The new Law on the Central Register of Ultimate Beneficial Owners (“Official Gazette of the Republic of Serbia” No. 19/2025, hereinafter: “Law”) enters into force on March 14, 2025. Most of its provisions will take effect after 18 months, i.e. from September 14, 2026. Exceptionally, certain provisions will apply immediately upon the Law’s entry into force, as detailed below.

The new Law will replace the regulation with the same name from year 2018, that is currently in force, with the aim of enhancing the transparency of ownership structures and aligning with international standards in the fight against money laundering and terrorist financing.

In addition to companies and other entities already covered by the current regulation on the central register of ultimate beneficial owners (“UBO”), the new Law also regulates the registration of trusts and similar legal arrangements managed from the Republic of Serbia, or those not managed in Serbia if the trustee (or a person comparable to a trustee) enters into a business, professional, or commercial relationship on behalf of the trust or conducts transactions or cash transactions with legal or natural persons on the territory of the Republic of Serbia (all entities hereinafter collectively referred to as “Registered Entities”). Furthermore, chambers of commerce and representative offices of foreign chambers of commerce are exempt from registration.

The content of the Central Register will remain unchanged regarding data on Registered Entities, except for the addition of items related to trusts and similar legal arrangements. On the other hand, the scope of information required for the registration of UBOs has been expanded, necessitating updates. In the future, the Central Register will also include documents used to determine the UBO, as well as a copy of the passport or foreign ID card if a foreign national is registered as the UBO.

Registered Entities will have an additional annual obligation to verify the accuracy and up-to-date status of the recorded UBO information.

The retention period for data and documents on the basis of which the UBO is registered remains ten years from the date of registration or the last change in UBO information. However, a new obligation has been introduced to retain documents on the basis of which the UBO is registered, in accordance with archival regulations, for a period of five years from the date of termination of the Registered Entity. This provision, along with the corresponding penalty provision in case of non-compliance, applies from the date the Law enters into force.

The Business Registers Agency will publish on its website a list of Registered Entities that have not registered a UBO in the Central Register within 30 days of establishment or deletion of the UBO, as well as those that have not registered a UBO by the start of the Law’s implementation. Additionally, the list will include Registered Entities that have not uploaded UBO documents within 60 days of the Law’s implementation. This list will be updated every 48 hours. Registered Entities on the list will be classified as high-risk under the law governing the prevention of money laundering and terrorist financing.

The Law also establishes the duty of obliged entities, as defined by the law governing the prevention of money laundering and terrorist financing (hereinafter: obliged entities), to obtain and compare data from the Central Register when determining the UBO of a client in accordance with that law. In case of data discrepancies, the Law prescribes further steps to be taken by obliged entities, Registered Entities, and the competent authorities.

Finally, the new Law imposes stricter penalties for criminal offense and violations in case of non-compliance with the prescribed obligations.