A new legal framework for the registration of beneficial owners has been established through the Law on the Central Register of Beneficial Owners and two new Rulebooks, which together create a comprehensive system for the identification and monitoring of beneficial ownership in Serbia. Legal term for harmonization is until November 30th, 2025.
Law on the Central Register of Beneficial Owners (“Official Gazette of the RS”, Nos. 19/2025, 51/2025 and 60/2025 – corr.)
- The obligation to register now extends to trusts and similar legal arrangements if they are managed from Serbia or conduct business in Serbia.
- Registered entities are required to verify and confirm the accuracy of beneficial ownership data at least once a year.
- The Business Registers Agency (APR) will maintain a public list of entities that fail to register beneficial owners or supporting documentation within the prescribed deadlines – such entities will automatically be classified as high-risk under anti–money laundering and counter–terrorism financing regulations.
- Sanctions include fines ranging from RSD 500,000.00 to 2,000,000.00 for legal entities, and RSD 50,000 to 150,000 for responsible persons. Intentional concealment of ownership may qualify as a criminal offence punishable by imprisonment of up to five years.
Rulebook on the Content of the Central Register of Beneficial Owners (“Official Gazette of the RS”, No. 83/2025)
- Introduces detailed categorization of beneficial owners through OSV and TR codes (e.g., OSV 1 for owners holding ≥25% of shares or voting rights, OSV 4 for trustees and trust beneficiaries, TR codes for founders, beneficiaries and protectors of trusts).
- Prescribes mandatory electronic submission of supporting documents, including founding acts, agreements, minutes of meetings, and personal identification documents of beneficial owners, all in PDF format.
- Provides for the recording of notations on discrepancies between registered data and data obtained pursuant to anti–money laundering regulations.
Rulebook on the Manner and Conditions of Electronic Data Exchange between the Business Registers Agency and the Competent State Authority for the Purpose of Beneficial Ownership Registration (“Official Gazette of the RS”, No. 83/2025)
- Regulates the technical aspects of the system, i.e. electronic data exchange between APR and other competent state authorities.
- Data exchange is carried out via SOAP web services or secured FTP protocols, using XML format (with WSDL and XSD standards).
- The system operates on a 24/7 basis, ensuring continuous availability and up-to-date records.
For additional information or consultations, the Tasić & Partners team is at your disposal.