Compliance calendar for Cayman Islands investment funds

Payment is made by your registered office provider. Confirm that your registered office provider is in funds to pay.

If this is not paid by 15 January, penalties will start to accrue from 16 January.

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Deadline for renewal of annual CIMA director registration for mutual funds only.

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Deadline to file economic substance notification (ESN) with the Department for International Tax Co-Operation (DITC).

If this is not filed and the fees are not paid by 31 March, penalties will start to accrue from 1 April.

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Filing is made by registered office provider.

Confirm that your registered office provider is in funds to pay. Annual return requires confirmation of nature of business. Provide selection from pre-approved list to registered office provider well in advance.

Note that the annual return cannot be filed until the above ESN has been made.

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Directors of Cayman Islands domiciled funds are required to receive Cayman-specific training on the money laundering, terrorist financing, proliferation financing and targeted financial sanction risks facing those businesses. Such training should be provided at least annually, or more frequently where there are changes to the legal or regulatory landscape or where there are significant changes to a fund's business operations or customer base.

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Registration notification is only required once (in order to register a fund entity with the DITC).

Registration must be completed by 30 April after the fund entity becomes a Reporting Financial Institution (which will generally be the date on which the fund entity accepts subscriptions / contributions and commences trading activities).

Consequently, and by way of example, where a fund entity commences trading activities between 1 May 2025 and 29 April 2026 (inclusive), the entity's deadline for registration will be 30 April 2026. 

Registration notification is filed using the online DITC Portal.

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Filing is made by auditors.

Contact Ogier if extensions are required due to delays in preparing audited financial statements. An extension must be sought from CIMA in good time before the audit submission deadline (that is 30 June if the last financial year end is 31 December).

Audit filing extensions are granted monthly, for up to three months after the original deadline, at CIMA's discretion. Any requests for an extension after the first request must be accompanied by a letter from the fund’s auditor with a detailed explanation for the delay. There is flexibility to apply at one time for more than one extension. For further information read our client advisory:

Update to audit filing extension requests for Cayman regulated mutual and private funds.

 
CIMA-registered funds must file their audited annual financial statements and Fund Annual Return with CIMA.

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Confirm with your administrator and / or other FATCA / CRS services provider.

Ogier can provide FATCA / CRS services.

*The reporting deadline of 31 July is currently under industry consultation and amendments may be made to change the reporting deadline from 31 July to 30 June. We will update this compliance calendar as soon as the definitive position is confirmed. 

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Confirm with your administrator and / or other CRS services provider for purposes of filing.

Confirm with Ogier that your CRS Policies and Procedures are up-to-date and in compliance with latest obligations.

Form is filed via the DITC Portal.

*The reporting deadline of 15 September is currently under industry consultation and amendments may be made to change the compliance form reporting deadline from 15 September to 30 June. We will update this compliance calendar as soon as the definitive position is confirmed. 

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The governing body of all CIMA regulated investment funds should hold an annual meeting to review and approve certain matters for compliance with CIMA's Rule on Corporate Governance.

Confirm attendance with members of the governing body. Ogier can provide a detailed agenda to confirm matters to be considered as part of the Annual Governance Review, including the fund's AML Policies and Procedures, NAV Calculation Policy and CRS Policy, to ensure compliance with CIMA requirements for such annual review.

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