by Andria Papageorgiou

COMPLIANCE, CYSECJanuary 31, 20250 comments

CySEC Publishes Consultation Paper on Fees under DORA

The Cyprus Securities and Exchange Commission (CySEC) has issued Consultation Paper CP-01-2025, outlining the proposed fees for entities falling under the Digital Operational Resilience Act (DORA). This move aligns with the Regulation (EU) 2022/2554, which aims to establish a harmonized framework for digital operational resilience across the financial sector in the European Union.

A. Scope of the Consultation

The paper is open for feedback from market participants and investors until March 7, 2025. It specifically concerns financial entities regulated by CySEC, including:

• Cyprus Investment Firms (CIFs)
• Crypto-Asset Service Providers (CASPs)
• Central Securities Depositories
• Central Counterparties
• Trading Venues
• Alternative Investment Fund Managers (AIFMs)
• Management Companies
• Crowdfunding Service Providers

B. Key Proposals on Fees

CySEC proposes an annual ICT Oversight Fee, depending on the entity’s classification under DORA:

Additionally, financial entities required to undergo a Threat-Led Penetration Test (TLPT) will face an additional TLPT assessment fee of €50,000 per test.

C. Implementation and Compliance

Entities must self-categorize based on their latest audited financial statements and submit their classification to CySEC between September 1-15 each year. The applicable fee must be paid by November 30 annually, with the first payments due in 2025.

D. Consultation Questions

CySEC invites stakeholders to provide input on:

1. Whether they agree with the proposed annual ICT Oversight Fee.
2. Whether they agree with the TLPT assessment fee.

Responses should be concise and submitted in a Word document via email to [email protected], following the format:
“CP-01-2025 – [Name of Organization or Individual]”.

The Consultation Paper on DORA fees marks an important step in Cyprus’ regulatory alignment with EU financial resilience standards. Market participants are encouraged to review the proposals and submit feedback before the March 7 deadline.

For further details, refer to the full Consultation Paper here.

In case you have any questions, please do not hesitate to contact us for further professional assistance.

Disclaimer: The information contained in this article is provided for informational purposes only, and should not be construed as legal advice on any matter. Andria Papageorgiou Law Firm is not responsible for any actions (or lack thereof) taken as a result of relying on or in any way using information contained in this article and in no event shall be liable for any damages resulting from reliance on or use of this information.