Are Cyprus trusts on a public register

There are two registers and they hold different things

Most answers to this question treat the Cyprus trust register as a single thing. There are two, kept under different statutes by different bodies, and confusing them produces answers that are wrong in both directions.

The trusts register, under article 25A of the law regulating administrative service providers. Three bodies each keep one: the Securities and Exchange Commission, the Bar Association, and the Institute of Certified Public Accountants. Which one a trust appears on depends on which of them supervises its Cyprus resident trustee.

The beneficial ownership register, under article 61C of the anti-money laundering law. The Securities and Exchange Commission keeps this one for everybody, and it exists because of the European anti-money laundering directives.

A trust is registered in both. The statute says so in terms: registration in the beneficial ownership register happens irrespective of registration in a trusts register kept under article 25A.

The trusts register records five things, and none of them is a person who benefits

Article 25A(6) is short and worth reading closely. The register is not available to the public and is available for inspection by the competent authorities. It contains:

1. the name of the trust;
2. the names and full address of every trustee, at all relevant times;
3. the date the trust was created;
4. the date of any change in the law governing the trust; and
5. the date the trust terminated.

That is the whole list. No settlor. No beneficiaries. No protector. No assets and no values.

What sits behind it is the obligation on the trustee to notify within fifteen days of the trust's creation, within fifteen days of a change in the trust's name or a trustee's name or address, and within fifteen days of a termination or a change of governing law.

The beneficial ownership register does record who benefits, and who may see it is defined

This is the register people are actually asking about. The trustee must obtain and hold adequate, accurate and up to date information on the settlor, the trustees, any protector, the beneficiaries or, where they are not yet determined, the class of persons in whose main interest the trust operates, and any other natural person exercising ultimate control.

Access is set out in article 61C(12) and it has three tiers.

The authorities, without restriction. The supervisory authority, the financial intelligence unit, Customs, the Tax Department and the Police.

Obliged entities, for their own customer due diligence. A bank or a professional firm carrying out checks on a client. The statute adds a proviso that they must use a risk based approach and must not rely on the register alone. The directive limits what they see to the name and surname, the month and year of birth, the country of residence, the nationality, and the nature and extent of the rights held. Not the full date of birth. They pay 4 euro per trust for a written report.

A person who proves a legitimate interest. The limits here are the ones that matter, and there are four. The information is confined to name, month and year of birth, country of residence, nationality, and the nature and extent of the beneficial interest. The applicant must prove the interest relates exclusively to, and contributes to, combating money laundering and terrorist financing. That proof must include evidence of previous activities and steps already taken to that end. And each application is decided case by case by the Commission, after which the applicant pays 75 euro per trust.

The suspension you have read about was a different register

Search for Cyprus and the beneficial owners register and you will find that public access was suspended in November 2022, following the judgment of the Court of Justice on the Fifth Anti-Money Laundering Directive. That is accurate, and it is about the register of beneficial owners of companies, kept at the Registrar of Companies under a different article of a different part of the law.

The trusts register is not that register, and it did not need suspending. Article 61C(12) has never contained a general public category. When it was enacted in 2021 it had four paragraphs, and the widest of them, paragraph (d), still required a written request about a trust with a controlling interest in a non-member-state entity.

And the trusts regime has since narrowed rather than been restored. Paragraph (d) was deleted in 2026, so the only route left for anyone other than an authority or an obliged entity is the legitimate interest test, with its four conditions and its case by case decision.

The exemption most sources do not mention, and what has actually been granted

Article 61C(16) allows the Commission, in exceptional cases and after a detailed assessment of the circumstances, to exempt all or part of the beneficial ownership information from access where granting access would expose the beneficial owner to a disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation, or where the beneficial owner is a minor or otherwise legally incapable.

The mechanics are in paragraph 15 of the directive, and one of them is more useful than the exemption itself. From the date the application is submitted, access to the information it concerns is suspended until the Commission decides. So the protection begins on filing rather than on grant. A negative decision is not enforceable for seventy five days from notification and is open to recourse under Article 146 of the Constitution.

It is used. The Commission publishes annual statistics on exemptions granted, as article 61C(16)(c) requires. Five were granted between 17 May 2022 and 31 August 2024, on 5 December 2022, 16 January 2023, 22 May 2023, and twice on 26 August 2024. In every case the whole data set was exempted rather than selected fields, and in two of the five the exemption covered the settlor as well as a beneficiary.

Three limits have to be stated with it, because the exemption is narrower than it sounds.

It does not apply against credit institutions and financial institutions, so a bank still sees what it needs.

It does not apply against the authorities. The supervisory authority, the financial intelligence unit, Customs, the Tax Department and the Police are outside it.

And nothing can be said about the chance of success. Only grants are published. The number of applications made, refused or withdrawn is not, so five grants is not a success rate and should not be read as one. Anyone quoting a percentage has invented it.

What the registers do not do

They do not make the trust invisible to a bank. An obliged entity entering a business relationship with a trustee is required to collect proof of registration or an extract of the register, and the trustee is required to declare that it acts as trustee and hand over the information. That is a statutory obligation on both sides, and no exemption reaches it.

They do not displace the trustee's own duty of confidence. Section 11 of the International Trusts Law provides that the trustee may not disclose trust documents or information, and that where a beneficiary asks for accounts the trustee may disclose only if, in the trustee's opinion, disclosure is necessary and secures the bona fide interests of the trust. That is a discretion resting with the trustee, not a right resting with the beneficiary.

They do not stop information crossing borders by other routes. Tax information exchange, automatic reporting of financial accounts and mandatory disclosure of cross border arrangements all operate independently of these registers and are not affected by anything on this page.

And they do not conceal beneficial ownership. They restrict who may look at it. Those are different propositions, and a structure sold on the first one is sold on something the statutes do not provide.

The honest summary

Neither register is open to public search. One of them does not record who benefits at all. The other does, and a stranger wanting to see it must satisfy the Commission that they are fighting financial crime, show what they have already done about it, be approved individually, and then pay per trust for five data points. There is a further application available to close even that, on a ground a holder of a substantial identifiable asset may plausibly meet, which takes effect from the day it is filed.

None of that is concealment, and it is stronger than concealment would be, because every part of it is written down and can be checked against the statute rather than taken on trust.