Cayman Islands funds and regulatory update: April 2026

This briefing provides a practical overview of recent legal and regulatory developments relevant to Cayman Islands funds.  

The following table sets out an executive summary of key updates, with further details on each topic in the sections below. 

In addition, we have an interactive compliance calendar for Cayman funds, which sets out the key dates for Cayman Islands investment funds in 2026 and can be used to auto-populate your own calendars and internal reminders. 

Summary of key developments 

New regulation for tokenised funds 

The Mutual Funds (Amendment) Act, 2026 and the Private Funds (Amendment) Act, 2026 came into force on 24 March 2026. Their main aim is to set out clear rules for tokenised mutual funds and tokenised private funds.  

Tokenised funds will be regulated in the same manner as traditional funds, and tokenisation does not change how a fund is classified. However, tokenised mutual funds and tokenised private funds must meet some extra requirements because of the use of digital equity or investment tokens. 

Alongside the amending Acts, the Virtual Asset (Service Providers) (Amendment) Act, 2026 has also come into force. This Act clarifies that the issuance of digital equity tokens and digital investment tokens by tokenised mutual funds and tokenised private funds respectively are excluded from the virtual asset service provider regime. This provides further certainty to the industry and delineates the funds regime from separate virtual asset regulation in the jurisdiction. 

Read more about the Cayman Islands tokenised fund regime.

DITC extends the deadline for filing certain CRS information 

Certain updates to the Common Reporting Standard (CRS) regime in the Cayman Islands took effect from 1 January 2026. See our client advisory for further detail on the amended CRS regime: Amendments to the Cayman Islands Common Reporting Standard Regulations.

On 21 January 2026, the Department for International Tax Cooperation (DITC) announced an extension of certain deadlines under the amended CRS regime. 

Under the CRS Amendment Regulations, Cayman Financial Institutions (other than exempted bodies) that became Financial Institutions in 2025 must register on the DITC Portal by 30 April 2026. However, the deadline to file two specific pieces of information has been extended to 31 January 2027 for all Cayman Financial Institutions: 

• appointment of a principal point of contact (PPoC) based in the Cayman Islands
• the date the institution became a Financial Institution 

This extension gives financial institutions more time to appoint a suitable Cayman-based PPoC. 

The DITC clarified that a PPoC is considered Cayman-based if: 

• an individual has a physical address in the Cayman Islands
• a legal person is incorporated, registered, or established in the Cayman Islands and has a physical address here (not just a mailing or correspondence address) 
  
  

Ogier Global’s team offers specialised FATCA / CRS Compliance, including Cayman PPoC services. For more information, please contact your usual Ogier representative. 

For further information on key dates for 2026 (including CRS deadlines), see our Cayman Islands investment funds – 2026 compliance calendar. 

CIMA issues clarification on the revision of fees payable by regulated mutual and private funds

Effective 1 January 2026,  the Cayman Islands government introduced a new fee structure for mutual funds and private funds. Instead of paying separate annual registration and annual return fees, regulated funds will now make one consolidated annual payment by 15 January each year. 

Pursuant to a General Industry Notice issued on 4 February 2026, the Cayman Islands Monetary Authority (CIMA) confirmed that the following revised consolidated annual fund and sub-fund fee amounts would apply from 1 January 2026: 

• the annual fee for registered funds is CI$4,125 (US$5,030)
• the annual fee for master funds is CI$3,075 (US$3,750)
• the annual fee per sub-fund for registered mutual funds is CI$750 (US$915)
• the annual fee per sub-fund or AIV for registered private funds is CI$525 (US$640)
   

CIMA also confirmed that annual return fees relating to financial years ending on or before 31 December 2025 will continue to be assessed at the pre-revised rates (ie CI$300 (US$366) or CI$150 (US$183), as applicable). 

The adjusted fee structure is intended to eliminate mid-year billing, simplify compliance obligations and to reduce duplicate payment cycles. 

Consolidation of the UK's sanctions list  

On 28 January 2026, the UK consolidated its sanctions screening into a single database affecting both the Cayman Islands and the British Virgin Islands.  

The OFSI Consolidated List of Financial Sanctions Targets and its associated search tool are no longer maintained or updated as of 28 January 2026 with the UK Sanctions List becoming the sole source for all UK sanctions designations. The consolidated dataset will cover asset-freezing sanctions as well as immigration, trade and transport restrictions, replacing the need to check multiple lists.  

Notably, all versions of the new UK Sanctions List will continue to display the historic OFSI Group ID for any person or entity that was designated before 28 January 2026. These legacy identifiers will remain valid for use in sanctions licence applications, as well as in frozen asset reports and suspected breach notifications. The new Unique ID assigned to each designated person will likewise be accepted for these purposes. 

TIA has published updated CRS lists of participating jurisdictions and reportable jurisdictions 

The Cayman Islands Tax Information Authority (TIA) has updated its lists of participating and reportable jurisdictions under the OECD Common Reporting Standard. 

Rwanda and Uganda have been added as participating jurisdictions. 

The following changes apply to reportable jurisdictions:  

• Mongolia, Papua New Guinea, and Paraguay are reportable for filings due in 2027 and later. 
• Fiji, Tunisia, and Zambia are reportable from 2028 filings onward. 
  
  

Entities operating Cayman investment fund structures should ensure their CRS compliance programmes are updated to reflect these changes, particularly for onboarding and reporting procedures.

How Ogier can help 

Ogier's team of fund regulatory experts can advise on all aspects of Cayman Islands fund regulation, supplemented by the other services we can offer such as AML Officers and FATCA and CRS compliance and reporting services. 

Reach out to your regular Ogier contact, or any member of the team listed below, should you require any assistance.