Cayman Islands PPoC Extension
- Elizabeth A. McMorrow
- 5 days ago
- 2 min read
The Cayman Islands announced an extension to the new requirement that the Principal Point of Contact (PPoC) be a resident in the Cayman Islands.
FI Registration Deadline
For entities created in 2025, the Cayman Islands requires that reporting and non-reporting Financial Institutions (FIs) submit a “Notification” by registering in the Cayman Islands DITC Portal by April 30, 2026. Registration is required under both the U.S.-Cayman Islands FATCA IGA and the Common Reporting Standard (CRS).
PPoC Extension
As part of the online Cayman Islands Notification process, it is necessary to appoint an Authorizing Person and Principal Point of Contact (PPoC) for each FI. The PPoC may be a named employee/fiduciary of the FI or an employee/fiduciary of a third-party service provider. Prior to the new regulations, the PPoC could be an individual who is resident outside of the Cayman Islands. Under the new regulations, an FI must name a PPoC who is resident in the Cayman Islands.
Initially, FIs formed in 2025 but registered in the DITC portal January 1, 2026, or later were required to name a PPoC who is resident in the Cayman Islands but FIs formed in 2025 that were already registered in the DITC portal by December 31, 2025, were not required to name a resident Cayman Islands PPoC until January 31, 2027.
The newly announced extension permits all FIs formed in 2025, regardless of whether they were registered in the DITC portal during 2025 or by April 30, 2026, to delay naming a PPoC who meets the Cayman Islands residency requirement until January 31, 2027.
Residency Requirement
The PPoC can satisfy the residency requirement as follows:
“Natural person: has a physical address in the Cayman Islands.
Legal person: (i) incorporated, registered, or established in the Cayman Islands; and (ii) maintains a physical address in the Cayman Islands (not solely a mailing or correspondence address).”
Click to read the January 21, 2026 Ministry of Financial Services & Commerce Industry Advisory.
For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.