Registering a new private fund with CIMA is a significant milestone — but the compliance obligations start immediately. One of the questions that catches newly registered fund operators most off guard is: when is the first FAR due, and what exactly must be filed?
The answer depends on several factors, including when the fund was registered, when it first drew capital, and whether it has reached its first financial year-end. This guide walks through each scenario clearly.
The Basic Rule: Six Months After the First Financial Year-End
Every private fund registered with CIMA must file an FAR (or a Declaration, if no capital has been drawn) within six months of the end of each financial year. For funds with a 31 December year-end, this means 30 June.
This obligation applies from the first financial year-end following registration — not from some later date when the fund becomes "fully operational." If your fund registered with CIMA on 1 November 2024, its first financial year-end is 31 December 2024, and its first filing obligation falls on 30 June 2025.
Scenario 1: Fund Registered but No Capital Drawn by the First Year-End
This is the most common scenario for newly registered PE and VC funds. The fund has been registered with CIMA, may have received capital commitments, but has not yet drawn capital for the purposes of investment by the time the first December year-end passes.
In this case:
- No audited financial statements are required for that year
- No full FAR is required for that year
- A Declaration of no capital contributions is required, submitted via REEFS within six months of the year-end
The Declaration is a brief formal filing confirming that no capital has been drawn. It must be submitted by the designated submitter (auditor or other local service provider) through REEFS by June 30. Failing to file the Declaration is a breach with the same regulatory consequences as failing to file a full FAR.
Scenario 2: Fund Registered and Capital Drawn in the First Year
If the fund draws capital for investment during its first financial year, it must file audited financial statements and a full FAR for that year.
Here, the 18-month first audit period rule is important. A private fund's first audit period can cover up to 18 months from the commencement of operations (the date of first capital drawdown). This means a fund that first drew capital in, say, July 2024 does not necessarily need to produce audited accounts for just the 5-month period ending December 2024. Under the regulations, the first audit period can extend through to January 2026 (18 months from July 2024), allowing the fund to produce its first set of audited accounts for a longer, more meaningful period. Funds should confirm the applicable period with their auditor and service provider early in the process.
Scenario 3: Fund Registered Late in the Year
A fund registered in November or December and reaching its first year-end within weeks of registration faces an immediate question: does it need to file anything by June 30?
Yes — if the year-end has passed, the obligation has been triggered. The relevant question is whether capital was drawn before that year-end. If not, a Declaration is due. If capital was drawn (rare but possible for rapidly deploying funds), audited accounts and a full FAR are due.
For very short first periods (e.g. a fund registered on 15 December with a 31 December year-end), CIMA applies practical judgment. Operators should discuss the specific circumstances with their local service provider and potentially seek a waiver of the audit requirement from CIMA for an unusually short stub period.
The First FAR Form: What's Different
The first FAR a fund submits is, in some respects, more complex than subsequent years. In particular:
Service provider information. The FAR requires details of all service providers — auditor, administrator, legal counsel, custodian, investment manager. For a new fund, some of these may not yet be fully onboarded, or may have changed since registration. All information must reflect the position as at the date the FAR is completed.
Investor data. The FAR requires information about the fund's investor base, including types of investors and their jurisdictions. For a first-year fund with only a partial close, this data may look quite different from later years.
Related Fund Entity section. Even in year one, the fund must disclose any AIVs, parallel funds, or other related entities. For newly launched funds, this may be limited — but it should not be left blank without confirming that no such entities exist.
Financial data. If audited accounts are required, the financial section of the FAR must correspond exactly to those accounts. Discrepancies between the FAR figures and the audited financial statements are a common source of first-year rejections.
Setting Up for Success in Year One
The single most important thing a newly registered fund can do to ensure a smooth first FAR season is to engage its service providers early — ideally before the fund's first financial year-end passes. The auditor, administrator, and registered office should all be clear on what the first-year filing obligations are, what the relevant deadlines are, and who is responsible for each component of the FAR.
The second most important thing is to validate the FAR form before it reaches REEFS. First-year FAR submissions have a higher error rate than subsequent years, precisely because the team is unfamiliar with the form, the data is being gathered for the first time, and there is no prior-year return to roll forward from.
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All blog posts are for informational purposes only and do not constitute legal, regulatory, or compliance advice. Fund operators should always confirm current requirements with CIMA or their legal and regulatory advisors.