MiFID authorisationEEA passportClient money segregation€75,000 tier does not apply

Cyprus Investment Firm licence for forex brokers

Cyprus is the only jurisdiction in this comparison that is not offshore. A CIF licence from CySEC is a MiFID II authorisation, which means an EEA passport, client money segregation, investor compensation fund membership and the full conduct framework. It also means the capital figure quoted for Cyprus almost everywhere is wrong: €75,000 is the tier for firms that cannot hold client money, which no brokerage can be.

Market maker
€750,000Dealing on own account — IFD Art.9(1)
STP broker
€150,000Holds client money — IFD Art.9(3)
State fee
From €7,000Indicative, per internal dataset
Timeline
Up to 6 monthsPlus preparation

Cyprus CIF requirements

Initial capital is set by the Investment Firms Directive, which applies across the EEA — the figures are not Cypriot peculiarities and cannot be negotiated down. What determines your tier is whether you deal on own account and whether you hold client money.

Supervisory authority

Cyprus Securities and Exchange Commission (CySEC).

Legal basis

Investment Services and Activities and Regulated Markets Law of 2021 (165(I)/2021) implementing MiFID II, with prudential requirements under Regulation (EU) 2019/2033 (IFR) and Directive (EU) 2019/2034 (IFD).

Initial capital — dealing on own account
€750,000IFD Article 9(1): applies to firms authorised for points (3) and (6) of Section A of MiFID Annex I — dealing on own account and underwriting on a firm commitment basis. A market-making or B-book brokerage sits here.
Initial capital — other firms holding client money
€150,000IFD Article 9(3): the catch-all tier. An STP or agency brokerage that holds client trading balances but does not deal on own account sits here.
Initial capital — €75,000 tier
Not available to brokeragesIFD Article 9(2) applies only to firms providing points (1), (2), (4), (5) and (7) that are NOT permitted to hold client money or securities. A brokerage holding client trading accounts cannot qualify, which is why the widely quoted 'from €75,000' figure is misleading.
Client money
Segregated, with safeguarding obligationsA defining difference from every offshore route in this comparison.
Investor compensation
ICF membership requiredCyprus operates an Investor Compensation Fund covering eligible retail clients.
Retail leverage
30:1 on major pairsESMA product intervention limits apply, with lower caps on other asset classes, plus negative balance protection and standardised risk warnings.
EEA passport
YesThe reason to choose Cyprus. A CIF may passport services across the EEA under MiFID — no offshore licence in this comparison offers anything comparable.
Local substance
RequiredDirectors, compliance, risk and internal audit functions with genuine presence in Cyprus. CySEC has tightened substance expectations materially.
Audit
Required annually
State fee
From €7,000Indicative figure from the internal dataset, not verified against a CySEC fee schedule. Confirm before budgeting.
Timeline
Up to 6 months from a complete applicationPreparation typically takes longer than the review.

Capital tiers verified against IFD Article 9 on 24 July 2026. The state fee is the one figure on this page taken from an internal dataset rather than a primary source — treat it as indicative only.

What a CIF licence covers

The CIF licence lists the MiFID investment services and activities the firm may provide. Your permission set determines both your capital tier and what you may lawfully do.

  • Reception and transmission of orders (Annex I A.1) — routing client orders without executing them.
  • Execution of orders on behalf of clients (A.2) — the core agency brokerage permission.
  • Dealing on own account (A.3) — taking the other side of client trades. This is the permission a market maker needs, and it triggers the €750,000 tier.
  • Portfolio management (A.4) and investment advice (A.5) — separate permissions with their own conduct obligations.
  • Underwriting or placing on a firm commitment basis (A.6) — also triggers the €750,000 tier.
  • Ancillary services such as safekeeping, FX services connected to investment services, and granting credit to clients.

CFDs are financial instruments under MiFID, so offering them is a regulated investment service across the EEA. Whether your model is A-book or B-book decides your capital tier before anything else does.

The CySEC application process

  1. Fix the permission set and execution model

    2–4 weeks

    Decide whether the firm will deal on own account. This single decision sets capital at €150,000 or €750,000 and shapes the entire application.

  2. Incorporate and build local substance

    6–10 weeks

    A Cyprus company with directors, and compliance, risk management and internal audit functions genuinely resident and resourced in Cyprus.

  3. Fund initial capital

    3–6 weeks

    The IFD tier applicable to your permissions, held in a form that satisfies the own funds composition rules in Article 9 of the IFR.

  4. Prepare the application dossier

    10–16 weeks

    Business plan with three-year projections, organisational structure, internal operations manual, AML manual, risk management framework, ICAAP, and fit and proper documentation for directors and shareholders.

    Filing: CySEC CIF application

  5. Arrange client money and ICF arrangements

    4–8 weeks

    Segregated client accounts with credit institutions, safeguarding procedures, and Investor Compensation Fund membership.

  6. CySEC review

    Up to 6 months

    Up to six months from a complete application, with rounds of questions on the business model, capital adequacy and substance.

  7. Passport notifications

    1–2 months per wave

    Once authorised, notify CySEC of the EEA member states you intend to serve under freedom of services or establishment.

Substance is where Cyprus applications most often stall. CySEC has moved decisively away from accepting nominal local presence, and a structure that looks like a letterbox will not be authorised.

What a CIF licence does and does not give you

Covered by this licence

  • Executing and transmitting client orders across the EEA
  • Dealing on own account with the €750,000 tier
  • Offering CFDs to EEA retail clients within ESMA limits
  • Passporting into other EEA member states
  • Portfolio management and investment advice, if permissioned

Not covered — separate licence required

  • Market making on the €150,000 tierDealing on own account requires €750,000
  • Any activity on the €75,000 tier while holding client moneyThat tier is closed to firms permitted to hold client money or securities
  • Offering leverage above ESMA retail caps to EEA retail clients30:1 on major pairs, lower elsewhere, with negative balance protection
  • Serving UK retail clients on the EEA passportThe UK left the passporting regime — separate FCA authorisation required
  • Serving US retail forex clientsNFA/CFTC registration required

Ongoing obligations of a CIF

Own funds and capital adequacy

Maintain own funds above the higher of the permanent minimum requirement, the fixed overheads requirement and the K-factor requirement under the IFR.

High
Client money safeguarding

Segregate client funds, reconcile them, and comply with the safeguarding rules — the obligation that most distinguishes Cyprus from offshore routes.

High
Product governance and intervention

Apply ESMA leverage caps, negative balance protection, margin close-out rules and standardised risk warnings to retail clients.

High
Best execution

Execution policy, monitoring of execution quality and periodic reporting on execution venues.

Medium
Client categorisation and appropriateness

Distinguish retail, professional and eligible counterparties and run appropriateness tests before onboarding.

Medium
AML/CTF

Full framework under the EU AML directives as implemented in Cyprus, with a resident compliance function.

High
Regulatory reporting

Periodic returns to CySEC on own funds, concentration risk, liquidity and client money, plus transaction reporting.

High

What a Cyprus licence does not solve

Cyprus buys market access and credibility. It does not remove the constraints that bind every retail brokerage.

  • The EEA passport does not cover the United Kingdom, which requires separate FCA authorisation since leaving the passporting regime.
  • It gives no access to the US, Canadian, Japanese or Australian retail markets.
  • ESMA retail leverage caps apply — a Cyprus licence cannot be used to offer offshore-style leverage to EEA retail clients.
  • It is an investment services authorisation, not a payment or e-money permission.
  • Substance is a continuing obligation, not an application formality.

When Cyprus is the right choice

Best for

  • Brokerages whose target market is EEA retail or professional clients, where no offshore licence is lawful.
  • Operators who need the credibility of an EU authorisation for banking, acquiring and liquidity relationships.
  • Firms able to fund €150,000 or €750,000 of initial capital and staff a genuine Cyprus operation.
  • Businesses that have outgrown an offshore licence and are being blocked by payment providers or partners.

Not for

  • Projects optimising for speed and low capital — the offshore routes in this comparison are an order of magnitude cheaper.
  • Brokerages whose commercial model depends on high leverage for retail clients.
  • Operators unwilling to maintain resident compliance, risk and internal audit functions.
  • Firms targeting only non-EEA markets, where the passport is worth nothing.

Cyprus forex licensing — frequently asked questions

€750,000 if the firm deals on own account, which covers any market-making or B-book brokerage, and €150,000 for a firm that holds client money without dealing on own account. The €75,000 figure quoted almost everywhere comes from IFD Article 9(2), which applies only to firms that are not permitted to hold client money or securities — a condition no retail brokerage can meet. Budgeting to €75,000 means budgeting for a licence you cannot use.

Yes. A Cyprus Investment Firm licence is a MiFID II authorisation issued under Law 165(I)/2021, with prudential requirements under the IFR and IFD. That is why Cyprus sits in a different tier from every offshore jurisdiction: it carries an EEA passport, client money segregation, investor compensation fund membership and the full MiFID conduct framework.

For EEA retail clients, ESMA product intervention limits apply: 30:1 on major currency pairs, with lower caps on minor pairs, gold, indices, commodities and equities, plus mandatory negative balance protection, margin close-out at 50% and standardised risk warnings. Professional clients may be offered higher leverage, but the reclassification criteria are strict and cannot be waived by agreement.

No. The United Kingdom left the EEA passporting regime, so serving UK retail clients requires separate authorisation from the FCA. This catches out brokerages that assume a Cyprus licence covers the whole of Europe in the commercial sense.

CySEC's review runs up to six months from a complete application, but the preparation phase is usually longer. Assembling the business plan, internal manuals, ICAAP, risk framework and fit-and-proper documentation, and putting genuine local substance in place, typically takes three to six months before filing.

They serve different businesses. Seychelles costs US$100,000 in capital and cannot be used for EEA retail clients at all. Cyprus costs €150,000 or €750,000, takes longer, imposes leverage caps and safeguarding obligations — and is the only one of the two that lawfully reaches the European retail market. If your clients are in the EEA, there is no comparison to make; if they are not, the passport is worth nothing to you.

Initial capital figures were verified on 24 July 2026 against Directive (EU) 2019/2034 Article 9 via EUR-Lex. Cypriot implementing requirements and CySEC fees change; confirm the current position with CySEC and Cyprus counsel before relying on this page.

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