Cayman Islands investment funds - Summer 2026 update

Common Reporting Standards and Economic Substance updates

The Department for International Tax Cooperation ("DITC") has issued an Industry Advisory outlining important updates to the Common Reporting Standards ("CRS") and Economic Substance ("ES") reporting requirements. The key updates are:

• For 2025 reporting period, the deadline for CRS Return is 31 July 2026 and the CRS Compliance Form is 15 September 2026.
• DITC is putting in place an updated XML Schema version 3.0 ("CRS XML v3.0") and as a result the DITC portal will be closed for submissions from early August for the transition to CRS XML v3.0 and will not reopen until early 2027. For the avoidance of doubt, this does not represent an extension of the 31 July 2026 filing deadline and Financial Institutions ("FIs") are reminded to ensure their CRS Reportable Accounts for the 2025 reporting period are submitted by the 31 July 2026 deadline.
• When the DITC portal reopens in 2027, all new filings, corrections, and deletions must use CRS XML v3.0. The updated OECD CRS XML Schema User Guide (v 4.0) and XML Schema v3.0 XSD files can be found on the OECD Tax Transparency Resource Centre.
• Following the transition to CRS XML v3.0, the DITC will no longer provide its XML generator tool so FIs should make alternative arrangements.
• DITC has published updated Individual Self-Certification Form and Entity Self-Certification Form on the DITC website, effective from 1 January 2026. The use of these templates is not mandatory, but they do include the minimum mandatory data that must be collected.
• DITC will no longer send courtesy reminder emails to Responsible Persons in advance of ES filing deadlines. From the 2025 ES year onwards, reminders will only appear via the DITC portal’s messaging banner. Relevant entities are expected to proactively monitor filing deadlines through the DITC portal and internal compliance systems.
• For 2026 reporting period, both the CRS Return and CRS Compliance Form will be due by 30 June 2027, replacing the previous 31 July and 15 September deadlines respectively.
• The two-factor authentication, previously required only for account activation, will be extended to all access to the DITC Portal, with implementation anticipated in Q3 2026.

Tokenised funds framework now in effect

In our Spring 2026 newsletter, we summarised the Cayman Islands’ new framework for tokenised investment funds, which came into force on 24 March 2026 through amendments to:

1. the Mutual Funds Act (as revised) ("MF Act");
2. the Private Funds Act (as revised) ("PF Act"); and
3. the Virtual Asset (Service Providers) Act (as revised) ("VASP Act").

The legislation provides regulatory certainty for tokenised fund structures by recognising the use of distributed ledger technology and digital tokens to represent investment interests.

Importantly, tokenised mutual funds and private funds continue to be regulated under the MF Act and the PF Act, respectively and the issuance of digital tokens representing ownership interests in a regulated Cayman Islands fund does not constitute a "virtual asset issuance" for the purposes of the VASP Act and therefore does not require separate approval from the Cayman Islands Monetary Authority ("CIMA").

For more information, please see our Regulatory Update linked here.
CIMA fund statistics

The Cayman Islands investment funds industry has continued to grow during the first half of 2026, reinforcing the jurisdiction’s position as a leading offshore domicile for investment funds. The total number of regulated funds domiciled in the Cayman Islands increased by 547 in the first half of 2026 to reach 31,145, according to Q2 2026 statistics published by the CIMA. Private and mutual fund registrations are now both at record highs. The full statistics can be found here.