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Cyprus Law 194(I)/2025 establishes mandatory pre-notification and ex-post screening for inbound foreign direct investments, implementing Cyprus's obligations under EU Regulation 2019/452 (the EU FDI Screening Regulation). Four cumulative conditions must be satisfied to trigger screening:
1. Foreign investor status — non-EU/EEA natural persons or legal entities where ≥25% of share capital or voting rights are ultimately held by third-country nationals/entities. 2. Equity acquisition threshold — acquisition or increase of ≥25% of the share capital or voting rights in a Cyprus undertaking. 3. Value threshold — investment value of at least €2 million (single transaction or aggregated within 12 months). 4. Strategic sector — investment concerns an "undertaking of strategic significance" operating in one of the designated covered sectors.
Covered sectors (Article 2 sectoral perimeter): critical infrastructure (energy, transport, water, health, communications, financial infrastructure); critical technologies and dual-use items (AI, robotics, semiconductors, cybersecurity, quantum, nuclear, nanotechnology, biotechnology, aerospace, defence-related technologies); data processing and storage; media freedom and pluralism; food security and agricultural land; defence (Cyprus National Guard + EU CSDP architecture); and — in the Cyprus-specific national extension — education and tourism, as well as real estate critically linked to the operation of covered infrastructure.
Competent Authority: Ministry of Finance (Υπουργείο Οικονομικών), which administers the notification intake, preliminary review, inter-ministerial committee consultation, and final decision. The Ministry has retrospective review authority: (i) unnotified investments may be re-examined within 5 years of completion; (ii) investments not subject to mandatory notification may be proactively reviewed within 15 months if national security concerns subsequently emerge.
Screening timeline: The Ministry must acknowledge receipt and inform the investor within 20 working days whether a full in-depth screening will proceed. During the review, the Competent Authority may consult an inter-ministerial advisory committee and must notify the European Commission and other EU Member States under the EU cooperation mechanism (Regulation 2019/452 Art. 9–10).
Decision outcomes: approval; conditional approval (with mitigation conditions imposed on the acquirer); or prohibition on grounds of security or public order threat.
Penalties:
penalty accruals;
Among EU member states, Cyprus's Law 194(I)/2025 stands out for explicitly designating tourism as a covered strategic sector and extending the screening perimeter to real estate linked to covered infrastructure. This reflects Cyprus's post-golden-passport sensitivity:
until its suspension in November 2020 following investigations by the European Parliament's PANA committee into aggressive sale of EU passports to sanctioned individuals and high-risk third-country nationals (including allegations of facilitation via offshore real-estate structures).
commercial real-estate acquisitions by non-EU investors — particularly relevant to Chinese, Russian, and Middle Eastern high-net-worth investor flows that historically channelled through the CIP route.
private universities and international schools used as EU-presence vehicles.
Closes EU FDI-screening lattice: Cyprus was one of the last EU-27 member states without a national FDI screening regime. With Law 194(I)/2025 (entry into force 2 April 2026) alongside Luxembourg's Loi du 14 juillet 2023 (in force since 1 September 2023), the EU-27 FDI-screening coverage map approaches saturation. The remaining gaps are principally among EU-acceding/candidate jurisdictions (MD, AL pending implementation verification, BA, XK, ME, MK, GE).
Critical economy exposure: Cyprus's screening regime covers:
globally); downstream subsidiary acquisitions of ship-management firms could trigger screening;
operators include ExxonMobil, Eni, Chevron, TotalEnergies, Shell — but note these are typically EU or US investors, not captured by the non-EU/EEA/Swiss investor scope).
EU-cooperation implications: The Cypriot Ministry of Finance is designated as Cyprus's Single Point of Contact under EU Regulation 2019/452 for information-sharing with the Commission and other Member States — triggering the Art. 9 notification duty for any covered transaction under review.
as EU-access vehicles by Chinese, Russian, Gulf, and Israeli investors) must now notify the Ministry of Finance if the Cyprus entity's strategic-sector exposure triggers the perimeter — a material change for Cyprus's fund-domiciliation and holding-company industry.
and resort groups that currently serve as EU investment-access nodes for Asian and Gulf HNW capital.
2 April 2026 if not voluntarily notified.
bypasses that was entirely absent in the pre-statute regime.
— is it asset-size, revenue, market-share, or designation-based?
holdings (i.e., does it trigger on secondary transfers within an existing EU-presence structure)?
regulation — the Ministry of Finance has not yet published implementing rules as of early 2026.