The Cyprus Bar Association issued Circular 02/2026 on 7 January 2026, through its Supervision and Compliance Department, addressed to obliged entities. It is expressly a reminder, and reminders are issued because something is being missed. Here it is that one Cyprus trust can sit on two registers, and that satisfying one does nothing for the other.
The Bar Association deals with the CySEC obligation first. Following the launch of CySEC's Register of Express Trusts and Similar Legal Arrangements, the CyTBOR system, and under article 61C(4)(a) and (5)(a)(b) of Law 188(I)/2007, information about express trusts (ρητά εμπιστεύματα), similar legal arrangements and their beneficial owners has to be entered in the register CySEC maintains, by application. The circular does not restate the mechanics; it directs members to CySEC's own announcement and directive for the procedure, the data required and the notification of changes.
Then comes the heading that carries the document: the additional obligation to register in the Bar Association's own register. Under article 25A(2) of Law 196(I)/2012, every trust governed by Cyprus law that has one of its trustees resident in Cyprus, that trustee being an exempt person supervised by the Bar Association, is registered in the Trusts Register (Μητρώο Εμπιστευμάτων) the Bar Association keeps. The word doing the work is "additional" (επιπρόσθετα): the CyTBOR filing is not a substitute, and the two registers do not hold the same thing.
The Bar Association's register holds five items: the name of the trust, the names and full address of every trustee at all relevant times, the date the trust was created, the date of any change in the law governing the trust, and the date of termination. Beneficial owners appear in this circular on the CySEC side, not in that list. Trustee record and beneficial-ownership record sit with different supervisors.
The deadlines are short, and they are where files go wrong. Under article 25A(7), every trustee resident in Cyprus of a Cyprus-law trust has fifteen days from the creation of the trust, or from the adoption of Cyprus law as its governing law, to follow the Bar Association's procedure for registering it. Under article 25A(8) and (9), any change in the information held has to be notified within fifteen days of the change. Termination or expiry of the trust, and termination of the provision of services to a trust, must be notified as well. For procedure, recording of changes and charges, the circular refers members to the relevant manual.
Two things are worth reading closely. First, the trigger in 25A(2) is drafted around a Cyprus-resident trustee who is a Bar-supervised exempt person, while the fifteen-day duty in 25A(7) is expressed on every Cyprus-resident trustee of a Cyprus-law trust. Read them together against the trust in front of you rather than assuming the narrower one governs. Second, the closing note is administrative and easy to underrate: where an administrative service provider (ΕΠΔΥ) or a natural person is appointed trustee, the annual and renewal fees for the Bar Association licence have to be paid on time, or the trust's registration in the register is put at risk. A lapsed licence fee is a register problem, not a billing one. The Bar Association adds that it may impose sanctions for non-compliance.
For beneficial-ownership work the practical point is the split. A CyTBOR entry tells you nothing about whether the Bar Association's trustee record is current, and a Bar Association entry names no beneficial owners. Anyone verifying a Cyprus trust structure should be able to say which register was checked, when, and against which recorded items.
Not legal advice. Verify against the primary source before acting.
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