Information Required of Brokers and Dealers (Form X-17A-5)

Report for the Period Beginning	01-01-2025
and Ending	12-31-2025
Type of Registrant	Broker-dealer

Material Weakness
Does this submission include an accountant's report covering the compliance report that indentifies one or more material weaknesses?	Yes No

Name of Broker-dealer

Nearwater Capital Markets, Ltd

Address of Principal Place of Business (Do not use P.O. Box No.)

Address 1	FLEMING COURT, FLEMING'S PLACE
Address 2	3RD FLOOR
City	DUBLIN 4, DUBLIN
State/Country	IRELAND
Mailing Zip/ Portal Code	00000

Name and Telephone Number of Person to Contact in Regard to this Report

Name	Robert Pascuzzi
Telephone Number	2127749023

Independent Public Accountant

Name - if individual, state last, first, and middle name	KPMG LLP
Address 1	Two Manhattan West
Address 2	375 9th Avenue, 17th Floor
City	New York
State/Country	NEW YORK
Mailing Zip/ Postal Code	10001
Check One	Certified Public Accountant Certified Public Accountant not resident in United States or any of its possessions

Oath or Affirmation

I, Robert Pascuzzi, swear (or affirm) that, to the best of my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of Nearwater Capital Markets, Ltd, as of 12-31-2025, are true and correct. I further swear (or affirm) that neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account classified solely as that of a customer, except as follows:

Signature	Robert Pascuzzi
Title	Chief Financial Officer

Notary Public

Checking this box acknowledges that this oath or affirmation has been notarized.