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Foreign Direct Investments (FDI) screening and approval requirement coming to Cyprus

The Council of Ministers will be finally introducing the much talked about Foreign Direct Investments (“FDI”) Bill to Parliament for approval, aiming to screen foreign investments that may pose risks to national security or public order in compliance with EU Legislation.

Scope of the new mechanism

The proposed law applies to foreign direct investments in enterprises operating in strategic sectors, such as:

  • Energy
  • Transport and communications
  • Health and biotechnology
  • Defence and national security
  • Financial services
  • Digital infrastructure and dual-use technologies

When does an Obligation to notify arise?

A notification obligation will arise when a Foreign Investor acquires at least 25% of the share capital of a strategic enterprise, or increases an existing shareholding to or beyond 50%.

Who is considered a Foreign Investor?

The definition of “foreign investor” includes both:

  • Natural or legal persons based outside the EU/EEA/Switzerland, and
  • EU-based entities that are 25% or more owned or controlled by third-country investors.

This ensures that indirect or structured investments via EU jurisdictions remain within the scope of the law, closing potential loopholes.

Review process and oversight

The Ministry of Finance will serve as the competent authority, responsible for receiving notifications and conducting risk assessments. It will have the legal authority to:

  • Approve the investment;
  • Prohibit it, if risks are identified; or
  • Unwind a completed transaction in exceptional cases.

Limited exemptions

The mechanism includes certain exemptions to avoid undue interference in routine transactions. Notably, it excludes investment in vessels under construction or subject to sale, except for floating storage and regasification units (FSRUs), which are classified as critical to national energy infrastructure and remain subject to review.

Strategic and legal implications

This development is not a move toward protectionism but a measured step to enhance resilience and ensure Cyprus remains aligned with the EU’s evolving approach to foreign investment governance, in accordance with EU legislation.

What businesses should do

Foreign investors and companies engaged in M&A or strategic partnerships in Cyprus should take early steps to evaluate whether their transactions may fall within the scope of the screening mechanism. This includes reviewing ownership structures, transaction thresholds, and industry classification.

Advance planning is especially important, as transactions cannot proceed without clearance once the law is in force. Timing, documentation, and regulatory coordination will be key factors for successful execution.

How we can assist

At Chrysses Demetriades & Co LLC, we assist clients in navigating complex investment regulations and regulatory approvals. Our team advises on:

  • Transaction structuring to ensure compliance;
  • Preparation and submission of screening notifications;
  • Liaison with the Ministry of Finance and other relevant authorities;
  • Strategic risk assessments for multi-jurisdictional investments.

If you are considering an investment in Cyprus that may be affected by the new screening rules, or if you are unsure whether notification is required, our team is ready to assist with practical, business-focused legal guidance.

For further information, please contact Demosthenes Mavrellis at demosthenes.mavrellis@demetriades.com


New legal framework on Workplace Violence and Harassment in Cyprus


On 11 April 2025, Cyprus enacted Law 42(I)/2025, officially titled The Prevention and Combating of Violence and Harassment in the Workplace Law of 2025. This legislation marks a significant step in safeguarding individuals from violence and harassment in professional settings, while introducing clear obligations and liabilities for employers and employees alike.

The Law is designed to prevent and address acts of violence and harassment in the workplace, protect individuals who report or witness such incidents and ensure confidentiality in handling cases. It also acknowledges the broader impact of domestic violence, requiring employers to support affected employees where reasonably feasible. The scope of the Law extends to employees, employers, and third parties with professional ties to a workplace. It applies to conduct taking place not only at traditional work premises but also in any setting or context linked to professional duties — including work-related travel, training, social events, or even digital communication.

Crucially, both violence and harassment are now classified as criminal offences. “Violence” includes actions or behaviours — even single incidents — that can cause physical, psychological, sexual, or economic harm. “Harassment” refers to unwelcome behaviour that undermines a person’s dignity or creates a hostile work environment. Anyone found guilty of committing or inciting such acts may face up to three years in prison, fines up to €10,000, or both. Obstructing a complaint or retaliating against the complainant is also punishable by law.

Legal persons (companies and other organisations) may also be held criminally liable for offences committed by individuals acting on their behalf or due to failures in supervision. Penalties for legal entities can reach up to €20,000, without affecting the liability of the individuals involved.

Employers have a central role in enforcing the Law. They must actively prevent workplace violence and harassment by adopting appropriate policies and procedures, ensuring complaints are handled fairly, confidentially, and without reprisal. Employers are required to draft a code of conduct, in consultation with employee representatives, clearly defining unacceptable behaviours and outlining complaint procedures. They must also designate trained personnel to handle such matters and ensure regular communication and training for staff.

Employees are protected against any adverse action — including dismissal or changes to working conditions — arising from the filing of a complaint or participation in related proceedings. These protections also apply to those who support or testify in such cases.

Complaints may be submitted to Labour Ministry inspectors or the Commissioner for Administration and the Protection of Human Rights (Ombudsman), who are tasked with enforcing the Law. All actions taken under the Law must comply with relevant data protection rules, particularly the GDPR.

Keywords: code of conduct, employee rights, employer obligations

For more information please speak with Thomas Christodoulou or your usual contact at Chrysses Demetriades & Co LLC.


Chrysses Demetriades & Co LLC joins the Cyprus International Business Association

We are pleased to share that our firm has recently joined the Cyprus International Business Association (CIBA), an organization that plays a significant role in representing and supporting the interests of international businesses operating in Cyprus.


Through this membership, we aim to contribute to CIBA’s ongoing efforts to promote a stable and business-friendly environment, while also remaining closely engaged with developments that affect the broader international business landscape.

This step reflects our continued commitment to maintaining strong ties within the professional community and to supporting initiatives that encourage sustainable growth and collaboration.

New Law enhances regulation of Fund Administrators in Cyprus

On 29 May 2025, the House of Representatives passed the Investment Funds Administrators Law, L.101(I)/2025, marking a pivotal advancement in Cyprus’s financial regulatory regime. Published in the Official Gazette on 18 June 2025, the Law introduces a standalone legal framework for the regulation and supervision of fund administrators—a sector previously operating under the broader umbrella of fund manager legislation.

This legislative development establishes a distinct regime tailored to the operations of fund administration companies, bringing Cyprus into closer alignment with leading EU and global jurisdictions. For the first time, investment fund administrators are subject to direct licensing and supervision by the Cyprus Securities and Exchange Commission (CySEC), ensuring a higher level of regulatory consistency and oversight.

Under the Law, fund administrators are required to maintain minimum capital reserves—€50,000, or €125,000 where additional services are provided—carry professional indemnity insurance, and operate from a registered and central office located in Cyprus. Governance standards are enhanced through obligations relating to board structure, internal controls, and risk management. In addition, the Law imposes robust compliance, reporting, and anti-money laundering obligations, reflecting a clear commitment to operational integrity and investor protection.

The scope of permitted activities includes core administrative services such as maintaining investor registers, calculating net asset values, and processing investor transactions for both UCITS and Alternative Investment Funds. While these functions were previously referenced under existing legislation and EU directives, they are now unified within a coherent and purpose-built legal structure.

Investor confidence is further safeguarded through provisions addressing conflicts of interest, mandatory disclosure requirements, and reinforced governance mechanisms. CySEC is granted broad enforcement powers to ensure adherence, including the imposition of sanctions where necessary.

The enactment of this Law significantly enhances the regulatory clarity and professionalism of Cyprus’s fund services sector. By setting a defined operational and supervisory framework, the Law strengthens the jurisdiction’s credibility and appeal to international asset managers seeking a stable and transparent European base. It represents a strategic step forward in Cyprus’s ongoing effort to modernise its financial services landscape and support sustainable growth in the investment funds industry.

For more information, please contact Demosthenes Mavrellis (demosthenes.mavrellis@demetriades.com) or your usual contact at Chrysses Demetriades & Co LLC.



Environmental litigation in Cyprus: A new Constitutional Era

Cyprus has entered a pivotal phase in environmental protection with the adoption of the Nineteenth Amendment to its Constitution in 2024. This landmark reform explicitly enshrines the right to a safe and sustainable environment, shifting from implied constitutional protections to a direct legal mandate.


In an article published in the e-newspaper of the Great Britain – Cyprus Business Association (GB-CY), our partner Katia Kakoulli explores how the amendment enhances access to justice, broadens legal standing, and imposes clearer obligations on the state, fundamentally reshaping environmental litigation in Cyprus. The piece also examines the historical legal context and the practical implications for individuals, businesses, and advocacy groups navigating this strengthened legal landscape.

Read the full article here: 

https://www.gbcy.business/_files/ugd/54fdf4_3ac1e447d5dd469fa8de863a34110a94.pdf

For more information please speak with Katia Kakoulli or your usual contact at Chrysses Demetriades & Co LLC.


Financing Renewable Energy projects and acquisitions: Key considerations for Investors and Lenders


The global energy transition is well underway, and renewable energy is at the heart of this shift. As the world moves towards decarbonisation, the financing landscape for Renewable Energy Sources (RES) projects and acquisitions is becoming increasingly sophisticated. With many government subsidies gradually being phased out, investors and lenders must now navigate complex financial structures to bring clean energy projects to life. Understanding the legal and financial frameworks that underpin renewable energy investments is critical to ensuring project success and long-term profitability.

At Chrysses Demetriades & Co LLC, we specialise in renewable energy law, offering comprehensive legal support to clients investing in and financing solar, wind, and other clean energy projects. Our expertise includes project finance, mergers and acquisitions (M&A), regulatory compliance, and due diligence—helping clients mitigate risks and unlock opportunities in this dynamic and rapidly evolving sector.

RES Project financing: A shifting landscape

Financing RES projects typically involves a mix of equity and debt financing, sourced from:

  • Government and transnational institutions (e.g., EU funding for green infrastructure projects).
  • Traditional financial institutions (banks and investment funds).
  • Alternative sources (private equity and institutional investors focused on sustainable investments).

Historically, the RES sector benefitted from subsidies and feed-in tariffs that spurred early development. While such incentives have largely tapered off for new projects, legacy agreements—such as those with the Renewable Energy Sources and Energy Conservation Fund—continue to provide long-term revenue stability for earlier investments.

Today, the viability and bankability of renewable projects hinge less on the sponsor’s financial strength and more on project-specific fundamentals, including:

  • Predictable cash flows,
  • Long-term Power Purchase Agreements (PPAs),
  • Regulatory clarity, and
  • Secure permitting and land tenure.

Still, sponsors may be asked to provide additional security (e.g., corporate guarantees or asset pledges) to strengthen the creditworthiness of the financing package.

Key considerations for Lenders and Investors in RES projects

When structuring RES project financing, lenders seek strong security over assets and income streams. Common measures include:

  • Mortgages on land used for solar or wind installations (freehold or long-term lease).
  • Assignment of receivables from PPAs with licensed suppliers or the Electricity Authority of Cyprus (EAC).
  • Insurance coverage tailored to RES related risks (e.g., weather variability, equipment failure).
  • Fixed and floating charges over project assets and revenues.
  • Share pledges over the project company to facilitate enforcement in case of default.

While cross-border financing agreements may be governed by international standards (often English law), local security documents remain subject to Cyprus law, requiring precise legal structuring to ensure enforceability.

How we help: Our firm advises on structuring renewable energy financing, aligning with both lender expectations and local legal requirements, while safeguarding our clients’ strategic and commercial objectives.

RES M&A: The importance of Due Diligence

As investor appetite grows for operational and development-stage renewable assets, thorough due diligence remains essential to assessing risks, validating investment assumptions, and ensuring regulatory compliance.

Key workstreams in RES M&A Due Diligence:

  • Legal: Project company structure, licensing status, and contractual rights.
  • Technical: Performance metrics, grid connection viability, and technology risk.
  • Financial: Revenue projections, cost assumptions, and debt servicing ability.
  • Business: Market dynamics and offtake competitiveness.
  • Real Estate: Land use rights, lease terms, zoning, and environmental constraints.

Critical legal considerations in RES transactions

🔹 Ownership & corporate structure
Ensuring the correct legal ownership of shares and project assets is vital—especially when renewables projects are structured via special purpose vehicles (SPVs).

🔹 Licensing & regulatory compliance
Renewable energy projects require multiple licenses (generation, environmental, construction, etc.). Any gaps or non-compliance can delay commissioning or trigger penalties.

🔹 Land tenure & Real Estate rights
Solar and wind installations often span large land areas. Legal review must confirm secure, long-term rights to use land—without encumbrances that could threaten project financing.

🔹 Power Purchase Agreements (PPAs)
PPAs are foundational to revenue certainty in renewables. Given that Cyprus currently operates a transitional electricity market, PPAs remain essential for selling energy under bilateral terms. Where PPAs are not yet in place, acquirers must either condition their investment on agreement execution or ensure bankable alternatives exist.

Material contracts & Change of Control restrictions

Investors and buyers must review:

  • Engineering, Procurement & Construction (EPC) and Operations & Maintenance (O&M) agreements.
  • Service contracts that may carry ongoing obligations.
  • Change of control provisions requiring consent from third parties before the project can be transferred or acquired.

How we help: We support clients through the entire acquisition process—conducting detailed due diligence, negotiating transaction documents, and structuring deals to minimise risk and maximise return.

Looking ahead: Opportunities in the RES market

The renewable energy sector presents compelling opportunities for investors and lenders aligned with sustainability goals. Success, however, requires a deep understanding of the legal and financial ecosystem in which these projects operate. Whether you’re financing a new solar park, acquiring a wind farm, or negotiating a long-term PPA, expert legal guidance can be the difference between a good project and a great one.

At Chrysses Demetriades & Co LLC, we partner with stakeholders across the renewable energy value chain to provide:

  • Tailored legal advice for renewable energy project financing and M&A,
  • Expertise in structuring project finance and bankable security packages,
  • Comprehensive due diligence and regulatory compliance support, and
  • Strategic contract negotiation and risk mitigation for PPAs and energy trading arrangements.

For more information, please contact Chrysses Demetriades or your usual contact at Chrysses Demetriades & Co LLC.


EU Procurement Law limits rights of Third-Country operators: Key takeaways from the CJEU Kolin Inşaat Decision

In a landmark ruling, the Court of Justice of the European Union (CJEU) has clarified the position of third-country economic operators—those outside the EU and lacking specific trade agreements—regarding participation and equal treatment in EU public procurement. The Kolin Inşaat Turizm Sanayi ve Ticaret decision (Case C-652/22, EU:C:2024:910) outlines significant restrictions on the rights of these operators to challenge procurement awards, marking a practical setback for claims of non-discrimination in EU tenders.

Key Background on the Decision

The issue arose when Kolin Inşaat, a Turkish firm, participated in an EU procurement procedure governed by Directive 2014/25, which applies to procurement within utility sectors and includes clauses under which third-country operators can be excluded or limited based on the presence (or absence) of trade agreements. Specifically, Article 43 of this Directive provides access to public procurement only to economic operators from countries with an international agreement with the EU, such as the WTO Government Procurement Agreement (GPA) or a relevant Free Trade Agreement (FTA). Turkey, however, does not have such an agreement covering public procurement with the EU. The court’s interpretation underscored that, although EU law does not outright exclude operators from such third countries, it does not extend equal treatment rights to them either.

Ruling Highlights: limited rights for non-EU economic operators

The CJEU’s ruling reinforced that, in the absence of an EU trade agreement, third-country operators do not have the right to demand equal treatment under EU procurement law. While they may be allowed to participate in specific tenders, they cannot invoke rights to non-discriminatory treatment guaranteed by Directive 2014/25 for EU operators or those from countries covered by applicable agreements.

1.     Non-Application of Equal Treatment: The CJEU clarified that third-country economic operators lacking an EU international agreement cannot rely on the EU’s procurement directives for protection from discriminatory practices. Thus, they have no basis to challenge awards on the grounds of equal treatment if their tender is disadvantaged.

2.     Directive limitations: Article 45(1) of Directive 2014/25 entitles “any interested economic operator” to submit tenders; however, this right does not equate to equal treatment in the case of third-country operators not covered by agreements. The court indicated that granting equal treatment in such cases would conflict with the principles set in Article 43 of Directive 2014/25, which reserves these benefits for signatories of relevant EU agreements.

3.     Practical implications for Third-Country bidders: The ruling effectively restricts third-country bidders from challenging procurement decisions based on EU directives if they lack treaty-based rights. This could deter participation by such operators, given the absence of recourse in cases of potential bias.

Conclusion: A pragmatic limitation for Non-EU Bidders

The Kolin Inşaat decision underscores the boundaries of EU procurement rules and reinforces the significance of trade agreements in ensuring access and rights for non-EU companies. Without such agreements, third-country operators face significant limitations, both in terms of participation rights and legal recourse. This decision highlights the critical need for understanding treaty-based rights and the limitations inherent in EU procurement law for third-country operators.

For more information, please contact Katia Kakoulli or your usual contact at Chrysses Demetriades & Co LLC.

Registration of essential employment terms in Ergani: new deadline for Cypriot employers

A new deadline has been set for the employers’ obligation to register in Ergani the essential terms of employment contracts.

Cypriot employers must take immediate steps to comply with a mandatory employment registration requirement introduced by the Ministry of Labour & Social Insurance. Under a recently issued decree, all employers—regardless of size or industry—must register the essential terms of employment for every employee, both existing and new, in the Ergani information system, which is the official online platform of the social insurance department

Extended compliance deadline – what employers need to know

The original deadline for completing this process was 28 February 2025, but an extension has now been granted until 31 May 2025. While this additional time provides some breathing room, it is essential that employers act now to avoid last-minute administrative burdens or potential non-compliance risks.

To comply with the decree, employers must ensure they have an active employer account in Ergani and submit an “employment contract” for every employee—this applies to all workers, including full-time, part-time, and fixed-term employees, without exception.

The information that must be registered includes:
✔ job title, job description, and the employee’s area of specialization
✔ workplace location (both as stated in the employment contract and the actual workplace at the time of registration)
✔ employer details (including the official registered office and, for retail businesses, the type of business)
✔ employee details (personal information and identification data)
✔ start date of employment
✔ end date of employment (for fixed-term contracts only)
✔ terms and duration of the probationary period
✔ standard working hours per day/week
✔ indication if the employee’s working schedule is unpredictable
✔ agreed salary or wages and the frequency of payment (daily, weekly, monthly, or hourly)
✔ annual leave entitlement and method of allocation
✔ additional benefits, allowances, commissions, or cost-of-living adjustments
✔ for temporary employment businesses, the details of the indirect employer

Failure to ensure complete and accurate registration of this information may lead to penalties, complications in employment disputes, or compliance investigations.

Why does this matter?

This registration requirement is more than just an administrative formality—it is a major compliance measure aimed at increasing transparency in employment relationships across Cyprus. it reflects the government’s ongoing efforts to strengthen labour protections, reduce unfair employment practices, and combat undeclared or improperly reported work.

The Ergani system serves as a centralized database, allowing authorities to verify that employment agreements align with national labour laws and ensuring that workers’ rights—such as wages, working hours, and leave entitlements—are properly documented and enforceable. For businesses, compliance with this requirement is not only a legal obligation but also an opportunity to streamline HR and payroll processes by maintaining a clear and structured record of employment terms.

Moreover, non-compliance could carry legal and financial risks, particularly in cases where disputes arise over employment terms. Proper registration in Ergani can serve as crucial evidence in demonstrating an employer’s adherence to legal requirements.
Additionally, businesses operating in industries with frequent labour inspections or regulatory oversight—such as hospitality, retail, and construction—should be particularly vigilant in ensuring timely and accurate registration to avoid potential scrutiny from labour authorities.

What employers should do now

Although the deadline has been extended, businesses should use this time strategically to ensure full compliance before the final deadline of 31 May 2025. Key steps include:
• confirming whether an Ergani employer account is already active—if not, complete the registration process as soon as possible.
• reviewing and updating all employment contracts to ensure they contain the necessary information required by the decree.
• gathering missing employee data early to prevent last-minute delays in completing the registration.
• assigning HR or legal teams to oversee compliance and ensuring that all employment terms are recorded correctly.
• submitting registrations well in advance to avoid system congestion or last-minute technical issues as the deadline approaches.
• seeking legal or HR consultation if any uncertainties arise regarding employment terms, data entry, or technical aspects of the Ergani system.

For more information, please contact Thomas Christodoulou or your usual contact at Chrysses Demetriades & Co LLC.

Top Tier rankings in The Legal 500 EMEA 2025

Our firm has once again been highly ranked in the latest Legal 500 Europe, Middle East & Africa Guide, receiving Top Tier rankings in all major practice areas in Cyprus: Commercial, Corporate & M&A, Dispute Resolution, Maritime & Admiralty, and Real Estate & Construction and recommended firm in Banking & Finance, Employment and EU & Competition.

This recognition underscores the trust our clients place in us and the depth of expertise within our firm. Our sincere gratitude goes to our clients, peers and instructing firms around the globe for their continued confidence and support.

To access our rankings and Legal 500’s Editorial Commentary about our firm visit: https://www.legal500.com/firms/10119-chrysses-demetriades-co-law-office/c-cyprus/rankings

MIQC Meets in Cyprus

The Marshall Islands Quality Council (MIQC) held its spring meeting in Limassol, Cyprus in April 2024. Gathering biannually, the MIQC is a consultative consortium of shipowners, managers, industry experts, and leaders that gather for open dialogue and discussion to enhance Republic of the Marshall Islands (RMI) Registry operations. MIQC meetings focus on the sharing of information and experiences and raising awareness and knowledge on a diverse range of industry issues. The April 2024 MIQC meeting, hosted by MIQC member Michael McBride, at the offices of Chrysses Demetriades & Co. LLC, included MIQC members, invited guest speakers, and RMI Registry personnel. Rear Admiral (RADM) Kevin S. Cook, United States Coast Guard (Retired) chairs the MIQC.

RADM Cook opened the meeting, with presentations from International Registries, Inc.’s (IRI’s) President Bill Gallagher (Reston); Chief Maritime Officer Simon Bonnett (London); Chief Commercial Officer Theo Xenakoudis (Piraeus); and Vice President, Maritime Brian Green (Fort Lauderdale) covering updates and news on the RMI Registry. This high-level insight set the stage for topical discussions on regulatory updates and outcomes from the International Maritime Organization and port State control trends worldwide. Prabhat Jha, Managing Director, MSC Shipmanagement Cyprus Limited, made a special presentation to the group. Dr. Thilo Dückert, Head of Product Development, OceanScore GmbH presented on the European Union (EU) Emissions Trading System/FuelEU Maritime Regulation.

The meeting concluded with a panel discussion on the situation in the Red Sea moderated by Brian Green, Vice President, Maritime (Fort Lauderdale). Joining the discussion were Captain Lee Stuart, Maritime Liaison Officer, United States Naval Forces Central Command; Russell Pegg, Maritime Security Advisor, Oil Companies International Marine Forum; James Wilkes, Managing Director, Gray Page; and Christos Kottas, Executive Director, J.P. Morgan Asset Management.

MIQC meetings provide a platform for information sharing, open discussion, and strengthened relationships between industry stakeholders and the RMI Registry’s team of professionals.

* This Article was first published in MIQC Meets in Cyprus – IRI | International Registries, Inc.

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