Cayman Islands fund: the Mutual Funds Act and the Private Funds Act.

A Cayman Islands fund answers to the Cayman Islands Monetary Authority (CIMA) under one of two statutes. Open-ended funds use the Mutual Funds Act (2025 Revision), whose registered fund takes at least CI$80,000 per investor unless its interests are listed. Closed-ended funds use the Private Funds Act (2025 Revision): they apply within 21 days of commitments and take no capital before registration. We run both routes from George Town.

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Cayman Islands in brief

Cayman Islands fund: open-ended or closed-ended decides the statute.

A Cayman Islands fund falls under one of two statutes, and CIMA administers both. Open-ended funds come under the Mutual Funds Act (2025 Revision), revised as at 1 January 2025, under which CIMA regulates five types of mutual fund. The registered fund of s.4(3) takes a minimum of CI$80,000 (US$100,000) per investor unless its interests are listed. A limited investor fund under s.4(4) has no more than 15 investors, a majority of whom can appoint or remove the operator. An administered fund takes its principal office from a licensed mutual fund administrator (s.4(1)(b)); a licensed fund holds its own licence (s.4(1)(a)); master funds make the fifth type. Closed-ended funds register under the Private Funds Act (2025 Revision). Neither Act creates the vehicle: the company or partnership beneath is registered by the General Registry, not by CIMA.

CIMA's fee schedule, updated 20 October 2026, prices the open-ended route. A registered fund pays CI$4,125 to apply, CI$4,125 a year and CI$300 for filing the application form, plus CI$750 a year for each sub-fund, at US$1.00 = CI$0.82. Registering a mutual fund takes about five business days once CIMA has every document; licensing one takes four to six weeks. A private fund pays CI$300 to apply and an annual registration fee of CI$4,125, the first with the application, plus CI$525 for each alternative investment vehicle (AIV), and the Private Funds Act asks CIMA to decide "as soon as reasonably practicable after receiving the application" (s.7(3)). The awkward part sits outside CIMA's file. Every Cayman fund also needs a vehicle, a CIMA-approved auditor, named AML officers and a manager whose position under the Securities Investment Business Act (SIBA) has been checked. A sponsor can hold the management company's shares through a STAR or exempted trust, a Cayman Islands trust that sits above the fund.

A Cayman Islands fund is regulated by CIMA: open-ended funds under the Mutual Funds Act (2025 Revision), closed-ended funds under the Private Funds Act (2025 Revision). The vehicle is registered separately.

A registered fund pays CI$4,125 to apply and CI$4,125 a year, plus CI$750 per sub-fund, and registers in about five business days. Private funds file within 21 days of commitments.

The two builds

An open-ended mutual fund, or a closed-ended private fund.

Open-ended or closed-ended decides the statute before anything else. The vehicle beneath, an exempted company, a segregated portfolio company (SPC), an exempted limited partnership, a limited liability company (LLC) or a unit trust, is a separate choice.

A registered mutual fund for open-ended money, or a private fund for closed-ended money.

01 - REGISTERED MUTUAL FUND

The Cayman mutual fund

An open-ended fund registered under s.4(3) of the Mutual Funds Act: CI$80,000 minimum per investor, a CIMA-approved auditor and an administrator's consent letter in the file. Limited investor and administered funds are variants with tests of their own.

An open-ended fund registered under s.4(3) of the Mutual Funds Act: CI$80,000 minimum per investor, a CIMA-approved auditor and an administrator's consent letter in the file. Limited investor and administered funds are variants with tests of their own.

  • ✓Section 4(3) registration
  • ✓CI$80,000 minimum per investor
  • ✓CI$4,125 to apply and yearly
  • ✓Limited investor: up to 15
  • ✓Administered: licensed administrator
  • ✓About five business days
02 - PRIVATE FUND

The Cayman private fund

A closed-ended fund under the Private Funds Act (2025 Revision). It may accept commitments first, must apply to CIMA within 21 days, and takes no capital contributions until registered. No minimum investment applies.

A closed-ended private fund: commitments first, a CIMA application within 21 days, no capital before registration.

  • ✓Application within 21 days
  • ✓No capital before registration
  • ✓No minimum investment
  • ✓CI$4,125 a year
  • ✓CI$525 per AIV
  • ✓Custodian, or title check on notice

Reflects the Mutual Funds Act and the Private Funds Act (both 2025 Revision) and CIMA's fee schedule of 20 October 2026. The licensed fund of s.4(1)(a) is assessed case by case.

Why the Cayman Islands

Six reasons sponsors register funds with CIMA.

✓
A statute for each shape

Open-ended money sits under the Mutual Funds Act and closed-ended money under the Private Funds Act, each with its own fee table and its own annual return form.Two Acts, two shapes.

✓
Registration in days

CIMA's licensing page puts the registration of a mutual fund at about five business days once all documentation has been received. Licensing a fund takes four to six weeks.About five business days.

✓
Commitments come first

A private fund may accept capital commitments before it applies and then has 21 days to file (s.5(1)(a)). Capital contributions wait until CIMA registers it (s.5(6)).21 days after commitments.

✓
Sub-funds at CI$750

Each segregated portfolio or sub-trust of a registered mutual fund adds CI$750 a year to the CIMA bill, against CI$4,125 for a fund of its own.CI$750 per sub-fund.

✓
Five vehicles on offer

Exempted company, SPC, exempted limited partnership, LLC or unit trust: the fund can sit in any of them. We choose the vehicle apart from the statute, on tax and investor grounds.Company, SPC, partnership, LLC, unit trust.

✓
Director registration in 48 hours

A mutual fund director on fewer than 20 covered entities registers with CIMA for CI$700, then CI$700 a year, and CIMA's FAQ says confirmation should follow within 48 hours.Confirmation within 48 hours.

How it compares

How the Cayman Islands differ from other fund domiciles.

Cayman costs more to enter than Seychelles or the Bahamas. A Luxembourg RAIF skips CSSF product approval but must reach EUR 1,250,000 within 24 months; Cayman puts each mutual or private fund through CIMA.

Cayman Islands vs other fund domiciles
FeatureCayman IslandsOther domiciles
Application feeCI$4,125 + CI$300 filingB$2,000 Bahamas · US$750 Seychelles
Annual feeCI$4,125 · CI$750 per sub-fundB$2,750 + B$1,250 Bahamas · US$1,000 Seychelles
Regulator's clockAbout five business daysSeven working days, FSA Seychelles
Product approvalCIMA registers the fundNone for a Luxembourg RAIF
Application fee
Cayman IslandsCI$4,125 + CI$300 filing
Other domicilesB$2,000 Bahamas · US$750 Seychelles
Annual fee
Cayman IslandsCI$4,125 · CI$750 per sub-fund
Other domicilesB$2,750 + B$1,250 Bahamas · US$1,000 Seychelles
Regulator's clock
Cayman IslandsAbout five business days
Other domicilesSeven working days, FSA Seychelles
Product approval
Cayman IslandsCIMA registers the fund
Other domicilesNone for a Luxembourg RAIF
Country by country
CountryVehicleRegulatorNotes
Cayman IslandsMutual or private fundCIMACI$4,125 a year per fund
BahamasProfessional fund with administratorSCBB$2,000 to apply; B$2,750 + B$1,250 a year
LuxembourgRAIFNo CSSF product approvalEUR 1,250,000 in 24 months
SeychellesPrivate fundFSA SeychellesUS$750, then US$1,000 a year
Cayman Islands
VehicleMutual or private fund
RegulatorCIMA
NotesCI$4,125 a year per fund
Bahamas
VehicleProfessional fund with administrator
RegulatorSCB
NotesB$2,000 to apply; B$2,750 + B$1,250 a year
Luxembourg
VehicleRAIF
RegulatorNo CSSF product approval
NotesEUR 1,250,000 in 24 months
Seychelles
VehiclePrivate fund
RegulatorFSA Seychelles
NotesUS$750, then US$1,000 a year
Before you launch

What a Cayman Islands fund actually requires.What a Cayman Islands fund requires.

CIMA's checklists spell out why files come back, from missing compliance officer CVs to unregistered directors. The ten items below are in the file before it goes in.

01
Fund type - registered (s.4(3)), limited investor (s.4(4)), administered (s.4(1)(b)) or licensed (s.4(1)(a)) if open-ended; a private fund if closed-ended.
02
Minimum investment - CI$80,000 or its equivalent per investor in a registered fund (s.4(3)(a)(i)); CIMA confirms the Private Funds Act sets none.
03
Vehicle - an exempted company (objects mainly outside the Islands, Companies Act (2026 Revision) s.163), an SPC, an exempted limited partnership, an LLC or a unit trust.
04
Auditor - approved by CIMA and auditing every year (Mutual Funds Act s.8(1), Private Funds Act s.13(1)), with local sign-off for mutual funds.
05
Administrator - a consent letter in a registered fund's file; an administered fund takes its principal office from a licensed administrator.
06
Directors - at least two for a private fund company; a mutual fund's directors must be registered or licensed with CIMA, or its application is rejected.
07
AML officers - CVs for the AMLCO, MLRO and deputies, and the REEFS MLRO form MLO-154-99 with each registration.
08
Investment manager - SIBA registration or a licence if formed or based in the Islands; CIMA rejects a mutual fund whose manager lacks it.
09
Valuation - a regulated mutual fund's NAV at least quarterly by an independent provider; a private fund values at least once a year (s.16(3)).
10
Timing - a private fund applies within 21 days after accepting capital commitments; a fund formed over six months earlier adds an exemption letter.
01
Fund type chosen.
02
CI$80,000 minimum, registered fund.
03
Vehicle formed.
04
CIMA-approved auditor.
05
Administrator's consent letter.
06
Two directors (private fund).
07
AML officers named.
08
Cayman manager: SIBA status.
09
NAV and valuation set.
10
21-day filing window.

As of 2026, per the Mutual Funds Act and Private Funds Act, CIMA's Investment Funds FAQs and its July 2020 Rule on calculating asset values.Mutual Funds Act and Private Funds Act (2025 Revisions), as of 2026.

Verify it yourself

Official sources

Regulator pages, legal texts and public registers the figures on this page are based on.

How it works

From term sheet to a fund on CIMA's register.

01
Shape and statute

Open-ended or closed-ended, investor count, minimum ticket and sub-funds settled; that fixes the statute and the fund type.Statute and type fixed.

02
Vehicle

Exempted company, SPC or exempted limited partnership registered with the General Registry, with its directors or general partner in place.Vehicle registered.

03
Providers and papers

Auditor's and administrator's consent letters, offering memorandum or summary of terms, AML officers named, the manager's position checked.Letters and documents.

04
CIMA filing

Application and fees through REEFS. A private fund files within 21 days after accepting commitments and takes no capital before registration.REEFS filing.

05
Running the fund

Fees by 15 January, audited accounts and the fund annual return within six months of year-end, valuations kept on schedule.Annual cycle.

Quick facts
RegulatorCIMA
Open-endedMutual Funds Act
Closed-endedPrivate Funds Act
Registered fundCI$80,000 per investor
Limited investor fundUp to 15 investors
Sub-fund feeCI$750 a year
Mutual fund registrationAbout 5 business days
Private fund filingWithin 21 days

CIMA dates a fund's registration from the day a complete application arrives. We plan the providers' papers backwards from that date and confirm the private fund timetable with CIMA per file.

On the ground in the Cayman Islands

Run from our George Town office.

Prifinance - Cayman Islands
George Town · Grand Cayman
George Town, Grand Cayman
✆+1 786 755 8065✉info.en@prifinance.com
◷Mon-Fri · replies within one business day
01
Statute and type

Mutual or private fund, and which mutual fund type, decided on the liquidity terms and the size of the minimum ticket.Mutual or private fund.

02
Vehicle and Registry

The exempted company, SPC or exempted limited partnership formed with the General Registry before CIMA sees the fund.Registry before CIMA.

03
The REEFS file

Application form, notarised affidavit, auditor's and administrator's consent letters, offering document and MLRO form lodged as one set.One complete REEFS set.

04
After registration

CIMA fees paid by 15 January; then the audited accounts and the fund annual return, each due within six months of year-end.Fees, accounts, annual return.

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Good to know

Taxation of Cayman Islands funds.

Cayman can give an exempted company or partnership written undertakings against future local taxes. The investor's home country decides the rest, and the analysis goes there.

Exempted company undertaking

The Financial Secretary may undertake that no law later enacted to tax profits, income, gains or appreciations will apply to an exempted company, for up to 30 years (Tax Concessions Act (2018 Revision), s.6).Up to 30 years.

Partnership undertaking

An exempted limited partnership can obtain an undertaking for up to 50 years that reaches its partners and any estate duty or inheritance tax as well (Exempted Limited Partnership Act (2025 Revision), s.38).Up to 50 years.

Economic substance

Under the International Tax Co-operation (Economic Substance) Act (2026 Revision), fund management carried on for an investment fund is a relevant activity of the manager. The test lands on a Cayman manager.Manager carries the test.

Beneficial ownership

A fund registered under either Act may give the contact details of a licensed fund administrator under the Beneficial Ownership Transparency Act (2026 Revision), and that contact answers requests within 24 hours.Administrator answers within 24 hours.

Annual return to CIMA

A mutual fund files a fund annual return for itself and each sub-fund within six months of year-end, through the auditor; an operator in breach faces a fine of five hundred dollars.Six months, via the auditor.

Investor-level analysis

Each investor's home country decides the tax on distributions and gains, so we choose the vehicle and draft the offering document with the main investor countries in view.Home country decides.

Tax summary
Exempted companyUndertaking up to 30 years
Exempted LPUndertaking up to 50 years
Economic substanceFund excluded; manager in scope
Beneficial ownershipAdministrator can be the contact
Investor levelHome-country treatment

*As of 2026 per the Tax Concessions, Exempted Limited Partnership and Economic Substance Acts. Investor outcomes are modelled per structure.

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We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.

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Full-service assistance - from the choice of statute and vehicle to the REEFS filing, the auditor and administrator, and the first annual return - run through our George Town office.

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FAQ

Cayman Islands funds: what sponsors ask first.

What is a Cayman mutual fund?+

A Cayman mutual fund is an open-ended fund regulated by CIMA under the Mutual Funds Act (2025 Revision). CIMA recognises five types: registered, master, limited investor, administered and licensed. A registered fund under s.4(3) needs at least CI$80,000 or its equivalent per investor unless its interests are listed.

What is a Cayman private fund?+

A Cayman private fund is a closed-ended fund registered with CIMA under the Private Funds Act (2025 Revision). It must apply within 21 days of accepting capital commitments and may not take contributions before registration. CIMA's FAQ confirms the Act imposes no minimum investment.

Which vehicle does a Cayman fund use?+

An exempted company, a segregated portfolio company, an exempted limited partnership, a limited liability company or a unit trust. The General Registry registers companies and partnerships; CIMA regulates the fund itself, whatever its wrapper, under the Mutual Funds Act or the Private Funds Act. SPC portfolios are not separate legal entities.

How long does it take to launch a Cayman Islands fund?+

About five business days at CIMA for a mutual fund once every document is in, and four to six weeks to license one. For a private fund the Act says "as soon as reasonably practicable". Before either filing, we plan several weeks for the vehicle and the providers' letters.

What does a Cayman Islands fund cost?+

CIMA charges a registered mutual fund CI$4,125 to apply, CI$4,125 a year and CI$300 for the application form, plus CI$750 a year per sub-fund; a private fund pays CI$300 to apply and CI$4,125 on registration and each year, plus CI$525 per AIV. Registry, auditor and administrator fees come on top. Our fee follows in writing after a free assessment.

Does the investment manager need a licence?+

Only if SIBA reaches it: a manager formed in the Islands or with a place of business there must be licensed, or registered if it serves only sophisticated or high net worth clients (SIBA ss.4(1), 5(1), Sch. 4). CIMA rejects a mutual fund whose manager lacks that, and a private fund only where it is required. Registration costs CI$6,000, then CI$6,000 a year; a securities manager licence CI$1,000, CI$10,000 on grant and CI$10,000 a year.

Who audits and values the fund?+

A CIMA-approved auditor, every year, with audited accounts due at CIMA within six months of year-end. A regulated mutual fund's NAV is calculated at least quarterly by a provider independent of the manager, save for disclosed exceptions; a private fund values its assets at least annually (s.16(3)).

Is the fund caught by economic substance rules?+

No. The Economic Substance Act (2026 Revision) excludes an investment fund from its relevant entities and leaves investment fund business off its list of relevant activities. A Cayman manager is another matter, since fund management for a fund is a relevant activity.

Cayman or Luxembourg?+

Luxembourg wins on one point: a RAIF needs no CSSF product approval at all, whereas each Cayman mutual or private fund goes through CIMA. The RAIF must reach EUR 1,250,000 within 24 months, while a Cayman private fund has no minimum investment. Investor expectations usually settle it.

Why Prifinance for a Cayman Islands fund?+

We fix the statute and fund type with you, form the vehicle at the General Registry, line up the auditor, administrator and AML officers, and file with CIMA through REEFS. The work runs from our George Town office and carries on into the annual cycle.

Mutual fund?+

Open-ended, five types, CIMA.

Private fund?+

Closed-ended, 21-day filing.

Vehicle?+

Company, SPC, partnership, LLC or unit trust.

How long?+

About five business days at CIMA.

Cost?+

CI$4,125 to apply and a year.

Manager licence?+

If formed or based in Cayman.

Audit?+

Yearly, CIMA-approved auditor.

Economic substance?+

Fund excluded, manager in scope.

Or Luxembourg?+

RAIF: no product approval.

Why you?+

Statute, vehicle and CIMA file.

Client notes
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Cayman Islands Monetary Authority (CIMA) or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.