Background:
From the reporting period ending 30 June 2025, Cyprus Investment Firms must submit IFR prudential reports exclusively in XBRL via CySEC’s portal. The Excel-based option used during the transition was discontinued after the 11 August 2025 deadline, and CIFs now need software that can generate and validate compliant XBRL files. So the old route of downloading the form from the portal and using its built-in Excel-to-XBRL conversion feature no longer applies. The only acceptable route is preparing and uploading your own zipped XBRL file directly to the portal.
- Applies to: Cyprus Investment Firms reporting on a solo or consolidated basis, and Union parent investment firms / holding companies reporting on a consolidated basis.
- Reports covered: supervisory reporting templates under Article 54 IFR (Regulation (EU) 2019/2033) and Commission Implementing Regulation (EU) 2021/2284, as applicable to the firm’s class.
- CySEC basis: Circular C546 (introduction of the XBRL Portal) and Circular C719 (XBRL-only submission from the 30 June 2025 reference date).
Our IFR – XBRL services in a nutshell:
- Conducting a reconciliation of your CIF’s balance sheet, P&L and fixed overheads data for the reference date.
- Calculating your CIF’s own funds for solvency purposes as well as the K-factor, Concentration and Liquidity requirements. Or rely on the data reconciliation and calculations provided by you!
- Populating the data. Completing the IF templates (IF 01–IF 11 as applicable to Class 2/3) in your working files.
- Mapping to the EBA taxonomy. Each template cell corresponds to a DPM data point in the EBA XBRL taxonomy. We use the version CySEC currently accepts. Framework 4.0 moved to the DPM 2.0 model and included minor amendments for Class 2 investment firms. Our XBRL conversion service is future proof and will comply with later releases accepted by CySEC.
- Generating the instance. Using our XBRL tool to produce the XBRL instance with the correct entity identifier (LEI), reporting period, module (solo/consolidated), filing indicators and units.
- Validating prior to CySEC submission. Running the EBA validation rules locally. CySEC’s XBRL Processor also validates after submission against the rules in its Manual for Investment Firms Submissions. We shall undertake on your behalf to resolve any technical errors.
- Zip and upload to xbrl.cysec.gov.cy. Then confirm the submission status shows no errors.
- Maintaining on your behalf an audit trail linking the Excel figures to the XBRL facts.
Our Step-by-step procedure:
- Confirm the reporting set. Identify the firm’s class (2 or 3), basis (solo / consolidated) and the IF templates due for the reference date.
- Confirm the taxonomy. Check the EBA reporting framework and taxonomy version CySEC accepts for that reference date. Update the XBRL tool before data entry starts.
- Prepare the data. Review the data provided by you (balance sheet, P&L as well as trade and other K-factor related data, for the reference date). We calculate available eligible own funds for solvency purposes, requirements based on K-factors/fixed overheads, permanent capital as well as concentration and liquidity requirements. Also conduct the necessary reconciliations to your accounting and historical time series data.
- Populate the templates. Enter the figures in the IF templates (Excel working files or the tool’s input screens). Keep units, signs and currency consistent with the taxonomy.
- Internal review. We review the templates against the prior period and the accounts. Material movements are identified and must be explained.
- Generate the XBRL instance. Convert the templates using our XBRL tool. Check the entity identifier (LEI), reference date, module, filing indicators and currency.
- Validate before upload. Run the full EBA validation rule set in the tool. Clear all blocking errors and review warnings.
- Zip and upload. Package the instance as a .zip and upload it to the CySEC XBRL Portal.
- Confirm acceptance. Check the portal status after CySEC’s XBRL Processor runs. Download or screenshot the confirmation.
- File the record. Save the final templates, XBRL file, validation report and portal confirmation in the reporting file.
Our Pre-submission checklist:
- Correct class, basis and template set identified
- Taxonomy version confirmed for the reference date; tool updated
- Figures reconciled to the accounts
- Period-on-period movements explained
- LEI, reference date, module and filing indicators checked
- Full EBA validation run with no blocking errors
- Zipped file uploaded to the CySEC XBRL Portal
- Portal acceptance confirmed and saved
- Reporting file complete.
Validation errors and resubmissions
A file that fails CySEC’s validation is treated as not submitted, so errors must be cleared before the deadline.
- Blocking errors: correct the source data or mapping, regenerate the XBRL, revalidate and re-upload.
- Warnings: review each one. Document why any warning is accepted.
- Unclear errors: contact CySEC on your behalf, quoting the rule ID and reference date.
- Corrections after acceptance: if an error is found in an accepted report, resubmit the corrected report promptly and record the reason, the change and the date.
Record-keeping and audit trail
For each reference date, keep one reporting file containing:
- Source data extracts and reconciliations to the accounts.
- Final populated IF templates.
- The submitted XBRL file (.zip) and the taxonomy version used.
- The pre-upload validation report and the CySEC portal confirmation.
- Review sign-offs and any correction log.
Retain records for at least five years. The file should let an auditor trace every reported figure back to its source.
