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The firm files, so do you

Regulator commentary · all insights
The firm files, so do you

The Cyprus Bar Association's 2025 compliance questionnaire is not one filing per firm. Circular 14/2026 addresses it to self-employed lawyers, to salaried lawyers inside firms, and to the firms themselves, on a test met by paying the annual fee, by holding a practising licence, or both.

The Bar Association issued it on 08 July 2026 to all its members; the announcing voice is its Supervision and Compliance Department, writing in the context of applying the risk management system it calls the Risk-Based Approach. One sentence carries the whole scope. All Members of the Bar Association, being self-employed lawyers or lawyers salaried in ΔΕΠΕ/Συνεταιρισμοί/ΕΠΔΥ, and ΔΕΠΕ/Συνεταιρισμοί/ΕΠΔΥ themselves, which during the reference period paid the annual fees to the Bar Association and/or held a licence to practise the profession, are obliged to follow the Bar Association's electronic procedure for completing the Annual Compliance Questionnaire.

In plainer words: there are two ways of being caught, paying and holding, and either one on its own is enough. A salaried lawyer is named there in their own right, and the firm is named in the same breath, separately. The circular writes those three entity types only as printed, two of them as abbreviations, and never expands them, so this card leaves them as printed rather than guess.

The procedure concerns the period 01/01/2025 to 31/12/2025 and is to be completed by 25 September 2026 by all Members that had the relevant obligation. The questionnaire is entered through the Amlex365 platform.

Credentials are the ones you already have. The username and password for Amlex365 are the same as those used for the previous reference period, 2024, and the Bar Association says they will be notified to you again by email, to the address recorded in its register, from a no-reply address of its own shown as sender Amlex365 | Cyprus Bar Association, carrying your unique username, your unique password and a link to the platform.

Two of the repair routes carry the date 24/07/2026. If you do not find the above, the circular requests that you contact its AML mailbox by 24/07/2026 so that both the username and the password can be sent to you. If the email address held for you is wrong or is not the one you use, a natural person is requested to update their details through their account on the Bar Association's portal by 24/07/2026 and to tell the Bar Association at that mailbox about the change, so the credentials can be sent again. In the case of a legal person, a relevant email is to be sent to the same mailbox, with no date attached to that route.

That date has gone. This card publishes on 28 August 2026, five weeks after 24 July. The circular does not say what a member who missed it should do now, and it does not move 25 September.

Access also needs the multi-factor authentication process completed. The circular links guidance for it, and separate guidance on completing the questionnaire, which it says can also be found on entering the system, at the top right of the page, in Greek and in English. No statement in this card comes from either of those manuals.

The closing sentence is discretionary. Where Members of the Bar Association do not comply with the above deadline, the Bar Association may impose sanctions. May, not will, and it is the deadline that is named.

Circular 01/2026 in January listed this questionnaire among the year's obligations and left it undated, saying the start of the process would be announced at a later stage. This is that announcement.

The test is paid fees and/or a practising licence, and the and/or is the Bar Association's own. One limb is enough, and being on someone else's payroll is not one of the ways out.

Not legal advice. Verify against the primary source before acting.

Sources

Published 28 August 2026 · Regulator commentary
Drafted with AI assistance. Reviewed, edited and approved before publication by a named person at Ioannou & Sharpe LLC, who takes editorial responsibility for its content. Approved by Harris Sharpe, 6 September 2026.

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Not legal advice. FIRMCY publishes this analysis for general informational purposes; verify against the primary sources before acting.