLCs, LLPs, registered foreign companies and partnerships (including exempted limited partnerships, general partnerships, limited partnerships and foreign limited partnerships). |
RoC |
|
30 April |
Registration deadline (if newly in scope) for entities defined as Financial Institutions under Common Reporting Standard ('CRS') and Foreign Account Tax Compliance Act ('FATCA') legislation for the prior year ending 31 December. |
Any Cayman-domiciled entity which has been defined as a "Financial Institution" for AEOI purposes. |
DITC |
|
30 June |
Audited Financial Statements and Fund Annual Return due for all CIMA-registered funds for the prior year ending 31 December. |
Mutual Funds and Private Funds. |
CIMA |
| 30 June | Schedule annual AML training for directors. |
CIMA requires Anti Money Laundering (AML), Counter Terrorism Financing (CTF), Proliferation Financing (PF) and Sanctions related training to ensure that local regulations and associated duties are understood by all relevant personnel of FSP's, including Directors, AML Officers, Senior Management and all applicable staff. This training must be conducted at least annually. Please contact Reuben Foster to arrange your annual AML training. |
CIMA |
|
31 July |
CRS and FATCA reporting due to the DITC for all Reporting Financial Institutions for the prior year ending 31 December. |
Any Cayman-domiciled entity which has been defined as a "Financial Institution" for AEOI purposes. |
DITC |
|
31 July |
CRS Filing Declaration (Nil return) | Any Cayman-domiciled entity which has been defined as a "Financial Institution" for CRS purposes. | DITC |
| 1 September | Annual review of Operational Matters |
The governing body of all CIMA regulated entities should hold an annual meeting to review and approve certain matters for compliance with their legal and regulatory requirements. Please contact Jon McLean to arrange your annual review of operational matters and to set up your annual board meeting. |
CIMA |
| 1 September | Recommended deadline to begin year-end termination planning for defunct or liquidating entities. Entities remaining active beyond 31 December will incur 2027 annual fees. | All Cayman companies, LLCs, partnerships and CIMA-regulated entities considering termination. | RoC / CIMA |
|
15 September |
CRS Compliance Form due for the prior year ending 31 December. |
Any Cayman-domiciled entity which has been defined as a "Financial Institution" for AEOI purposes. |
DITC |
|
31 December |
De-registration deadline to avoid next year's fees for CIMA registered entities and Directors. |
Any CIMA-registered entity. |
CIMA |
| 12 months following the previous financial year end | Economic Substance Returns due to the Department for International Tax Cooperation ('DITC') for "relevant entities" carrying on a "relevant activity". Entities must complete their Economic Substance Return within 12 months of the applicable year-end (e.g. 31 March, 30 June, 30 September or 31 December). | Relevant entities, which includes all Cayman Islands companies, LLCs, LLPs, registered foreign companies and partnerships (including exempted limited partnerships, general partnerships, limited partnerships and foreign limited partnerships) and also foundation companies. | DITC |
| 31 January 2027 (for entities first in scope in 2026) | Initial CRS registration and submission of Principal Point of Contact (PPoC) information where 2026 is the entity's first CRS reporting period. | Financial Institutions newly in scope for CRS. | DITC |
| 2027 | From the 2026 reporting period (filed in 2027), CRS reporting and the CRS Compliance Form deadlines will move to 30 June under the updated CRS 2.0 regime. | Reporting Financial Institutions under CRS. | DITC |
It is recommended to review the Updates Bulletin regularly, on the website for the Cayman Islands Department for International Tax Cooperation (DITC).
Enforcement under the beneficial ownership regime in the Cayman Islands took effect on 1 January 2025. All clients must ensure their Cayman entities are compliant with the new regime to avoid enforcement measures.
Director registration, renewals and cancellations with the Cayman Islands Monetary Authority (CIMA) should be made and paid for through CIMA's portal by using the login credentials previously supplied upon registration.
Forms and Online Portal Access can be viewed on the DITC website.
The CRS has updated the list of Reportable Jurisdictions to include Armenia, Rwanda, Tunisia, Morocco, Senegal, and Uganda for reports due in 2025 and onwards. The list can be viewed on the DITC website.
The CRS enforcement guidelines v1.4 March 2023 detail some of the potential fines for entities and certain individuals in respect of the CRS regime. 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.
Originally published 17 December 2025
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.
