The Cyprus Bar Association issued Circular 01/2026 on 7 January 2026, through its Supervision and Compliance Department, to all members and obliged entities. It enumerates in a single document the 2026 obligations arising from Law 196(I)/2012, Law 188(I)/2007 and the Bar Association's own directives and circulars. A year's calendar on three pages. The value is in what the dates say against each other.
Start with the compliance officer's annual report. Timely submission of the report for 2025 is 31 March 2026, and that is the date that will end up in most diaries. But the submission mechanics attach two conditions, joined by "and": the report and the minutes approving it, scanned into a single pdf file, are to be submitted within thirty days of the relevant meeting, and at the latest three months after the end of the calendar year, namely 31 March. Board approval has its own date: the report is prepared and put to the board within two months of year end, and the last date that approval can take place is 28 February 2026. So a firm whose board approves on 20 January is not filing in March. It is filing by 19 February. The March date is a ceiling, not the deadline.
One carve-out belongs in the workflow. Where the compliance officer, the director and the shareholder are the same natural person — the self-employed practitioner, the single-person entity — board approval is not required. The circular does not then say what the thirty-day count runs from when there is no meeting, which leaves 31 March doing the work alone. Two firms in the same corridor can be on genuinely different timetables, and it is worth resolving which you are on.
The other 31 March in the document belongs to a different obligation and often to a different person. The annual fee for each administrative services provider company (ΕΠΔΥ) on the register the Bar Association keeps is payable from 1 January to 31 March 2026, at €300 per ΕΠΔΥ, and only online through the Bar Association's website — payments at its offices or by bank transfer will not be accepted. One sentence sets this obligation apart. Fail to pay within the period and the ΕΠΔΥ is removed from the register until the fee is paid, with a 10 per cent surcharge. Elsewhere the circular closes with the Bar Association being able to impose sanctions. Here the consequence is stated flatly, and it lands on your registration, not just your wallet.
Three items carry no 2026 event date at all. A certified compliance officer has had to be in place since 31 January 2024 in every obliged entity supervised by the Bar Association that provides the article 2A(c)(ii) and (d) services — a state to be in, not a task to schedule. At least ten hours of training on money laundering and terrorist financing, appropriate to the role, has to be done during 2026; the window is the whole year, which is how it reaches December undone. And the annual compliance questionnaire covering 1 January to 31 December 2025 goes through the Amlex365 platform, with the circular saying only that the start of the process will be announced later. That one needs a watch, not a date.
Two things to do this week. Pull the date your board approved last year's report, project this year's, and count thirty days forward before you assume the quarter is yours. Then confirm who in the structure actually invoices for the article 2A(c)(ii) and (d) services, because the circular is explicit that the report is filed by the natural or legal person that invoices, not whoever holds the compliance file.
Not legal advice. Verify against the primary source before acting.
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