Pursuant to the Law on the Central Register of Beneficial Owners, registered entities are required to periodically verify the accuracy and currency of the information on their beneficial owners recorded with the Serbian Business Registers Agency (“SBRA”).
This obligation applies, inter alia, to companies, companies in liquidation, cooperatives, branches of foreign companies, business associations, associations and unions of associations, foundations and endowments, institutions, as well as representative offices of foreign companies, associations, foundations and endowments.
The obligation does not apply, inter alia, to sole proprietors, public joint-stock companies, companies undergoing bankruptcy or compulsory liquidation proceedings, or other entities exempted by law.
The key obligation is the annual verification of beneficial ownership information.
- A registered entity, acting through its authorised representative, is required to verify the accuracy and currency of the recorded beneficial ownership information within one year from the date on which such information was last recorded or its accuracy and currency were last confirmed. Following such verification, the registered entity must confirm the accuracy and currency of the information in the Central Register of Beneficial Owners within a further 30-day period.
- For existing registered entities that complied with the requirements of the new Law during the period from 1 October to 1 December 2025, the uploading of the documents on the basis of which the beneficial owner was identified constituted the first verification of the recorded beneficial ownership information.
- Accordingly, the first annual verification deadlines will begin to fall due as of 1 October 2026. It is important to note that 1 October 2026 is not a uniform deadline applicable to all registered entities. The applicable deadline must be determined on an individual basis, by reference to the date on which the beneficial ownership information was last recorded or its accuracy and currency were last confirmed. Where the beneficial owner has changed in the meantime, the one-year verification period runs from the date of such change.
How is the obligation fulfilled:
- The recording and confirmation of beneficial ownership information is carried out electronically through the SBRA Central Register of Beneficial Owners Portal. The registered legal representative accesses the system through an eID account, using a qualified electronic certificate or the ConsentID application. Electronic signing is performed using the applicable electronic signature solution, including the NexU application, ConsentID or a cloud-based electronic signature.
- The procedure may be carried out directly by the registered legal representative. The relevant filing may also be prepared by an authorised accountant or attorney-at-law, subject to the requirements prescribed by the SBRA. However, the filing must ultimately be signed by the registered legal representative.
- The SBRA has expressly stated that it will initiate misdemeanour proceedings against the registered entity and its responsible person where the accuracy and currency of beneficial ownership information are not confirmed within the statutory deadline.
Given that the first annual verification deadlines will begin to fall due as of 1 October 2026, registered entities are advised to timely verify the date of their most recent registration or verification of beneficial ownership information and ensure that they have a functioning eID account, an appropriate electronic signature solution and access to the SBRA system.
For additional information or consultations, the Tasić & Partners team is at your disposal.