The Business Registers Agency (APR) announced on 25 September 2026 that the obligation for annual verification of beneficial owner (stvarni vlasnik) data in the Central Register of Beneficial Owners enters into force on 1 October 2026, pursuant to the Law on Prevention of Money Laundering and Terrorism Financing (Article 22a) and the Rulebook on the Central Register of Beneficial Owners. All legal entities registered in Serbia (companies, entrepreneurs, associations, foundations) must verify and, if necessary, update their beneficial ownership information at least once per calendar year. The first verification must be completed by 31 December 2026. The process is conducted electronically via the APR’s e-Register portal using a qualified electronic certificate. Entities must confirm the accuracy of existing data or submit changes (new beneficial owners, changed ownership percentages, updated personal details). Failure to perform the annual verification by the deadline results in a fine of RSD 100,000 to 2,000,000 for the legal entity and RSD 50,000 to 500,000 for the responsible person. Additionally, non-compliant entities will be flagged in the public register, potentially affecting banking relationships, public procurement eligibility, and tax incentive claims.
Key Takeaways
- Mandatory Annual Verification by 31 December Each Year: Starting 1 October 2026, all entities must complete their first annual verification by 31 December 2026. Subsequent verifications are due by 31 December of each following year. The verification is a simple electronic confirmation if no changes occurred.
- Penalties and Business Consequences for Non-Compliance: Fines up to RSD 2 million for entities and RSD 500,000 for responsible persons. Non-verified entities face public flagging, which triggers enhanced due diligence by banks and may disqualify them from public tenders and tax incentives.
- Integration with AML Obligations for Financial Institutions: Banks and obliged entities will rely on the verified register for customer due diligence. Discrepancies between the register and customer declarations will trigger suspicious transaction reports. Entities should align internal UBO records with the APR register before the deadline.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement