Cyprus Securities and Exchange Commission (CySEC) has issued a circular that serves as a reminder to Cyprus Investment Fund Managers (CyIFMs) regarding website compliance.

The regulator notes that it has observed inconsistencies in website content, inadequate disclosures and deviations from the applicable regulatory framework.

CyIFMS are generally required to maintain a website, ensuring that its content aligns with marketing communications requirements. Additionally, they must disclose certain documents and information, making them accessible to investors through their website.

CyIFMs are expected to undertake the following actions to ensure compliance:

1. Website maintenance: Ensure the proper upkeep of an official website (owned and operated by them). CySEC also urges sub thresholds CyAIFMS that address their funds to non-retail investors and do not have SFDR disclosures obligations to maintain a website, even though no specific requirement applies to them.
2. Regulatory compliance: Conduct an immediate review to ensure website content aligns with the regulatory requirements (e.g. Regulation (EU) 2019/1156 on facilitating cross-border distribution of CIUs, ESMA Guidelines on Marketing communications).
3. Website review and updates: Conduct an immediate review to ensure that all required disclosures (including a list of active funds under management and their target investor group) are accurate, and up to date.
4. Direct accessibility of documents: Ensure, where applicable, that the key investor documents (e.g. prospectuses, PRIIPs KID) are directly available on their websites without requiring users to sign up or request access.
5. Third-party website oversight: If a fund maintains a separate website, the CyIFM remains responsible for its compliance and must have full administrative access.
6. Internal compliance framework: Establish an internal review process for website content and marketing communications to ensure continued adherence to regulatory requirements.

To enhance oversight and regulatory compliance, CyIFMs must update CySEC of any new or modified website (beyond those initially reported to CySEC) via the Funds Portal within 10 days from the establishment or modification.