As we begin 2026, we are writing to highlight two Cayman regulatory updates:
• Principal Point of Contact (PPoC) residency requirement
• Cayman Islands Monetary Authority (CIMA) Prudential Information Survey requirement
1. The PPoC residency requirement
What is changing
From 1 January 2026, a Cayman financial institution (FI) must appoint a PPoC who is resident in the Cayman Islands. Most Cayman private funds are FIs, so existing appointments should be reviewed.
Who is affected and when
• Existing FIs (registered on the DITC Portal on or before 31 December 2025): transition period to 31 January 2027 to move to a Cayman-based PPoC
• New FIs (registered since 1 January 2026): must appoint a Cayman-based PPoC on registration
How is this completed
• Appointment or change is filed via the DITC Portal
• The PPoC liaises with the Department for International Tax Cooperation (DITC), receives regulatory communications and, where required, adds a secondary user on the DITC Portal for FATCA and CRS
Why it matters
Failure to appoint a Cayman-based PPoC may attract an administrative penalty of up to KYD 10,000.
2. CIMA Prudential Information Survey (Registered Persons)
What is changing?
CIMA now requires Registered Persons (including SIBA investment advisers) to submit a Prudential Information Survey via the REEFS Portal. CIMA has issued a notice and a completion guide.
Deadline
For the 2025 calendar year, submission is due on or before 31 March 2026 via the REEFS Portal. Cayman registered office agents submit on your behalf.
How is this completed?
• Review CIMA’s notice and completion guide
• Prepare responses (we can provide a pre-filled template on request)
• Coordinate submission with your Cayman registered office agent via REEFS
Why it matters
Although the survey appears statistical, submission is a mandatory regulatory requirement for in-scope Registered Persons.
More information
• CIMA’s notice
• CIMA’s completion guide
How Langham Hall can help
Langham Hall works with Cayman partners to coordinate Cayman-based PPoC appointments and DITC filings. We also provide a pre-filled template to help Registered Persons complete the CIMA survey efficiently.
Get in touch
Please email aml.asia@langhamhall.com to discuss applicability to your structures or to request assistance with DITC or REEFS submissions.
