Annual audit filings for Cayman Islands regulated funds: deadlines, filing extensions and exemptions

As the 30 June 2026 deadline approaches for filing audited financial statements with the Cayman Islands Monetary Authority (for regulated funds with a 31 December financial year-end), some funds may be considering whether they need to apply for an audit filing extension or, where eligible, for an audit exemption.

This briefing provides a high-level summary of each of these application processes. 

Audit filing requirements 

Under both the Mutual Funds Act (Revised) (MFA) and the Private Funds Act (Revised) (PFA), regulated funds are required to submit annual audited financial statements to the Cayman Islands Monetary Authority (CIMA). These audited financial statements must be filed within six months of the relevant fund's financial year-end along with the fund annual return (FAR) and the accompanying fund annual return fee (FAR Fee). 

For funds with a financial year end of 31 December 2025, the filing of the audited financial statements, the FAR and FAR Fee should be submitted before 30 June 2026.

The 2025 FAR reporting period will be the last year for which a separate FAR fee will be payable at the time of submitting the FAR and audited financial statements to CIMA. Going forward, the FAR Fee will be consolidated with the annual registration fee for each regulated fund. Accordingly, no separate FAR fee will be required when filing in 2027 for the 2026 reporting period. This change is intended to reduce duplication, simplify compliance requirements and improve administrative efficiency for CIMA in its role as funds regulator.

CIMA audit filing extensions

A CIMA regulated fund is permitted to apply for up to three audit filing extensions (each extension covering a one-month period) to provide additional time to file the fund's audit. Following changes to the CIMA audit filing extension request process in 2025, a fund may apply at one time for up to three extensions.

A regulated fund must be in good standing with CIMA in order to apply for an audit filing extension. Where a regulated fund is not in good standing with CIMA (for example, where there are prior outstanding financials and accompanying filings), the fund will not be eligible to apply for an audit filing extension until it has brought any relevant missed CIMA filings up to date and paid any outstanding fees to CIMA.

To request an audit filing extension, a regulated fund must submit the REEFS form, the required supporting documents, and an application fee to CIMA. The application must be submitted by a current core service provider for the regulated fund with access to the CIMA REEFs Portal. Ogier can assist with preparing and submitting these filings. 

An application for a first extension does not require external supporting documents. For a second or third extension, the application must be accompanied by a detailed letter from the fund’s auditor comprehensively explaining the reasons for the delay. 

CIMA audit exemption

Under both the MFA and PFA, CIMA has the discretion to grant an exemption from the audit requirement to provide audited financial statements with respect to the whole or part of any financial year of the regulated fund, either absolutely or subject to conditions. 

CIMA's regulatory policies set out the circumstances in which a fund may apply for an exemption. Commonly relied upon grounds include where a fund has not launched and is being liquidated or de-registered, where a fund has launched but has been unsuccessful in raising sufficient capital for sustainability and where a fund is unable to obtain audited accounts due to events such as bankruptcy proceedings, legal or regulatory enforcement actions.

In practice, the requirements for an audit exemption application include operator resolutions, an affidavit of an operator, and payment of a filing fee. Pursuant to CIMA's regulatory policies, there may be additional accompanying documentation required depending on the basis of the application. For example, CIMA may require a form of written confirmation from the fund's administrator or registrar and transfer agent confirming certain matters.

CIMA will assess each audit exemption request on a case-by-case basis. 

Other considerations

A private fund that has not received capital contributions from investors for the purposes of investments is not required to file its audited financial statements and FAR with CIMA within six months of its financial year-end. In this case, an audit exemption is not applicable. Instead, the private fund must file a declaration with CIMA within six months after the end of the relevant financial year confirming that the private fund has not received any capital contributions from investors.

Where a regulated umbrella fund structure (such as a segregated portfolio company or unit trust) is submitting an audit extension filing application, a separate application and fee is payable for each sub-fund which files individual audited financial statements. However, where the umbrella fund is a regulated private fund or, where the umbrella mutual fund files consolidated audited financial statements, only one application and fee is payable. Similarly, where the audited financial statements for an umbrella fund structure are unconsolidated, separate audit exemption applications may be submitted for each sub-fund. 

Timing

An application for either an audit filing extension or an audit exemption should be submitted in advance of the relevant audit filing deadline. Funds should consult with Cayman counsel to determine appropriate timing for such filings. 

How Ogier can help

For advice concerning any of the above matters, please contact your usual Ogier attorney or any of the contacts listed in this briefing.

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Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

Regulatory information can be found under Legal Notice