One Cyprus Licence, 27 EU Markets: What Your Insurance Brokerage Actually Needs

(real client enquiry)

Dear CYAUSE,

Thank you for the prompt proposal. Before we take this to our board, we have questions on the costing you set out:

• Incorporation of an insurance brokers/agents company — €1,500 + VAT + disbursements.
• Issuance of an insurance brokers/agents licence including passporting — €4,200 + VAT + disbursements (from €5,000 + VAT).

1. What specific disbursements are you referring to in items 1 and 2?
2. Should we understand that the €5,000 + VAT covers those disbursements?
3. Regarding the local director who does not personally hold a licence, must they work physically at the office location?

Kind regards,

Dear Client,

Taking your questions in order.

1. What the disbursements actually are

Disbursements are fees paid to the local authorities on your behalf — they are not our fees, and we pass them through at cost. For the company formation they range from €450 to €800, depending on what you need: an expedited process costs more, as does issuing certificates in both Greek and English.

There is a separate item worth flagging now rather than later. Amendments to the articles of association, if your structure requires them, are charged separately and depend on the volume of changes — typically €1,000 to €2,500 + VAT, because one of our lawyers drafts them to fit your specific arrangements and files them with the Registrar for approval.

Our practical advice: do not do this at incorporation. Standard articles will carry you through the licensing stage perfectly well. Amend them once the company has earned some traction and you know what the business actually needs. It is ultimately a management decision, but we see clients spend on bespoke articles at month one and rewrite them at month eighteen.

2. Does the €5,000 + VAT cover the disbursements?

More or less, yes. That figure was framed to give you a realistic all-in expectation for the licensing stage rather than a headline number that grows later. We would rather quote you a range you can budget against than a low figure that needs revisiting.

3. Must the local director be physically at the office?

No. The local director is a statutory requirement, not a physical attendance one. The role exists so that the company has proper local governance and someone answerable under Cyprus law — it does not oblige that person to sit at a desk in the office.

That said, do not confuse this with substance. The director requirement and the company’s substance position are two different tests, and satisfying the first does not satisfy the second.

Kind regards,

Dear CYAUSE,

Following up after reviewing the proposal in detail, two further questions have arisen:

1. If our CEO and Vice President assume the roles of directors of the Cyprus entity and hold their respective licences, is it still mandatory to hire another employee who holds a licence? Or would it be sufficient to hire a local representative in a lower-level position?
2. Regarding the fixed office cost, is there room to negotiate this expense based on our operational scale? If so, what is the minimum estimated amount required to comply with physical presence (substance) requirements?

It is worth noting that the company will not commercialise insurance products within Cyprus.

Kind regards,

Dear Client,

Both questions go to the heart of what a licence application actually turns on, so they are worth answering carefully.

1. Can your own directors’ licences carry the application?

Yes — this can be accepted, provided the CEO and/or Vice President hold accredited, recognised credentials, and those credentials are validated by the Cyprus Superintendent of Insurance.

The word doing the work in that sentence is recognised. A qualification that is respected in your home market is not automatically recognised in Cyprus. The Superintendent assesses the professional competence of the people who will actually direct the business, and a foreign licence is evaluated on its substance, not its title. In practice this is the single most common point on which applications stall, and it is worth resolving before you incur incorporation costs rather than after.

If the credentials are validated, you would not additionally need to employ a separately licensed individual. If they are not, a licensed person becomes necessary, and a local representative in a junior position would not fill that gap — the requirement attaches to professional competence at the level that directs the business.

Our recommendation is to submit the CEO’s and Vice President’s qualifications for assessment as an early step. It costs little and it determines your staffing model.

2. The office cost and what substance really means

There is some room to scale the office arrangement to your operations. €300 + VAT per month is the absolute minimum that makes sense to us — below that, we would not be comfortable that the arrangement stands up.

We would put the emphasis differently from most providers, though. The question is not how little you can spend; it is whether the arrangement is defensible if examined. An address that exists only on paper creates exposure disproportionate to the money it saves — both with the regulator at licensing stage and with the tax authorities afterwards on management and control.

Your point that the company will not commercialise insurance products within Cyprus is well made, and it is exactly the model the regime is designed for. It does not, however, reduce the substance requirement. The company is Cyprus-licensed and Cyprus-resident; where it sells is a separate matter from where it is genuinely managed.

Why this route is worth the effort

Cyprus is very popular for EU passporting, and we act for many clients who have established a local agency to distribute their products and services across different EU countries. One licence, obtained once, opens distribution across the Union rather than requiring a separate authorisation in each market. For a group entering Europe from outside it, that is usually the decisive economics.

For the wider requirements — qualifications, documentation and indicative timelines — our detailed guide is here: Cyprus Insurance Brokers’ Licence — Useful Information and Requirements for EU Passporting.

Kind regards,

Summary of indicative costs

Indicative only, for one specific set of facts. Disbursements are statutory fees paid to the authorities and passed through at cost.

This enquiry has been anonymised. All names, company details and contact information have been removed with the client’s interests in mind.

This article is provided for general information only. It does not constitute investment, tax, legal, regulatory or audit advice, and the fees quoted are indicative figures given for one specific set of facts — they are not an offer and will differ for your business. Licensing outcomes depend on the assessment of the Superintendent of Insurance on the facts of each application. Interested parties should enquire with us at enquiries@cyprusaccountants.com.cy or on +357 22 336 309 for advice based on their own circumstances.