CySEC Circular C671: Cyprus Investment Firms Quarterly Statistics Submission for 31/12/2024

TO : Cyprus Investment Firms (‘CIFs’) FROM : Cyprus Securities and Exchange Commission DATE : December 20, 2024 CIRCULAR No : C671 FILE No : E.K. 02.03.001 and E.K. 01.13.001.002.002 SUBJECT : CIFs Quarterly Statistics (Form QST-CIF) – 31/12/2024 Submission The present Circular is issued pursuant to section 25(1)(c)(ii) & (iii) of the Cyprus Securities and Exchange Commission Law (the ‘CySEC Law’). The Cyprus Securities and Exchange Commission (the ‘CySEC') wishes to inform all CIFs that in order to make the collection of information more efficient, some information requested in the Form RBSF-CIF, has been integrated in the new version of the Form QST-CIF (the ‘Form’). Thus, the Form RBSF-CIF, will not be collected for the year 2024 until further notice. However, as there have been many changes to the new version of the Form, we urge all CIFs to read carefully all the information provided in this Circular.

1. Information Requested by CySEC 1.1 The latest version of the Form QST-CIF, Version 15, found in the Appendix, must be completed and submitted to CySEC by all CIFsthat were authorised by December 31, 2024. In this respect, CIFs that were authorised by December 31, 2024, but have not made use of their authorisation must also submit the Form. 1.2 The steps that CIFs will have to follow, for the successful submission of the Form to the TRS, can be found here. Upon submission, CIFs are responsible to ensure that they have received a feedback file, i.e. an official submission confirmation dispatched by the TRS in the Outgoing directory. 1.3 The feedback file will either contain a NO ERROR indication or, in case that an error(s) has occurred during submission, the description of that error(s). In case of any errors detected during submission of the Form, CIFs must review the Form and ensure that all errors are addressed and corrected before they digitally sign (only applicable for the Excel files) and re-submit the Form. The Form is regarded as being successfully submitted to CySEC, only when a NO ERROR indication feedback file is received. This feedback file is dispatched, only during CySEC regular hours.

2 2. Deadline for the submission of the Form 2.1. The Form must be successfully submitted electronically via the CySEC’s Transaction Reporting System (‘TRS’) by Monday, February 3, 2025, the latest. CySEC wishes to emphasise the importance of meeting the deadline set, for successful submission of the Form. 2.2. Kindly note that the deadline for submissions of the Form to TRS is 5 weeks after each quarter end. 2.3. Failure to promptly and duly comply with the above may bear the administrative penalties of section 37(5) of the CySEC Law. It is further noted that CySEC will not send any reminders to those CIFs, which fail to promptly and duly comply. 3. Important information regarding the new version of the form 3.1. The new version of the Form consists of two main parts, Part I and Part II. ➢ Part I (sections A – O): must be completed on a quarterly basis. (i.e. Q1, Q2, Q3 and Q4 submissions) ➢ Part II (sections A – F): must be completed on an annual basis only. (i.e. Q4 submission only) 3.2. Based on point 3.1 above, upon completion of the Reference date, cell D18 of Section General Info, for reference dates of the form 31/03/20XX, 30/06/20XX and 30/09/20XX, cells in Sections (A – F) of Part II of the form will automatically grey out, indicating that no completion is required for these reference dates. 3.3. Based on point 3.1 above, upon completion of the Reference date, cell D18 of Section General Info, for reference date of the form 31/12/20XX, cells in Sections (A – F) of Part II of the form will automatically become activated, indicating that completion is required. 3.4. CIFs are advised to complete the form based on Audited Financial Statements, if those are available. In case audited figures are not available, CIFs may use unaudited figures for the purposes of completion of the form. Please read carefully the below additions on the new form. The ‘New Points’ and ‘New Sections’ referred to below, have now been added on the form QST-CIF. These new points/sections refer to data that was previously collected through the form RBSF-CIF. 3.5. PART I – to be completed on a quarterly basis 3.5.1. Points 2.3 and 2.4 of Section K – New points Information regarding Volume of Transactions under Dealing on Own account.

3 3.6. PART II – to be completed on an annual basis 3.6.1. Section A – Governance and Ownership – New section Information regarding the entity’s governance and shareholding arrangements, e.g. on the Board of Directors, beneficial owners, group structure etc. 3.6.2. Section B – Services – New section Additional information regarding the provision of services and financial products, as well as information of the liquidity providers and execution venues used by the entity. 3.6.3. Section C – Distribution Network – New section Information in relation to the Distribution Network of the entity, e.g. number of representative offices, subsidiaries, branches, tied agents etc. 3.6.4. Section D – CIF’s Exposure to Risks – New section Information in relation to the risks that the entity is exposed to, e.g. credit risk, liquidity risk, compliance risk etc. 3.6.5. Section E – Internal Policies and Procedures – New section Information regarding the entity’s governance arrangements and internal policies and procedures, CIF’s self-assessment on internal policies and procedures, methods of disclosure of costs and charges etc. 3.6.6. Section F – Other information – New section Information regarding off balance sheet assets, financial projections, financial losses incurred etc. 4. General Comments for the Form 4.1. The Form will be available only in the English language. 4.2. CIFs are required to report data in Euro, rounded to the nearest unit. 4.3. Please always ensure that you have the latest version of the Form, i.e. Version 15. 4.4. Instructions on the completion of the Form can be found in the ‘Instructions’ worksheet of the Form. 4.5. Definition of ‘client’ varies across different Sections of the Form. CySEC wishes to emphasize the importance of reading the Instructions/Definitions Sections of the Form carefully when completing each Section. 4.6. Reporting periods vary across different Sections of the Form: “as at the reference date”, “during the reporting period”, “during the cumulative reporting period”. CIFs are expected to read carefully the ‘General Instructions’ found on the top of each Section so that the figures reported in that Section refer to the correct reporting period. Kind reminder of the table below:

4 Quarter Reporting Period Cumulative Reporting Period Reference Date Period Time Span Period Time Span Date Q1 01/01/20XX-31/03/20XX 3 months 01/01/20XX-31/03/20XX 3 months 31/03/20XX Q2 01/04/20XX-30/06/20XX 3 months 01/01/20XX-30/06/20XX 6 months 30/06/20XX Q3 01/07/20XX-30/09/20XX 3 months 01/01/20XX-30/09/20XX 9 months 30/09/20XX Q4 01/10/20XX-31/12/20XX 3 months 01/01/20XX-31/12/20XX 12 months 31/12/20XX 4.7. Before submitting the Form, please ensure that all validation tests that are contained in the Form (Section General Info, Sections of Part I (A – O), Sections of Part II (A – F) and Validation Tests Worksheet) are TRUE (Green Colour). 5. Method of creating, signing and submitting the Form to the CySEC After populating the required Excel fields in the Form, CIFs should name their Excel file in accordance with the following naming convention: Username_yyyymmdd_QST-CIF The information below explains the naming convention: (1) Username – is the username of the TRS credentials, which should already be in the possession of the CIFs, which have previously submitted any electronic files to the TRS system. This codification should be entered in capital letters. CIFs, that have not previously requested the TRS credentials, can do so, by referring here, where further information is provided about the TRS. (2) yyyymmdd – this denotes the end of the reporting period of the Form. In this case, the Form should have a 20241231 format. Future forms will have different reporting periods. (3) QST-CIF – this is the coding of the Form, that it remains unchanged and should be inserted, exactly as it appears. (4) The Excel® must be of 2007 version and onwards. Excel will add the extension .xlsx, as soon as it is saved. This extension should not under any circumstances, be inserted manually. Τhe fully completed excel form, which is named based on the above paragraph, must be submitted only electronically, through the Transaction Reporting System (‘TRS’), within the timeframes set. 6. Support 6.1. Queries on how to complete the fields of the Form Should you have any queries on the completion of Form QST-CIF, please submit them only in writing, any day PRIOR to Monday, January 27, 2025, by sending an email to the address riskstatistics.cifs@cysec.gov.cy.

5 6.2. Technical Queries on digitally signing and submitting the Form For technical matters on digitally signing and submitting the Form, the CIFs are advised to frequently visit the CySEC’s website, at the specified section. For further clarifications, CIFs are requested to use the electronic address information.technology@cysec.gov.cy. All email communication with CySEC should include the subject, the CIF’s full name and the TRS coding. Yours sincerely Panikkos Vakkou Vice-Chairman Cyprus Securities and Exchange Commission