On 6 March 2025, the Assembly of the Republic of Serbia adopted the new Law on Central Registry of Beneficial Owners (the “Law”). The new Law entered into force on 14 March 2025, however its application has been delayed in order to provide sufficient time for business subjects to achieve compliance with the new obligations.
The goal of the changes introduced by the new Law is to have more transparent and reliable records of the beneficial owners.
Key Novelties
One of the key novelties is the obligation to submit the documents based on which the UBO was registered as such.
Further, there will be an obligation to regularly review the registered data and update them, if necessary.
The deadline for the UBO registration has been prolonged – it is now 30 days from the date of the registration of a business entity or change of the ownership structure in the business subject.
The Law envisages the duty of banks (and other obligors) to review the documents and data registered in the UBO register and compare them with data and documents they separately obtained.
The Business Registers Agency (the “BRA”) remains as the authority in charge of monitoring the implementation of this Law, with a new, additional obligation. Namely, after 60 days from the date the Law becomes applicable, the BRA will publish a list of business subjects that have not registered/submitted required data and documents concerning their UBO.
The penalties for breaching the Law are the same as they were in the previous law – ranging from RSD 500,000.00 (approx. EUR 4,300.00) up to RSD 2,000,000.00 (approx. EUR 17,000.00).
Application of the Law
14 September 2026.
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