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

There have been recent updates to the audit filing extension request process for Cayman Islands Monetary Authority regulated mutual funds and private funds. These updates came into effect on 6 May 2025.

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 with CIMA within six months of the relevant fund's financial year-end unless such fund is granted an extension to the filing deadline for their audited financial statements by CIMA. 

CIMA will consider granting extensions for up to a maximum of three months after the original audit filing deadline.   

CIMA has recently issued an updated Regulatory Enhanced Electronic Forms Submission (REEFS) form for submitting an audit filing extension request. The new REEFS form, which came into effect on 6 May 2025, introduced a number of changes to CIMA's audit filing extension request process.

Key changes to CIMA's audit filing extension request process

•    It is now possible to apply for multiple audit filing extensions at one time: one, two or even three extensions (covering a period of up to three months after the original audit filing deadline) may be applied for at one time from CIMA. Previously, only one audit filing extension application could be submitted to CIMA at a time.

•    The new REEFS form has been enhanced to provide that regulated private funds, and not just regulated mutual funds, may now use CIMA's REEFS portal to submit an audit filing extension request.

•    There is a new deferral option available within the new REEFS form – noting however that this may only be used for extenuating circumstances and would not amount to a waiver of the relevant audit requirement.

Requirements for an audit filing extension for a Cayman regulated fund

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.  

As a reminder, an audit extension filing request should be submitted in advance of the relevant audit filing deadline. For example, where a fund has a financial year-end of 31 December 2024, the deadline to submit the audit would be 30 June 2025. On this basis, the first audit extension filing request would need to be filed with CIMA before 30 June 2025.

To request an audit filing extension, a regulated fund must submit the REEFS form, the required supporting documents, and an application fee to CIMA. For a second or third extension, the application must also include a detailed letter from the fund’s auditor explaining the reasons for the delay. CIMA expects the auditor’s letter for a three-month extension to be more comprehensive than for a two-month extension. The application fee is CI$625 (US$762) per one-month extension and must be paid when the request is submitted.

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