Cyprus Law 110(I)/2025 for Trapped Purchasers: Practical Analysis

Cyprus Law 110(I)/2025 reopened a route for certain buyers whose properties could not be transferred because the seller’s title was burdened by an earlier mortgage, memo or other prohibition.

It is not a general amnesty for every missing title deed. It does not cure planning breaches, make an unissued title appear, cancel every creditor right or guarantee a transfer. The dates, title status, payment history, registered burdens and procedural deadlines decide whether the route is available.

Why the law changed

The 2025 amendment followed the Supreme Court judgment of 20 June 2024 in Civil Appeal No. 285/2018, which disrupted the earlier trapped-purchaser mechanism. Law 110(I)/2025 was published in the Official Gazette on 4 July 2025 and rebuilt the statutory route with new conditions intended to balance the buyer’s position against the property and contractual rights of sellers and secured creditors.

The contract dates come first

The current Part VIB procedure applies only where the property is affected by a sale contract that falls within one of two historic categories:

• The contract was concluded and deposited at the competent District Lands Office by 31 December 2014.

• The contract was concluded by 31 December 2014 and later deposited under a court order made on an application filed at the competent District Court by 31 December 2024.

Those dates are easy to misstate. The second limb does not move the contract date to 2024. The contract still had to be concluded by 31 December 2014. The later date concerns the court application used to obtain late deposit.

This trapped-purchaser regime should therefore be kept separate from the modern Specific Performance Law requirements that apply to current sale contracts.

New applications and pending applications are not treated in the same way

For the standard route, a registered title deed must exist for the property covered by the contract. Full payment and any required creditor consent or court order are also examined.

Applications already submitted before Law 110(I)/2025 came into force have a separate transitional route. The Director may continue examining a pending application where issuing the title is feasible and the title is issued within the statutory period of two years and eight months from the commencement of the amending law, following the Director’s notice.

The transitional provisions also require specified technical evidence within eight months of the Director’s notice. Depending on the development, that may include the relevant building-permit certificate or evidence that completion of land-division works has been notified. If the documents are not produced, or title issuance is not feasible within the permitted period, the application may be rejected.

Payment is not a footnote

Full payment of the purchase price is one of the conditions examined. Where a balance remains, the Director may serve a written notice requiring payment into the special temporary account within 60 days. Failure to pay within that period can lead to rejection.

The Director may also require other evidence from an interested person within 60 days. Receipts, bank records, developer statements, contract amendments and correspondence should be organised before a notice arrives, not after the deadline has started.

Earlier mortgages, memos and prohibitions

Where a registered mortgage, memo or prohibition predates deposit of the sale contract, the current law requires written consent from the person in whose favour it operates for its release, deletion or cancellation in relation to the property.

If consent is refused, the buyer is not automatically entitled to bypass the creditor. Where the purchase price has been paid in full, an application may be made to the District Court for an order that the refusal is abusive and unjustified. The court application must be filed within 45 days from the refusal.

A copy of that court application should be deposited at the District Lands Office. Where the statutory conditions are met, pending enforcement or other proceedings are suspended until the court order is issued, and the deposit operates as a prohibition against disposal of the property while the application is pending.

What the law does not do

• It does not apply to every contract or every buyer waiting for title deeds.

• It does not remove the requirement to prove the contract and its deposit history.

• It does not treat a missing separate title as irrelevant.

• It does not ignore unpaid purchase money or missing evidence.

• It does not cancel an earlier creditor’s right without written consent or the specified court order.

• It does not guarantee that planning, building or division problems can be resolved.

• It does not replace an individual Land Registry, contract and litigation review.

A practical file review

Before giving an opinion, we normally need the complete history, not only the sale contract. The useful starting documents are:

• The original sale contract and every amendment.

• Evidence of the date and manner of deposit at the District Lands Office.

• Any court order for late deposit and the date of the court application.

• A current Land Registry search and available title-deed information.

• Receipts, bank transfers and a statement showing whether the price is fully paid.

• Details of every mortgage, memo, prohibition or other burden registered before the contract.

• Any written request for creditor consent and the creditor’s response or refusal.

• Planning, building, division and completion documents.

• Any existing trapped-purchaser application, Land Registry notice, rejection or pending court proceeding.

The wider title and conveyancing position should be reviewed with our Cyprus property-law service. Where a creditor has refused consent or court relief is being considered, the matter also needs a litigation and dispute-resolution review.

Frequently asked questions

Does Law 110(I)/2025 apply to every buyer without title deeds?

No. The statutory route is tied to specific historic contract and deposit dates, title-deed conditions, payment, registered burdens and procedural requirements. A buyer may have a genuine title problem and still fall outside this particular mechanism.

Which contract date matters?

The contract must have been concluded by 31 December 2014. It must either have been deposited by that date or have been deposited later under a court order based on an application filed by 31 December 2024.

Is a separate title deed required?

For the standard route, yes. Pending applications submitted before the 2025 amendment have a limited transitional process where title issuance is feasible within the statutory period and the required technical evidence is supplied.

What happens if an earlier mortgagee or creditor refuses consent?

If the price is fully paid, the buyer may seek a District Court order that the refusal is abusive and unjustified. The court application must be filed within 45 days from the refusal, so the refusal date and evidence of it matter.

Can an unpaid balance be paid later?

The law permits the Director to require payment of the balance into a special temporary account within 60 days of notice. Missing that deadline can result in rejection.

Does filing an application guarantee transfer?

No. The Director examines the statutory conditions and can reject the application where they are not satisfied within the prescribed periods. A court order may also be required where prior-charge consent is refused.

Official sources

• Consolidated Transfer and Mortgage of Immovable Property Law, including sections 44IH to 44KA

• Department of Lands and Surveys announcement on the 2025 trapped-purchaser amendment

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Ask us to review a trapped-purchaser or title-deed file | law@papacleovoulou.com | +357 26 933218

General information only. Last reviewed 1 August 2026. Eligibility under Law 110(I)/2025 depends on the original contract, deposit dates, title status, payment evidence, registered burdens, notices and any pending Land Registry or court process.