Renewal or surrender of Cayman Islands director registration to avoid non-compliance: action required

Action is required for any person registered under the Directors Registration and Licensing Act (Revised) (DRLA) which enables them to act as a director of a "covered entity". Covered entities include funds registered as mutual funds under the Mutual Funds Act (Revised) and certain "registered persons" under the Securities Investment Business Act (Revised), including certain investment managers.

Such directors are required to log in to confirm their registration and pay the annual fee by 15 January 2027 with the Cayman Islands Monetary Authority (CIMA) under the DLRA. Directors who fail to pay their annual registration fee by 15 January are liable to a late payment penalty under the DRLA, in addition to the outstanding annual fee.

Note that funds regulated under the Private Funds Act (Revised) are not currently covered entities and directors of such entities are not required to be registered under the DRLA. 

Failure to register, renew or update director information (such as ceasing to act as a director of a covered entity) in accordance with the relevant deadlines may result in penalties under Cayman's administrative fines regime. Failure to renew a DRLA registration or licence will result in the covered entity ceasing to be in good standing with CIMA and potentially being in breach of regulations applicable to covered entities, resulting in further substantial administrative fines for that entity. For example, on 31 August 2026, CIMA published a warning notice identifying certain registered directors whom it considered to be non-compliant with the DRLA for failing to maintain their registrations, including by failing to pay the prescribed annual fee, and proposed to cancel their registrations.

Accordingly, we recommend that directors address the requirements for renewal or surrender of their registrations as soon as possible.

Any director who has ceased to be appointed as a director of any covered entity (either due to the resignation of the director or if the covered entity has completed its deregistration with CIMA) and does not intend to act as a director of a covered entity in the future may surrender their registration. To avoid incurring fees for 2027, the surrender (including payment of the relevant surrender fee) must be completed by 31 December 2026.

All updates, renewals and surrenders are managed through CIMA's online portal. Each director will have their own login details.

Visit CIMA's online portal: CIMA Director Gateway

Where a director is intending to surrender their registration on the basis that the remaining CIMA regulated mutual fund that they act as a director for is deregistering with CIMA, Ogier advises that the director may only proceed once the covered entity has completed the deregistration process with CIMA. For further information on the termination of Cayman vehicles and minimising 2027 fees, see our briefing: Termination of Cayman Islands entities: key options and year-end timing for 2026/2027.

For further information concerning any of the above matters, contact your usual Ogier attorney or any of the contacts listed in this briefing.

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Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

Regulatory information can be found under Legal Notice