Cyprus FDI Law

Cyprus recently established a framework for screening foreign direct investment. The relevant law was published in the Official Gazette on 14 November 2025, and will be enacted on 2 April 2026, titled “Law on the Establishment of a Framework for Screening Foreign Direct Investments of 2025” (Law 194(I)/2025).

The law introduces a screening process in line with the Regulation (EU) 2019/452 for foreign direct investments that may raise concerns for security and public order.

A foreign direct investment (“FDI”) is defined as an investment of any kind by a foreign investor aiming to establish or to maintain lasting and direct links between the foreign investor and the entrepreneur to whom, or the undertaking to which, the capital is made available in order to carry on an economic activity in a Member State, including investments which enable effective participation in the management or control of a company carrying out an economic activity.

A foreign investor is an individual who is not a national of an EU or EEA Member State, nor of Switzerland, or an undertaking established in a third country (outside the EU, EEA, or Switzerland) that intends to conduct or has conducted an FDI in Cyprus.

A notification is mandatory by a foreign investor prior to conducting an FDI in cases:

• where the FDI equals or exceeds the amount of EUR 2.000.000, individually or in combination with other transactions of the same parties within a twelve-month period; and
• the FDI relates to an undertaking of a strategic sector; and
• the FDI results to the acquisition of special participation. Special participation means the acquisition, directly or indirectly, of 25% or more of the share capital or voting rights of the undertaking.

Strategic sectors include energy; transport; water supply; health; education; tourism; telecommunications; media; data processing and storage; aerospace; defence; election or financial services; food security; dual-use technologies; cybersecurity; nanotechnology; biotechnology; land and real estate important for the use of these infrastructures.

The notification must be filed prior to the completion of an FDI, and the approval from the Authority is required for the transaction to proceed. The Cyprus Ministry of Finance (the “Authority”) is the authority in charge to examine, approve, forbit or suspend a transaction. An Advisory Committee, formed by representatives of seven Ministries, provides information and reasoned advice to the Authority in regards to the undergoing screenings.

The Authority can examine any FDI, irrespective if the conditions for mandatory filing are met, if the FDI may affect the security or public order. If the FDI is not subject to mandatory filing, the Authority may examine the FDI within 15 months of completion; while if the FDI is subject to mandatory filing which has not been submitted, the Authority may examine the FDI within 5 years from completion.

Administrative and financial penalties can be imposed for not filing a mandatory notification, in addition to any other rights of the Authority. The Authority may take actions for the issuance of a prohibitory and/or injunctive court order in cases of violation of the Law.

The Authority will decide within twenty business days from the submission of a completed filing for approval of an FDI, as to whether the FDI will be screened by the Authority. If the Authority decides that the FDI will not be screened, the Authority will inform the foreign investor within five business days from the date of their decision. If the Authority decides that the FDI will be screened, the Authority will inform the foreign investor within five business days from the date of their decision and will decide within sixty-five business days from the date of their decision to screen the FDI, as to whether the FDI is likely to affect the Cyprus Republic's security or public order.

The decisions of the Authority are subject to appeal before the Administrative Court pursuant to Article 146 of the Constitution of the Republic of Cyprus.

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.