Updates for CIMA registered directors: one-time amnesty scheme and upcoming deadlines for renewal or surrender

The Cayman Islands Monetary Authority has launched a one-time amnesty scheme to provide eligible registered directors a limited opportunity to settle outstanding annual fees and accrued penalties at a discounted rate. 

Announced on 3 September, the One-time Non-Compliant Directors' Amnesty Scheme will be effective 16 September to 15 October 2025, though eligible registered directors must review and confirm their status in advance.

The Cayman Islands Monetary Authority (CIMA) registered directors are strongly encouraged to take advantage of this 30-day window as an opportunity to restore their good regulatory standing. 

Registered directors must also be aware of CIMA’s upcoming renewal and cancellation deadlines for registration to minimise fees in 2026. 

What is a CIMA registered director?

Under the Directors Registration and Licensing Act, 2014, as amended, persons acting as a director of a company that is or will be a "covered entity" are required to be registered or licensed with CIMA. Directors of covered entities are divided into three categories: registered directors, professional directors and corporate directors and different requirements apply to each category.  

This update is specific to registered directors – that is, a natural person appointed as a director of fewer than 20 covered entities with such person registered individually with CIMA.  

For more information of the director registration and licensing regime, see our briefing: Director registration and licensing in the Cayman Islands.

The one-time action amnesty scheme 

The scheme is voluntary and will be effective from 16 September to 15 October 2025 and will be available to registered directors who, as of 31 August 2025, have more than two years of unpaid annual fees.

CIMA has directly contacted the relevant registered directors that meet the criteria for the scheme via e-mail, confirming the following:

• applications under the scheme will only be accepted via the CIMA Gateway portal
• the relevant registered directors that have been contacted by CIMA should log in to the Gateway portal to review and confirm their status in advance of 16 September (additional details will be available on the Gateway portal effective 16 September)
• registered directors who meet the eligibility criteria (but have not been contacted by CIMA regarding the scheme), should directly contact CIMA by e-mail: amnesty@cima.ky
• the scheme is not applicable to directors that are presently under investigation or subject to enforcement action by CIMA or another regulatory body
• once the scheme closes, full fees and penalties will apply without exception 

Where a registered director is not in good standing with CIMA, this may lead to delays with the surrender of their director registration (see below) and potential administrative fines among other things.  

Renewal or surrender of registered directors for 2026 

Registered directors are required under the Directors Registration and Licensing Act, 2014 to renew their registration and pay the annual fee to CIMA by 15 January 2026.

Failure to register, renew or update director information (such as ceasing to act as a director of a covered entity) in accordance with the relevant deadlines may result in penalties under Cayman's administrative fines regime. Failure to renew the registration or license will result in the covered entity ceasing to be in good standing with CIMA and potentially in breach of regulations applicable to covered entities, resulting in further substantial administrative fines for that entity. 

What are the next steps? 

We advise directors to address the requirements for renewal or cancellation of their registrations as soon as possible. Any director that has ceased to be appointed as a director of any covered entity (either due to the resignation of the director or if the covered entity has completed its deregistration with CIMA) and does not intend to act as a director of a covered entity in the future may surrender or cancel their registration. To avoid incurring fees for 2026, the cancellation must be completed by 31 December 2025. 

Where a director is intending to surrender or cancel their registration on the basis that the covered entity to which they are appointed is deregistering with CIMA, we would note that that the director may only proceed once the covered entity has completed the deregistration process with CIMA.

For further information on the termination of Cayman vehicles and minimising 2026 fees, see our briefing: Termination of Cayman entities and minimising 2026 fees.

All updates, renewals and surrenders / cancellations are managed through CIMA's online portal.

For further information concerning any of the above matters, 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