New Law on Central Records of Beneficial Owners

Author: Attorney-at-Law Milačić Z. Vladimir, Law Firm “VUK Tax Attorneys”

Date: 13th September 2025

As of 1st October 2025, the new Law on Central Records of Beneficial Owners (the “Law”) will be implemented in the Republic of Serbia, introducing new obligations regarding registration of beneficial owners in the Central Records of Beneficial Owners (“Central Records”) maintained by the Serbian Business Registries’ Agency. Primary aim of the Law is to enhance transparency of ownership structures of legal entities and ensure harmonization with the European standards, with the view to identifying beneficial owners and preventing misconduct in business operations, particularly those related to money laundering and financing of terrorism.

The Law expands types of entities required to register its beneficial owners, so this obligation now applies not only to companies (excluding public joint-stock companies), cooperatives, branches and representative offices of foreign legal entities, foundations, endowment funds, institutions and associations, but also to trusts and legal relationships similar to trust that are managed from the territory of the Republic of Serbia.

One of the key novelties introduced by the Law is mandatory registration of an extended set of information about beneficial owner (full name, personal identification number, date, place and country of birth, as well as country of domicile, whereas for foreign nationals additional data are required, such as passport or identity card number and the issuing country, and/or the foreigner’s single registration number issued in Serbia). Moreover, the Law introduces the obligation to upload supporting documentation in electronic format through the application of the Central Records based on which the beneficial owner is determined (foundation act, extracts from the commercial registry etc.), as well as identification documents of the beneficial owner. Until now, entities were only required to enter the information without submitting supporting documents, whereas they are now obliged to enclose in the application underlying documents that served for determining beneficial owner, as well as identification documents of a foreign national who is evidenced as beneficial owner.

Entities that have already registered their beneficial owners prior to start of the implementation of the new Law are obliged to re-register their beneficial owners and upload within 60 days relevant documentation based on which beneficial owner is determined, i.e. no later than 30th November 2025.

Also, the Law extends deadline for registration of changes in the Central Records. Instead of 15-day period, entities are now given 30 days from the date of change of the beneficial owner (for example, due to change in ownership structure) to update the information and submit the relevant documents.

The Law also introduces annual verification of data about beneficial owner. Namely, each entity must verify accuracy and validity of the information about its beneficial ownership at least once per year. One-year period counts from the date of last registration, last verification, or last submission of documents in accordance with the new Law. When one-year period expires, entity has 30 days to confirm that the information is accurate and up-to-date, and if ownership structure changes in the meantime, the one-year period starts to count from the date of registering such change.

The Serbian Business Registries’ Agency will publish on its website list of entities that fail to register their beneficial owners within the 30-day deadline, as well as those that fail to re-register data and/or fail to enclose supporting documents within 60 days after the Law started to apply (until 30th November 2025). This list will be updated every 48 hours. Entities appearing on the list will be classified as high-risk entities under the Law on Prevention of Money Laundering and Financing of Terrorism. Furthermore, if entities such as banks, who are obliged to implement the Law on Prevention of Money Laundering and Financing of Terrorism, determine inconsistencies between information available in the Central Records and information they possess, they must immediately notify the client and inscribe remark in the Central Records.

The Law imposes obligation to retain documentation that served for determining beneficial owner, for a period of ten (10) years from the date of registering beneficial owner of registering last change thereof. The Law does not prescribe the form in which this documentation must be retained, whereas this requirement appears redundant indeed. Namely, all relevant documents are already uploaded electronically to the Central Records and are permanently accessible therein, and the burden of proof anyhow rests with the entity to demonstrate authenticity and accuracy of said documentation if legal proceedings are initiated in that regard.

Failure to comply with the obligations imposed by the Law constitutes a misdemeanor, for which a monetary fine ranging from 500,000 RSD to RSD 2,000,000 RSD may be imposed to legal entity, and a monetary fine ranging from 50,000 RSD to 150,000 RSD to its statutory representative.

In conclusion, the new Law introduces changes such as expansion of types of entities on which the Law applies, mandatory submission of supporting documents in electronic form, extension of deadline for registering changes from 15 to 30 days, annual verification of data registered, publication of non-compliant high-risk entities and monetary fines for breaching the Law.

The Law Firm “VUK Tax Attorneys” will continue to monitor implementation of the new Law and remains at disposal to clients to ensure full compliance with their obligations related to the registering beneficial owners in the Central Records.