Legal News · Commercial Law
From 1 October 2026, companies must annually confirm data on beneficial owners with the Business Registers Agency. The deadline is not the same for everyone, and failure to comply can cost up to 2,000,000 dinars.
Sole proprietors are not subject to the registration of beneficial owners within the meaning of the law on the Central Register of Beneficial Owners.
From 1st October 2026, companies, cooperatives, associations, foundations, institutions and other registered entities are required to check and confirm the accuracy of data on their beneficial owners once a year in the Central Register of Beneficial Owners, which is maintained by Serbian Business Registration Agency (APR).
The obligation arises from Article 9 of the Law on the Central Register of Beneficial Owners (Official Gazette of the RS, Nos. 19/2025, 51/2025 and 60/2025 - corr.). Recording the beneficial owner is no longer a one-off task: data must be checked and confirmed every year.
The deadline is not the same for everyone. You must verify the data within one year from the date of the last recording of the beneficial owner's data, i.e. from the last confirmation of their accuracy. After that, you have another 30 days to confirm the data in the Central Register.
For entities that complied with the new law between 1 October and 1 December 2025, uploading documentation during that period is considered the first verification, so the deadline is calculated from that date.
The company uploaded the documentation on the beneficial owner on 20 October 2025. It must carry out the verification by 20 October 2026, and the confirmation within the next 30 days. If there has been a change in the beneficial owner in the meantime, the new one-year time limit runs from the date of registration of that change.
The obligation applies to business companies (except public joint-stock companies), cooperatives, foundations, endowments, institutions, associations, as well as branches and representative offices of foreign companies. The confirmation is mandatory even when there have been no changes, and even if the same person has been the sole owner of the company for years.
Entrepreneurs, including flat-rate taxpayers, do not have this obligation, as they operate as natural persons and are not registered entities within the meaning of this law.
Confirmation is made by the legal representative, or a person authorised by them, electronically via the APR portal. This requires:
If there has been a change in the beneficial owner or the documentation proving that status, the changes must first be recorded and the relevant documents uploaded, and then the data is confirmed with an electronic signature.
The law provides for misdemeanor liability for both the legal entity and the director for failing to submit the confirmation within the prescribed period:
| Liable party | Fine |
|---|---|
| Legal entity | 500,000 – 2,000,000 dinars |
| Responsible person in the legal entity | 50,000 – 150,000 dinars |
For the intentional concealment of the beneficial owner, the law also provides for criminal liability, with a prison sentence of six months to five years.
If you are unsure when your deadline is or whether your beneficial ownership documentation is complete, the PM Lawyers office can check your data in the Central Register and help you make the submission on time. Read more about our services on the page Corporate law.
From 1 October 2026, pursuant to Article 9 of the Law on the Central Register of Beneficial Owners. For most companies, this is the first annual confirmation following compliance with the new law in 2025.
No. The deadline expires one year from the last registration or the last confirmation of beneficial owner data, and after that there is another 30 days for confirmation in the Central Register.
Yes. Confirmation is mandatory even when there have been no changes, even if the same person has been the sole owner of the company for years.
No. Entrepreneurs, including flat-rate taxpayers, are not registered entities within the meaning of this law and have no obligation to provide an annual confirmation.
From 500,000 to 2,000,000 dinars for a legal entity and from 50,000 to 150,000 dinars for the responsible person within the legal entity.
We will check your company's beneficial ownership data in the Central Register and help you make the confirmation on time.
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