In brief: Cyprus is preparing a reform of the outdated Cap.109 law on property acquisitions by foreigners from outside the EU. Current rules impose limits and require government approval, yet due to loopholes, transactions often proceed with minimal oversight. Authorities are not happy with this — in August the Ministry of the Interior confirmed that a new regime is being drafted.
As the bill is still in progress, non-EU buyers need to understand what rules apply today and which changes are under discussion.
What Applies Now (Cap.109)
Permit requirement. An acquisition permit (commonly called an Aliens’ Permit) is required. It is issued by the district administration on behalf of the Council of Ministers, based on a set of documents submitted after the signing of the contract.
Limits on property:
- A plot of land up to 4,000 m² for building a single residence (for own use);
- Up to two “units” of property: either two residential properties, or one residence plus a shop of up to 100 m², or one residence plus an office of up to 250 m². The restriction applies jointly to spouses (the permit is issued in both names).
Application procedure and timing. The purchase contract is registered with the Department of Lands and Surveys; the application for the permit is submitted to the relevant district office. Actual processing times vary: typically one to two months, but longer in Paphos.
The Problem of ‘Minimal Oversight’
In August 2025, the Ministry of the Interior confirmed in response to a parliamentary query that transfer and assignment documents are accepted by the land registrar even without a prior permit. The permit itself is only required at the stage of final Title transfer into the buyer’s name.
In practice, this neutralises the intended restrictions of Cap.109 and allows foreigners to accumulate multiple properties through transfers and assignments.
The scale is significant: as of early July, 53,076 properties had already been transferred to non-EU nationals this year alone, with Paphos leading the figures.
What Is Planned
The government has announced a complete replacement of the porous Cap.109 law. Parallel parliamentary initiatives are also proposing stricter rules. Among the ideas currently on the table:
- Strict ‘pre-permit’ model: a ban on registering any documents (including assignments) before the acquisition permit is granted — closing the present loophole.
- Tighter “one unit” limits: proposals to restrict purchases to a single apartment or house of around 200 m² for non-EU individuals and companies under their control. These figures are still indicative; final thresholds may differ.
- Filter for Cypriot companies with foreign beneficiaries: expanding compliance and transparency requirements to prevent circumvention of limits via local corporate structures.
Status as of today: the Ministry of the Interior and the Legal Service are still working on the draft; no new law has yet been adopted.
What This Means for Non-EU Buyers Right Now
- Plan your transaction within current limits (one property or one plot, or the permitted combinations). Ensure your contract specifies the requirement for the permit and the consequences of refusal.
- Do not rely on assignments as a loophole. Although registrars currently accept them, this does not make such purchases risk-free. The new law will almost certainly require permits before any registration.
- Review your ownership structure. Buying through a Cypriot company has historically allowed buyers to bypass limits, but this is precisely the practice under review. Conduct full due diligence on beneficiary transparency and AML risks.
- Build in time buffers. In some districts the issuance of permits is slower than average — factor this into your completion timetable.
Conclusion
For non-EU nationals, Cyprus continues to operate under a permit-based regime with quantitative and size restrictions. The real uncertainty is when and in what form the new law will come into force.
A properly drafted contract, early application for the permit, a clean ownership structure and close monitoring of parliamentary developments are the best safeguards for your purchase today — and protection against potential risks tomorrow.
This article will be updated as soon as the final text of the draft law is published.
