Companies in Serbia are required to update their ownership data by 30 November 2025
On 1 October 2025, Serbia introduced a new procedure for registering beneficial (actual) owners of legal entities and other persons. It is based on the Law on the Central Register of Beneficial Owners (Zakon o centralnoj evidenciji stvarnih vlasnika, Sl. glasnik RS, No. 19/2025).
The law came into force on 14 March 2025, but provided for a transition period that ended on 1 October. From that moment on, the requirements for registering and updating data on owners became mandatory for all entities subject to the law.
The aim of the reform is to increase the transparency of corporate structures, strengthen control over company ownership and bring Serbian legislation into line with international standards in the field of combating money laundering and terrorist financing.
Who needs to update their information
The obligation to submit or update data on beneficial owners applies to:
- companies (except public joint stock companies);
- cooperatives;
- branches and representative offices of foreign companies;
- associations, foundations, institutions and organisations (except political parties, sports associations, trade unions and religious communities);
- trusts and similar legal entities, if their activities are related to the territory of Serbia.
Companies that fail to update their ownership information within 30 days of their establishment or fail to submit documents within 60 days of the law coming into force will be included in a public list of high-risk entities published by the Agency for the Registration of Enterprises (APR).
Key changes
1. Mandatory submission of supporting documents
When registering or updating data, electronic copies of documents confirming ownership or control must now be attached, such as articles of association, memoranda of association, meeting resolutions and other supporting documents.
If the beneficiary is a foreign citizen, a copy of their passport or ID card is also required.
2. Annual confirmation of data validity
Companies are required to verify and confirm annually that the information about their owners remains valid.
3. Transition period and deadline for updating records
Entities that are already registered must bring their records into compliance with the new rules by 30 November 2025, i.e. within 60 days of the law coming into force.
4. Access and storage of data
Information and documents will be available to government and supervisory authorities, as well as entities that are required to comply with the Anti-Money Laundering Act.
All data must be stored for at least 5 and no more than 10 years after the company is removed from the register.
Data is submitted via the APR electronic portal.
Liability for violations
Serious penalties are provided for non-compliance with the requirements:
- for legal entities — a fine of between RSD 500,000 and RSD 2,000,000;
- for responsible officials — between RSD 50,000 and RSD 150,000.
Intentional concealment of information or submission of false data may result in criminal liability, including imprisonment.
In addition, restrictive measures may be applied, such as a temporary ban on certain activities until the violations are remedied.
Recommendations for companies
Organisations with foreign structures, trusts or complex ownership schemes are advised to consult legal advisors with experience in international structures and document legalisation procedures. This will help to ensure that information is correctly documented and avoid sanctions.
Our support
We provide comprehensive support to non-resident companies doing business in Serbia:
- we advise on the requirements of the new legislation;
- we help prepare and submit documents to the APR;
- we accompany the procedures for legalisation and notarisation of foreign documents.
