Post-License Roadmap for CySEC-Regulated Firms: What Comes Next?

After the License Comes the Real Work

Receiving your CySEC license as a CIF or AIFM is a major milestone — but it’s only the beginning. Once authorized, firms must complete a series of activation steps, implement their operational infrastructure, and demonstrate to the regulator that they have robust systems in place for compliance, reporting, governance, and client management.

This guide provides a practical, step-by-step roadmap of everything required after obtaining a license from CySEC, helping new investment firms go live quickly and correctly.

1. Immediate Post-License Obligations

As soon as CySEC grants authorization, firms enter the activation phase, where they must complete a number of mandatory tasks before starting operations.

1.1 Notify CySEC of Operational Readiness

Newly licensed firms must confirm they are fully operational. This includes:

• Internal governance structures
• Technology systems
• Personnel appointed to key functions
• Outsourcing documentation

CySEC may conduct checks or request additional confirmation.

1.2 Appoint All Key Function Holders

CySEC requires confirmation of the following roles (some can be outsourced):

• Compliance Officer
• Risk Manager
• Money Laundering Reporting Officer (MLRO)
• Internal Auditor
• Portfolio Manager / Investment Committee (if applicable)

For AIFMs:

• Valuation Officer / external valuer
• Depositary appointment

1.3 Investor Compensation Fund Registration (for CIFs)

CIFs offering services to retail clients must register with the Investor Compensation Fund (ICF).

1.4 Finalize Share Capital & Deposits

Initial capital requirements must be fully paid and documented.

2. Setting Up Core Operational Infrastructure

Once the mandatory appointments and notifications are completed, firms must implement a functioning operational environment.

This typically includes the following pillars:

2.1 Client Onboarding & AML Systems

CySEC expects fully documented and functioning procedures for:

• KYC / KYB
• Client risk scoring
• AML transaction monitoring
• Suitability & appropriateness assessments
• Source of wealth verification
• Record keeping & audit trails

A digital workflow significantly improves efficiency and compliance — especially for CIFs with cross-border clients.

2.2 Portfolio & Investment Management Setup

For CIFs with portfolio management permissions and for AIFMs, a Portfolio Management System (PMS) is essential:

You must be able to:

• Capture transactions across custodians/brokers
• Reconcile positions and valuations
• Manage model portfolios (if applicable)
• Generate performance reports
• Consolidate client holdings
• Calculate exposure, risk metrics, and NAV components

Firms are expected to show that their PMS supports MiFID II and AIFMD transparency rules.

2.3 Bank & Custodian Integrations

Activation of operational accounts:

• Custody accounts
• Trading accounts
• Fund administrator connections (for AIFMs)
• Payment rails / client money handling (where applicable)

Consistent data flow from custodians and service providers is a critical post-license requirement.

2.4 Internal Governance & Documentation

Firms must finalize and implement:

• Compliance Manual
• AML Manual
• Risk Management Framework
• Internal Audit Plan
• Remuneration Policy
• Best Execution Policy
• Conflicts of Interest Policy
• Outsourcing Register & Governance

These must be “live” documents — not theoretical templates.

3. Regulatory Reporting: What Starts Immediately

CySEC’s ongoing reporting obligations begin as soon as the firm is activated.

3.1 CySEC Periodic Reporting

Depending on the license type, firms must file:

• Quarterly Statistics Reports
• Capital Adequacy Reports
• Monthly EMIR / MiFID II transaction reporting
• AIFMD Annex IV reports (for AIFMs)
• Annual Audited Financial Statements

A failure to report — even newly after licensing — can trigger regulatory scrutiny.

3.2 Transaction Reporting (EMIR / MiFID II)

Investment firms must report:

• Trades
• Orders
• Derivatives exposure
• Counterparty data
• Post-trade transparency

Many newly licensed CIFs underestimate the complexity of these reporting pipelines.

3.3 AIFMD Annex IV Reporting (for AIFMs / AIFs)

Includes disclosures on:

• AUM
• Leverage
• Concentration risk
• Asset types
• Liquidity profiles

These must be automated wherever possible to avoid manual errors.

4. Going Live: Client Portal, Reporting & Engagement

Regulated firms must provide transparent reporting to clients, including:

• Portfolio statements
• Performance reports
• Fee breakdowns
• Trade confirmations
• Annual suitability assessments

A secure client portal is now considered market standard for CySEC-regulated firms, particularly those serving international investors.

5. Technology Stack: Making Your Firm Operational Quickly

To launch effectively, newly licensed firms must assemble an integrated technology stack covering:

Core Components:

1. CRM & Client Onboarding
2. KYC/AML Automation
3. Portfolio Management System
4. Client Portal
5. Data Aggregation & Reconciliation
6. Regulatory Reporting Automation
7. Document Vault & Compliance Logs
8. Performance Analytics & Dashboards

A fragmented tech stack creates risk and slows down launch timelines. Reluna solves this through an all-in-one infrastructure built for CySEC-regulated entities.

6. How Reluna Supports Newly Licensed CySEC Firms

Reluna is purpose-built to help CIFs and AIFMs launch quickly and run efficiently under CySEC’s regulatory framework.

Reluna provides:

• Full client onboarding & KYC workflows
• Multi-custodian data aggregation
• Portfolio management & reconciliation
• Compliance reporting (MiFID II, EMIR, AIFMD)
• Fee calculations & performance reporting
• Document management & audit trails
• Secure, white-labeled client portal
• Enterprise-level dashboards for management teams

Most newly licensed firms choose Reluna because it enables them to go live in weeks instead of months.

7. Timeline: What Happens After Authorization?

• ‍License Approval → Activation. 2–6 weeks. Appointment of officers, readiness notifications, bank/custodian setup‍
• Operational Infrastructure Build. 1–3 months. Tech stack setup, reporting frameworks, onboarding workflows‍
• Soft Launch / First. Clients 1–2 months. Controlled onboarding, testing reporting, internal assessments‍
• Full Commercial Launch. 3–6 months. from authorization Business scaling, ongoing compliance cycle begins

8. Common Mistakes Newly Licensed Firms Should Avoid

• Delaying the implementation of tech and reporting systems
• Relying on Excel or manual processes for reconciliations
• Insufficient documentation of internal governance
• Not preparing a structured client onboarding pipeline
• No automation for CySEC, EMIR, or MiFID II reporting
• Underestimating the operational load on compliance staff

9. Next Steps: Accelerate Your Post-License Launch

If you’ve recently obtained your CySEC license as a CIF or AIFM, your priority is now to build the operational backbone necessary to begin serving clients — quickly, professionally, and in full compliance.

Reluna helps you:

• Set up your operational processes
• Build a scalable technology infrastructure
• Automate reporting and onboarding
• Ensure regulatory compliance from day one

Request a demo to learn how Reluna can help your Cyprus-regulated investment firm launch smoothly.