What the 2025 law does, what it does not, and what buyers need to know

By Eleni Philippou

I have been practising property law in Cyprus, and in Paphos in particular, for more than twenty years, and the most persistent problem I have dealt with in that time is the trapped buyer: the client who paid in full for a home, sometimes a decade ago, and still cannot get a title deed into their name. Last summer the House of Representatives passed Law 110(I)/2025, which sets out a new framework for resolving these cases. It is a real step forward, but some of the optimism around it outruns what the law can deliver.

How we got here

The crisis dates to the property boom of the early 2000s, when thousands of buyers, many of them foreign nationals buying holiday or retirement homes, paid developers in full for off-plan properties without knowing that the developer had mortgaged the underlying land. The bank’s charge sat over the whole plot, and the buyer, who owed the bank nothing, was caught between a developer who had taken the money and a lender with a valid security interest.

Cyprus first tried to fix this in 2015, with Law 139(I)/2015, the Trapped Buyers Law. Where the price had been paid and the contract deposited, a buyer could apply to the Land Registry to have the title transferred and the developer’s encumbrances lifted. It was crude, but it worked: more than 11,000 deeds were issued. Then, on 20 June 2024, in Civil Appeal 285/2018, the Court of Appeal held the central provisions unconstitutional, contrary to Articles 23 and 26 of the Constitution, because they stripped secured creditors of their rights without consent. Applications froze overnight, and some 9,497 buyers, most of whom had already waited years, were told to wait again.

What the new law says

Law 110(I)/2025 amends the Immovable Property (Transfer and Mortgage) Law of 1965 and is designed, with more care than its predecessor, to survive constitutional challenge. It reaches cases where the sale contract was deposited with the Land Registry by 31 December 2014, or where a court application to lodge it was filed by 31 December 2024. Contracts outside those dates are not covered. For cases that qualify, what happens next depends on what is blocking the deed.

Where a title deed exists and the land carries no mortgage, and the only problem is that the developer cannot complete the transfer, often because it has collapsed into insolvency or disappeared, the law works well. There is no creditor to satisfy, and the Land Registry can simply transfer the deed. These cases should move quickest.

Where a deed exists but the property is mortgaged, the lender, usually a bank, must consent in writing to releasing it, and that consent rarely comes for nothing: the bank will normally want a payment from each buyer towards the developer’s debt to release the unit. Where the bank refuses, and the buyer 2

has paid in full, the buyer may apply to the court within 45 days for an order declaring the refusal abusive and unjustified. The order does not strip out the mortgage; it stands in place of the bank’s consent so the Land Registry can proceed, and once a copy is lodged with the Registry, other proceedings, including foreclosure, are suspended until the court rules. But the law does not define “abusive” or “unjustified”, no court has yet ruled on the point, and the banks argue the override is itself unconstitutional, the very objection that brought down the 2015 law. For now it is a route to prepare for, not to rely on.

Where no title deed has been issued at all, expectations and reality part ways. Many buyers assumed the Director of the Land Registry would simply issue a deed and hand it over. It does not work that way: the application can transfer a deed that exists, but it cannot create one. Getting a deed issued is a separate process that often stalls on missing construction permits, illegal structures, or planning violations that cannot be regularised. Where it is feasible, the buyer has eight months to file the technical documents, and the deed must issue within two years and eight months of the law, by around March 2028; otherwise the application can be rejected.

Who it helps, and who it does not

The numbers temper the optimism. Of the 9,497 frozen applications, the Interior Minister has said 5,417 have no title deed at all and will stay pending until it is known whether one can be issued. Of the remaining 4,080, around 2,500 are unencumbered and should be processed in the normal course, leaving roughly 1,580 that turn on bank consent or a trip to court. And these are only the cases already in the system: a further 15,000 or so buyers, hit by serious planning violations, are not addressed by the law at all and will need a separate solution or a planning amnesty.

The obstacles nobody warns you about

Even within the framework, the process is rarely linear. The Land Registry will want a clearance certificate from the local authority confirming that all charges are settled, yet those charges are usually the developer’s, and the council will not issue the certificate until they are paid. The architects and engineers whose sign-off is needed to complete the permits are often owed fees by the same absent developer, and will not sign until paid. There may be unfinished works the developer never completed. In each case the buyer has no legal duty to pay, but in practice the money comes from them, because there is no one else. And because these are almost always shared developments, the buyers who want to act are held up by neighbours who cannot or will not, and the law cannot compel an unwilling co-owner to join in.

The deadlines are short

If your application was frozen in 2024, it should now be reactivated, but you must make sure it is moving and be ready when the Registry writes to you. The 45-day window to challenge a bank’s refusal is tighter than it sounds once you have to instruct a lawyer and issue proceedings, and the long-stop for a deed to be issued is early March 2028. The time to take advice is now, not when a letter lands asking for documents you do not have. 3

A note for new buyers

This law is for the backlog, not for anyone buying today. If you are buying now, the lesson of the whole saga is prevention. Insist on a Land Registry search certificate before you sign; the law now requires one, no more than five working days old, with every contract. Check whether the property has its own separate title deed, and if not, ask why. Above all, instruct your own independent lawyer, paid by you and answerable to you, not the one the developer recommends.

The trapped buyer crisis is not really about Cyprus being a bad place to buy. Time and again it comes down to buyers signing without independent legal advice, by which point the contract is signed, the money is paid, and the options have narrowed to almost nothing. The new law rests on firmer constitutional ground than the last, and I expect it to last longer. For clean cases it offers real tools; for the tangled ones it offers a framework, but not, on its own, a solution. For most people, by the time they realise they need a lawyer, the moment to instruct one has already passed.

This article provides general information only and does not constitute legal advice.

Eleni Philippou, LLB, LLM, TEP, Advocate, Senior Partner, Philippou Law Firm, www.philippoulaw.com