Cayman private funds (Funds) and investment advisers (IAs) face a series of regulatory deadlines across reporting, AML and economic substance in 2026.
Setout below is a practical timetable of the main requirements for the year, together with guidance on which requirements apply and the steps involved. Each item in the table links to further notes below.
Key deadlines for 2026
What matters this year
For many firms, the challenge lies less in any individual filing than in the number of requirements that need to be managed across the year.
Reporting, AML and economic substance obligations often involve different stakeholders, systems and advisers, which makes timing and coordination particularly important.
Several deadlines also sit relatively close together. For firms with multiple Cayman entities, that can create a significant operational burden if preparation starts too late.
Where support may be needed
Depending on the structure, support may be required across areas including:
- Economic substance classification and filing
- DITC portal registration
- Preparation of fund annual returns
- AML survey support
- FATCA and CRS reporting
- Annual AML training and related records
Notes and guidance
1. Economic substance notification and return
Funds
All Cayman entities are required to submit the ESN. Your registered agent would confirm during the last calendar year whether your Fund:
- Conducted any relevant activity; and
- Was a relevant entity.
A Fund usually falls within the “investment fund” exemption. As a result, it is required to submit the ESN by 31 January, but not the ESR by 31 December.
Investment advisers
Compared with a Fund, an IA is usually regarded as a relevant entity conducting relevant activity. As a result, it is required to submit both the ESN by 31 January and the ESR by 31 December.
Next step
Liaise with your registered agent for classification, completion and submission.
How Langham Hall can help
We can share market experience upon request.
2. Prudential information survey
Investment advisers
An IA registered as a CIMA registered person is required to submit the PI Survey.
Next step
Check whether your IA is a CIMA registered person. If applicable, liaise with your registered agent for completion and submission.
How Langham Hall can help
We can share a pre-filled template to assist you in getting started with the PI Survey upon request.
3. DITC registration and PPoC
Funds
A Fund classified as a reporting financial institution under FATCA and CRS requires DITC portal registration.
Investment advisers
An IA classified as a reporting financial institution under CRS requires DITC portal registration.
An IA with no financial accounts will not be required to submit a CRS report and CRS compliance form going forward.
Next step
Check whether your Fund or IA newly became a financial institution in 2025. If applicable, proceed with registration.
How Langham Hall can help
We support DITC portal registration as part of our service.
4. FAR and audited financial statements
Funds
A Fund registered as a CIMA private fund is required to submit the FAR together with the audited financial statements within six months of the financial year end.
For common year ends:
- 31 December year end: deadline is 30 June
- 30 June year end: deadline is 31 December
- 30 September year end: deadline is 31 March
Next step
Check whether your Fund is a CIMA private fund. If applicable, liaise with your fund administrator for preparation and your auditor for submission.
How Langham Hall can help
Preparation of FAR is part of our service.
5. AML survey
Investment advisers
An IA registered as a CIMA registered person is required to submit the AML Survey.
Next step
Check whether your IA is a CIMA registered person. If applicable, liaise with your AMLCO for completion and submission.
How Langham Hall can help
We can share a pre-filled template to assist you in getting started with the AML Survey upon request.
Please note that your AMLCO is responsible for completion and submission. If you would like to explore our AML Officers service, which includes completion of the AML Survey, please feel free to contact us.
6. FATCA and CRS reporting
Funds
A Fund classified as a reporting financial institution under FATCA and CRS is required to submit FATCA and CRS reports.
Next step
Liaise with your fund administrator for preparation and submission.
How Langham Hall can help
Preparation and submission of FATCA and CRS reports are part of our service.
7. CRS compliance form
Funds
A Fund classified as a reporting financial institution under CRS is required to submit the CRS compliance form.
Next step
Liaise with your fund administrator for preparation and submission.
How Langham Hall can help
Preparation and submission of the CRS compliance form is part of our service.
8. Frozen assets report
Funds
All Cayman entities maintaining any accounts for persons listed on the UK sanctions list are required to submit the frozen assets report.
There is no need to provide a nil return where there are no relevant accounts.
Investment advisers
The same applies. In general, an IA does not maintain any accounts.
Next step
Liaise with your fund administrator for confirmation and your MLRO for submission. For IAs, coordinate the account information internally.
How Langham Hall can help
Sanctions screening on investors is part of our service. If applicable, we can share information to support preparation and submission of the report.
We can also share market experience upon request. If you would like to explore our AML Officers service, which includes preparation of the frozen assets report, please feel free to contact us.
9. Annual AML training
Funds and investment advisers
Directors, AML officers, senior management and designated staff are required to complete Cayman AML training at least annually.
Next step
Liaise with your AMLCO for training materials, certificates and register updates.
How Langham Hall can help
We can provide general AML training materials and certificates upon request.
Please note that your AMLCO is responsible for maintaining the register. CIMA expects directors, AML officers and senior management to receive advanced AML training.
If you would like to explore our AML Officers service, which includes provision of advanced AML training and maintenance of the register, please feel free to contact us.
10. Annual board meeting
Funds
A Fund registered as a CIMA private fund is required to convene a board meeting at least annually. Agenda and meeting minutes should be maintained for record-keeping purposes.
Investment advisers
An IA registered as a CIMA registered person is required to convene a board meeting at least annually. Agenda and meeting minutes should be maintained for record-keeping purposes.
Next step
Ensure that the board meeting is arranged at least annually.
How Langham Hall can help
As fund administrator, we can attend the board meeting to present the administrator report upon request. We can also share market experience upon request.
Get in contact
If you would like to discuss how these requirements apply to your Cayman entities, please contact aml.asia@langhamhall.com
