As of October 1, 2025, the Law on the Central Register of Beneficial Owners in Serbia (“Official Gazette of the RS”, Nos. 19/2025, 51/2025 and 60/2025 corr.) will enter into force. In this article, you will learn the basic information about the beneficial owner in Serbia (UBOs in Serbia) and the key compliance rules.
- Which Documents Should You Prepare for the New UBO Law in Serbia?
- Who is considered a Beneficial Owner in Serbia?
- To whom does the Law on UBOs in Serbia apply?
- Renewed Registration of Beneficial Owner in Serbia – Mandatory Even for Previously Registered Entities?
- Consequences of Non-Compliance with Registering Beneficial Owners in Serbia
Which Documents Should You Prepare for the New UBO Law in Serbia?
The Serbian Law on UBOs requires that the Central Register of Beneficial Owners in Serbia must contain:
- documents based on which the beneficial owner in Serbia (UBO in Serbia) has been determined,
- a copy of the passport or foreign ID card, if a foreign national is registered as a beneficial owner in Serbia.
Who is considered a Beneficial Owner in Serbia?
A beneficial owner in Serbia (UBO in Serbia) is a natural person who:
- directly or indirectly owns 25% or more of shares, equity, or voting rights in a registered entity,
- directly or indirectly exercises a controlling influence over management or decision-making,
- provides funds to the entity and thereby significantly influences its financing and business decisions,
- is a founder, trustee, protector, beneficiary, or a person holding a dominant position in a trust or a comparable legal arrangement,
- is a founder, beneficiary, or member of the governing body of a foundation or endowment.
If all reasonable measures fail to identify the beneficial owner, the registered representative or a member of the management body assumes the role of the UBO in Serbia.
To whom does the Law on UBOs in Serbia apply?
These obligations apply to the following entities registered in the Republic of Serbia:
- companies (except public joint-stock companies),
- cooperatives,
- branches and representative offices of foreign companies,
- associations (except chambers of commerce, political parties, trade unions, sports organizations, churches, and religious communities),
- foundations and endowments,
- institutions.
In addition, the law also applies to:
- trusts and similar legal arrangements managed from Serbia or where a comparable person has a seat/residence in Serbia,
- transactions involving assets, including digital assets, as well as cash transactions (receipt or payment of cash).
Renewed Registration of Beneficial Owner in Serbia – Mandatory Even for Previously Registered Entities?
All registered entities must complete a renewed registration of the beneficial owner in Serbia, regardless of whether this has been done previously. In other words, you must provide documents proving the ownership structure and verify and re-register the data on the UBOs in Serbia at least once per year, even if no changes occur.
The beneficial owner must be registered both at the time of incorporation of the company and upon any subsequent changes, while in addition, the information must be updated annually, with the obligation to submit new documents to the electronic register.
Consequences of Non-Compliance with Registering Beneficial Owners in Serbia
If obligations are not fulfilled:
- banks may block company accounts,
- Serbian Business Registers Agency will publish a list of non-compliant entities, which will be considered high-risk from an anti-money laundering (AML) perspective,
- in misdemeanor proceedings, fines of up to 2,000,000 RSD (approx. EUR 17,000) may be imposed.
To properly fulfill these obligations, it is highly advisable to engage a corporate lawyer who can help with he registration of beneficial owners in Serbia.