The Cyprus Acquisition Permit for Non-EU Buyers: Cap. 109 Explained
Reviewed by Eleni Philippou · Advocate · Cyprus Bar Association · LL.M. (Distinction)Last updated: July 4, 2026
Non-EU (“third-country”) nationals need an acquisition permit under the Immovable Property Acquisition (Aliens) Law, Cap. 109, before property can be registered in their name. The application is made on Form Comm. 145 to the District Administration — which decides under powers delegated by the Council of Ministers since 1999 — carries no government fee, and is routinely granted. You can sign, pay and take possession before it is issued.
Key takeaways
- Non-EU buyers need permission under Cap. 109 before title can be registered; EU/EEA citizens are exempt.
- It is applied for on Form Comm. 145 at the District Administration, which decides under powers delegated by the Council of Ministers since 1999.
- There is no government fee, and refusals for genuine home purchases are rare.
- You can sign the contract, pay, deposit it and take possession before the permit — it only gates the transfer of title.
- Current limits are broadly up to two units, or land up to ~4,000 m² for one owner-occupied home, assessed per family.
- A draft 2026 reform would tighten this (one home, zone bans, 51% EU-ownership for companies) — proposed, not yet law.
Do non-EU buyers need permission to buy property in Cyprus?
Yes. Under the Immovable Property Acquisition (Aliens) Law, Cap. 109, any “alien” — in practice a national of a country outside the EU, or a company controlled by non-EU nationals — must obtain official permission before immovable property in Cyprus can be registered in their name. EU and EEA citizens are exempt and buy on the same footing as Cypriots.
The permission is commonly called “Council of Ministers approval.” For a genuine buyer of a home or holiday property it is widely regarded as a formality — but it is a legal requirement, not a rubber stamp, and title cannot pass to you without it.
Who grants the permit — the Council of Ministers or the District Officer?
The law vests the power in the Council of Ministers, which is why the approval carries that name. In practice, however, the Council delegated its decision-making to the District Officers back in 1999.
So your application is examined and decided at the District Administration office of the district where the property is located — Limassol, Paphos, Larnaca, Nicosia or Famagusta — not by ministers in cabinet. Many older guides still say “Council of Ministers” decides; the modern reality is the District Officer.
A modern-practice point
Because the decision is delegated to District Officers, timelines and handling vary by district. The permit is an administrative approval by the local District Administration under the Council of Ministers’ delegated authority — plan around the district, not around “the Cabinet.”
Can I sign the contract and pay before I have the permit?
Yes — and in fact you normally must, because the application requires a copy of your signed contract of sale. Signing, paying stage payments, depositing your contract at the Land Registry for specific-performance protection, and even taking possession are all lawful before the permit is issued.
The permission becomes essential only at the final step: registering the title deed in your name. This ordering surprises many buyers, but it means the permit rarely delays a purchase in practice — the application simply runs in parallel with the conveyance. Your contract deposit, not the permit, is what protects your money in the meantime.
The Form Comm. 145 application, step by step
The process is straightforward and is usually handled by your advocate under a power of attorney, so overseas buyers need not attend in person.
- 1Sign and protect. Sign the contract of sale and deposit it at the Land Registry within six months for specific performance.
- 2File Form Comm. 145. Your advocate files the form at the District Administration for the property’s district, with the supporting documents.
- 3Review. The District Office reviews the file and may verify details with other departments; a complete file avoids delay.
- 4Approval letter. If approved, you receive the acquisition permit — a letter of approval, often with standard conditions such as using the property as declared.
- 5Register title. The permit is presented at the Department of Lands and Surveys when the deed is transferred into your name.
What documents do I need for the acquisition permit?
The core bundle filed with Form Comm. 145 typically includes: a copy of the signed contract of sale; the property’s title deed or, where none yet exists, the planning permit and plans; floor and site plans; passport copies for you and your spouse; your marriage certificate (with a certified translation if not in Greek or English); and evidence of your financial standing, such as bank references.
Where the buyer is a company, the file adds the corporate certificates — shareholders, directors, registered office — and the memorandum and articles, so the District Office can confirm who ultimately controls it. Missing documents are the most common reason an otherwise routine application stalls, so prepare the file carefully.
How long does the permit take, and what does it cost?
There is no government fee for the application. Processing times vary by district and workload, with no binding service standard — treat the figures below as indicative rather than guaranteed.
| District | Typical processing |
|---|---|
| Limassol | ≈ 30–45 days |
| Larnaca / Nicosia / Famagusta | ≈ 1–2 months |
| Paphos | Up to several months |
| Government fee | None |
What are the ownership limits for a non-EU buyer?
Under current practice a permit is granted for a limited holding, assessed per family unit (spouses are treated together, so they cannot double the entitlement by applying separately).
| What you can acquire | Limit |
|---|---|
| Residential units | Up to two units (or one home plus a shop ≤100 m² / office ≤250 m²) |
| Building plot / land | Up to ~4,000 m² for one owner-occupied home |
| Assessed per | Family unit (spouses together) |
| Company route | A non-EU-controlled company is itself an “alien” and needs the permit |
Do UK citizens need the permit after Brexit?
Yes. Since the end of the Brexit transition period on 1 January 2021, UK nationals are third-country nationals for Cap. 109, exactly like American, Israeli, Chinese or Gulf buyers. A British buyer signs the contract, then applies on Form Comm. 145, and needs the permit before the deed can be registered.
The practical impact is modest — the permit is granted to good-faith UK buyers as a matter of routine and adds no government fee — but it is a step that did not exist for British buyers before Brexit, and it should be planned into the conveyance with legal advice.
Is the law changing? The proposed 2026 reform
A significant tightening is on the table, but at the time of writing it is proposed, not enacted. In February 2026 the Ministry of Interior advanced a draft framework to modernise Cap. 109, and parliamentary proposals were consolidated into a bill during 2026.
Any non-EU buyer should verify the current state of the law before committing — and note that reforms of this kind typically respect permits and contracts already in place, which is an argument for completing applications sooner rather than later.
What the draft would change (not yet law)
Limit non-EU nationals to one home or apartment.
Cap land and ban agricultural/forest land and property near military zones, ports, airports and the ceasefire line.
Require companies buying property to be at least 51% Cypriot/EU-owned, closing the corporate route.
Introduce a minimum holding period. Confirm the enacted position before relying on any of this.
Key facts
- Legal basis
- Immovable Property Acquisition (Aliens) Law, Cap. 109
- Who needs it
- Non-EU nationals and non-EU-controlled companies (EU/EEA exempt)
- Application
- Form Comm. 145, at the District Administration
- Who decides
- District Officer, under authority delegated by the Council of Ministers (1999)
- Fee / timing
- No fee; ~30–45 days Limassol, 1–2 months others, longer Paphos
- Current limits
- Up to 2 units, or land ~4,000 m² for one home (per family)
- 2026 reform
- Proposed (not law): one unit, zone bans, 51% EU-ownership for companies
Frequently asked questions
Do non-EU citizens need permission to buy property in Cyprus?
Yes. Under Cap. 109, non-EU nationals and non-EU-controlled companies need an acquisition permit before property can be registered in their name. EU and EEA citizens are exempt. The permit is routinely granted to genuine buyers, but it is a legal requirement, so title cannot pass without it.
Who actually grants the acquisition permit?
Although the power formally rests with the Council of Ministers, it was delegated to the District Officers in 1999. Your application is therefore decided at the District Administration office for the property’s district, not by ministers in cabinet — a point many older guides get wrong.
Can I sign and pay before the permit is granted?
Yes, and usually you must, because the application needs a copy of your signed contract. You can sign, pay stage payments, deposit the contract for specific performance and take possession while the permit is pending. It only gates the final transfer of title into your name.
How long does the Cyprus acquisition permit take?
There is no fixed period and no government fee. As reported in 2025, Limassol was deciding applications in roughly 30–45 days, Larnaca, Nicosia and Famagusta in one to two months, and Paphos could take several months. Because you can sign, pay and occupy beforehand, the wait rarely delays a purchase.
How much property can a non-EU buyer acquire in Cyprus?
Under current practice, broadly up to two residential units (or one home plus a small shop or office), or a building plot of about 4,000 m² for one owner-occupied home. Limits are assessed per family, so spouses are treated together. A non-EU-controlled company is itself an “alien” and needs the same permit.
Do UK citizens need the acquisition permit after Brexit?
Yes. Since 1 January 2021 UK nationals are third-country nationals under Cap. 109 and need the permit before title can be registered, unlike before Brexit when no permit was required. It is largely procedural and carries no fee, but it adds a stage that should be planned into the conveyance.
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General legal information, not legal advice, and no lawyer–client relationship is created. Figures are current to the date above and depend on your specific transaction. Speak to a qualified Cyprus advocate before acting.