Trapped Buyers in Cyprus: The 2025 Law

Paid in full, and still not the owner. The law finally has a route again

In short

The 2015 mechanism was held unconstitutional in June 2024 and applications froze.
Law 110(I)/2025 rebuilt it around the lender: consent first, and a court route when consent is refused.
The deadlines are strict, and some of them are already running.

A trapped buyer is someone who paid for a property in Cyprus, often in full, but never received the title deed, because the developer's own mortgage or other charges sat on the land before the buyer's contract was deposited. Part VIB of the Transfer and Mortgage of Immovable Property Law, Law 9/1965, added by Law 139(I)/2015, let the Land Registry transfer the title anyway.

On 20 June 2024, in Civil Appeal No. 285/2018, the Court of Appeal held the central provisions of that mechanism unconstitutional, contrary to Articles 23 and 26 of the Constitution, because they stripped secured creditors of their rights without consent. Thousands of pending applications froze. Law 110(I)/2025, published on 4 July 2025, is the answer: a rebuilt mechanism designed to survive that judgment.

Where to start

Send us the deposited contract, proof of what you have paid, and any letter in which a bank or other charge holder has refused consent. We reply within one business day with where your case stands under the new law.

Send us the papers

Who the new law reaches

Two cut-off dates decide whether you are in

Under the new section 44IH, the mechanism applies where the sale contract was deposited at the District Land Office under the Sale of Immovable Property (Specific Performance) Law by 31 December 2014, or was concluded by 31 December 2014 and deposited later under a court order, on an application filed at the District Court by 31 December 2024.

A separate title deed must have been issued for the property. Where no title exists, the law provides instead for a certificate from the competent authority under the Roads and Buildings Law that the issue of a title is not feasible, and those cases remain, in substance, outside the transfer mechanism: this is the hard edge of the reform, and it is where a large part of the frozen backlog sits.

The mechanism

Consent first, and a forty-five day court route when it is refused

Where charges or prohibitions were registered before your contract was deposited, the starting point is now the written consent of those who hold them, usually the developer's bank, to their release. That is what the Court of Appeal's judgment demanded: the secured creditor is no longer simply overridden.

Where consent is refused and the purchase price has been paid in full, the buyer may apply to court within forty-five days of the refusal for an order declaring the refusal abusive and unjustified. A copy of that order then stands in the place of the consent before the Land Registry. The law does not define abusive or unjustified; those words will be given their content case by case, which makes the quality of the application matter.

While the application is pending, and provided a copy is filed at the District Land Office, enforcement against the property, including under the Bankruptcy and Companies Laws, is suspended, and the filing acts as a prohibition on any disposal of the property. A buyer who has paid only part of the price keeps the same protection by undertaking in writing to pay the balance into the special account the law provides.

If you had already applied

The frozen applications restart, on a timetable

Applications filed before the new law took effect are examined again, provided a separate title can be issued for the property. The title must be issued within two years and eight months from the law's commencement, which runs to early March 2028, and after the Land Registry's notice the buyer has eight months to submit the documents the law lists, including the development's building permit certificate. Where the Registry finds that a title cannot be issued, it may reject the application.

The practical point: these are not deadlines to watch from a distance. The documents take time to assemble, some must come from the developer or the authorities, and a rejected application is a bad place to discover that a certificate was missing.

Common questions

Am I a trapped buyer in the legal sense?

If you bought Cyprus property, your contract was deposited at the Land Registry by 31 December 2014, or concluded by then and deposited under a court order applied for by 31 December 2024, and the title has never been transferred because of the seller's prior mortgage or other charges, you are within the scope of Part VIB of Law 9/1965 as rebuilt by Law 110(I)/2025. A separate title deed must exist for the property.

What happened in June 2024?

In Civil Appeal No. 285/2018, decided on 20 June 2024, the Court of Appeal held the central provisions of the 2015 trapped-buyers mechanism unconstitutional, contrary to Articles 23 and 26 of the Constitution, because they allowed the transfer of mortgaged property without the secured creditor's consent. Pending applications froze until the new law.

What does Law 110(I)/2025 change?

It rebuilds the mechanism around the lender's constitutional rights: prior charge holders must consent in writing to release, and where consent is refused and the price is fully paid, the buyer may apply to court within 45 days of the refusal for an order that the refusal is abusive and unjustified. That order substitutes for the consent. Enforcement against the property is suspended while the application is decided.

The bank refused consent. How long do I have?

Forty-five days from the refusal to file the court application. The period is short by design, and the application has to persuade the court that the refusal is abusive and unjustified, terms the law leaves undefined, so the evidence of full payment and of the refusal itself needs to be assembled before the letter arrives, not after.

I applied years ago and everything stopped. What now?

Pre-2025 applications are examined again, provided a separate title can be issued for the property within two years and eight months from the law's commencement, to early March 2028. After the Land Registry's notice you have eight months to submit the required documents. If a title cannot be issued, the application may be rejected, which is why the no-title cases need separate advice.

My building has no separate title deeds at all. Does the law help me?

Not directly. The transfer mechanism requires an issued title deed. Where the competent authority certifies that a title cannot be issued, the case falls outside the mechanism, and the realistic routes are contractual: specific performance where the deposited contract supports it, assignment, or a damages claim. Which of those is open depends on the papers, so send them to us.

Title Deed Problems in Cyprus

Guide

Specific Performance or Damages

Comparison

Buying Without a Title Deed

Article

The Property Practice

The firm

Every reference on this page was read in the text of Law 110(I)/2025 as published in the Official Gazette, and is recorded in the register of sources.

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