Effective 1 October 2025, amendments to the Law on the Centralised Records of Beneficial Owners (UBO) in Serbia will introduce important new obligations for a broader range of entities.
What’s changing?
- Expanded scope of reporting entities
UBO registration requirements will now apply not only to companies and other legal entities, but also to trusts and similar legal arrangements managed from Serbia or engaging in business, professional, or commercial activities, or conducting cash transactions in Serbia. - Mandatory digital submission of supporting documentation to the Serbian Business Registers Agency (SBRA)
Entities will be required to electronically submit to the SBRA all documents used to determine the UBO, including a passport or ID copy if the UBO is a foreign national. The SBRA will assess the accuracy and completeness of the submitted data.
The deadline for initial upload of these documents is 30 November 2025. - Ongoing compliance obligations
The UBO Register maintained by SBRA must be updated at least once a year. Updates should include revised UBO information supported by new documentation if there are any changes, or formal confirmation that no changes have taken place. Additionally, any changes in ownership structure or governing bodies impacting the UBO must be reported within 30 days of their occurrence.
Consequences of non-compliance
Failure to register or update UBO information may result in monetary fines of up to EUR 17,000 for legal entities and up to EUR 1,200 for responsible individuals.
Intentional concealment of the UBO, submission of false data, or manipulation of accurate records in the UBO Register is punishable by imprisonment ranging from six months to five years.
In addition, the amended law introduces protective measures, including temporary bans on conducting specific business activities for legal entities and prohibitions on holding certain positions for responsible persons, lasting from six months to three years.
The information in this document does not constitute legal advice on any particular matter and is provided for general informational purposes only.
