Cyprus Registrar to Commence Strike-Off Proceedings for Unpaid Annual Levies
Key Legal Considerations for Directors, Shareholders and Corporate Service Providers
Introduction
On 30 September 2026, the Cyprus Department of Registrar of Companies and Intellectual Property (the “Registrar”) announced that it will commence strike-off proceedings in December 2026 against companies with outstanding annual levy obligations for any of the years 2012 to 2023.
The announcement is significant for Cyprus companies and corporate groups with outstanding historical annual levies, particularly in view of the abolition of the annual levy from 2024 onwards.
Importantly, the abolition of the annual levy does not relieve companies of their outstanding obligations in respect of previous years.
1. Legal Framework and Outstanding Annual Levy Obligations
The Registrar’s intended action is based on section 327(2A)(b) of the Companies Law, Cap. 113 (the “Companies Law”), which provides for the striking off of companies in circumstances involving non-payment of annual levies.
The annual levy obligations were governed by section 391 of the Companies Law. Pursuant to the Companies (Amendment) Law of 2024, Law 25(I)/2024, the annual levy was abolished with effect from 2024. However, liabilities relating to earlier years remain outstanding.
While the abolition announcement issued in March 2024 confirmed that annual levies for the years 2011 to 2023 remain payable, the Registrar’s announcement of 30 September 2026 specifically identifies companies with unpaid annual levies for any year between 2012 and 2023 as falling within the forthcoming strike-off initiative.
Accordingly, the relevant issue is whether a company has outstanding annual levy obligations for any of the years expressly identified in the September 2026 announcement.
2. The Announced Strike-Off Procedure
According to the Registrar’s announcement, the strike-off process will commence in December 2026.
Pursuant to section 327(3)(c) of the Companies Law, companies identified as having outstanding annual levies for any year between 2012 and 2023 will be subject to publication in the Official Gazette of the Republic of Cyprus, with a three-month period before the proposed strike-off takes effect.
Following that period, the Registrar intends to proceed with striking the relevant companies off the register unless cause is shown to the contrary.
The Registrar’s published procedural guidance further provides for notification to the company’s registered office and the possibility of an objection to the proposed strike-off.
The commencement of the process in December 2026 should therefore be distinguished from the actual striking off of a company, which follows the applicable statutory procedure.
3. Implications for Cyprus Companies
The forthcoming initiative highlights the continuing significance of historical statutory obligations, notwithstanding subsequent legislative changes.
For companies with outstanding annual levies, failure to address the relevant obligations may result in removal from the register and the company’s dissolution following completion of the prescribed procedure.
Such an outcome may have significant implications where the company continues to hold assets, maintain contractual relationships or form part of an investment or corporate group structure.
The assessment of any particular company’s position should take account of its outstanding obligations, its current registration status and any applicable grounds for objecting to the proposed strike-off.
4. Recommended Steps for Directors and Corporate Service Providers
In anticipation of the announced proceedings, directors and corporate service providers should review the annual levy payment records of the companies under their responsibility, particularly for the period 2012–2023.
Where outstanding amounts are identified, companies should verify the relevant liabilities, including any applicable penalties, and take appropriate steps to regularise their position.
Companies should also ensure that their registered office details are up to date and monitor any notices issued by the Registrar, including relevant publications in the Official Gazette.
Where a company disputes the basis for a proposed strike-off, the circumstances should be assessed promptly to determine whether an objection or other appropriate action is available under the applicable procedure.
Conclusion
The Registrar’s announcement of 30 September 2026 marks a forthcoming enforcement measure concerning unpaid annual levies for the years 2012–2023.
Although the annual levy was abolished from 2024, outstanding obligations relating to earlier years remain relevant, and companies affected by the announced initiative may face strike-off proceedings commencing in December 2026.
Directors, shareholders and corporate service providers should therefore take timely steps to verify historical annual levy liabilities and address any outstanding matters before the proposed proceedings progress.
Disclaimer: This publication is intended for general information purposes only and does not constitute legal advice. The application of the Companies Law and the relevant strike-off procedures depends on the facts and circumstances of each case. Specific legal advice should be obtained where appropriate.