Pursuant to legislative amendments to the Cyprus Companies Law, Cap.113 (the “Law”), as of 21 April 2020, the Registrar of Companies and Official Receiver in Cyprus (the “Registrar”) will be imposing new administrative fines, for failure by Cypriot companies to submit certain filings within the deadlines set out in the Law.
 
The new administrative fines, firstly introduced by the Companies (Amending) (No.3) Law of 2018 (N.149(I)/2018) on the 18 December 2018, were to take effect in “one year” from the date of entry into force of this amending law, i.e. on the 18 December 2019. However, the Companies (Amending) (No.3) Law of 2019 (N.163(I)/2019), passed on the 16 December 2019, amended the wording from “one year” to “sixteen (16) months”, extending thus the deadline to the 18 April 2020. But since the 18 April 2020 is a public holiday in Cyprus, the deadline is set on the 21 April 2020, pursuant to the Cyprus Interpretation Law, Cap.1.
 
In light of the above, we note that if there is a delay in submitting the below filings, the Registrar will impose the administrative fines set out in the Law as indicated in the following table:
 

FILING REQUIREMENT	​ STANDARD STATUTORY DEADLINE	ADMINISTRATIVE FINE AS OF 21 APRIL 2020
Annual returns (HE32)	28 days from the company’s       reporting date.	EUR 50 (one-off fine), plus   EUR 1 for every day for which the default continues within the first 6 months, plus   EUR 2 for every additional day thereafter for which the default continues, with a maximum fee of Euro 500 for each default.
Changes in the registered office (HE2)	14 days from the date of the change.	EUR 50 (one-off fine), plus   EUR 1 for every day for which the default continues, with a maximum fee of Euro 250 for each default.
Changes of director(s) and/or secretary, and/or any change in their details (HE4)
Transfer of shares and/or any change in the details of the registered shareholder(s) (HE57)	14 days from the date of entry of the new shareholder(s) and/or of the change, in the register of members.
Allotment of shares (HE12)	1 month from the date of the allotment of shares.