New regulations require companies in Serbia to report their “actual owners” (ultimate beneficiaries of ownership) in order to increase transparency and prevent money laundering. All registered entities must align their data with the amended Law on the Central Register of Actual Owners and submit the required documentation to the Serbian Business Registers Agency (APR) within the prescribed deadline.

Legal basis and amendments to the law

The National Assembly of the Republic of Serbia adopted the Law on the Central Register of Actual Owners, which entered into force in March 2025. It was initially planned for the application to be postponed for 18 months, but the amendments significantly shortened the deadline and determined that the application begins on October 1, 2025. At the same time, it was additionally prescribed that all existing legal entities are obliged to harmonize their operations with the new provisions within 60 days from the beginning of the law’s application.

The goal of the new solutions is to improve the system of preventing money laundering and the financing of terrorism, to increase the transparency of ownership structures, and to harmonize domestic legislation with international standards.

Obligation to report actual owners

All registered legal persons and other entities are obliged to record data on actual owners in the Central Register of Actual Owners (CESV). The obligation includes a wide range of entities: companies, branches, cooperatives, associations, foundations, institutions, and other persons registered in the Republic of Serbia.

Only certain entities are exempt from this obligation, such as sole proprietors, public joint-stock companies, political parties, trade unions, religious communities, and organizations that are specifically prescribed as not being obliged.

The obligation also applies to entities that previously reported actual owners – they are now required to carry out re-registration, updating, or confirmation of data, with mandatory uploading of documentation on the basis of which the actual owner was determined. The law also prescribes an annual obligation to check and confirm the accuracy of the recorded data.

Deadline for reporting – November 29, 2025

All existing entities are required to align their data within 60 days from the beginning of the Law’s application. Since the Law begins to apply on October 1, 2025, the final deadline for reporting actual owners expires on November 29, 2025.

By that date, all obligated entities must:

• record actual owners or confirm existing data,

• electronically submit supporting documentation to APR.

For newly established legal entities, the deadline for reporting is 30 days from establishment, while all changes in ownership structure must be reported within 30 days of occurrence.

Consequences of failing to report

Failure to fulfill the obligation to report actual owners within the prescribed deadline carries serious consequences, including:

1. Misdemeanor fines
   • for a legal entity: from 500,000 to 2,000,000 RSD,
   • for the responsible person: from 50,000 to 150,000 RSD.

2. Criminal liability
   In cases of concealment, entering incorrect data, or deleting correct data, responsible persons may also bear criminal liability, including imprisonment.

3. Protective measures
   The court may impose a ban on performing activities on the legal entity, or a ban on performing duties on the responsible person.

4. Business consequences
   APR will publish a list of entities that have not aligned data on actual owners. Such entities receive the status of high-risk entities in the anti-money laundering system, which may lead to:
   • enhanced supervision,
   • difficulty in accessing financial services,
   • possible restrictions or account blocks by banks,
   • damage to business reputation.

Steps for reporting actual owners (CESV)

Reporting is done exclusively electronically via the APR portal. The procedure includes:

1. Preparation of technical requirements
   • qualified electronic certificate of the authorized representative,
   • creation of a user account on the APR portal,
   • installed software for electronic signing.

2. Access to the CESV portal
   The authorized representative logs in and initiates a new request for recording the actual owner.

3. Entering or confirming data
   Data is entered for the natural person who meets the criteria of an actual owner (most commonly a person who holds 25% or more of shares, has management control, or another prevailing influence).

4. Uploading documentation
   Documents that confirm the basis for determining the actual owner must be attached: founding act, extract from a foreign register, contracts, ownership structure diagram, management body decisions, identification documents for foreign nationals, etc.

5. Electronic signing and submitting the request
   The request is signed with a qualified electronic signature and submitted to APR. The recording is generally processed very quickly and becomes visible in the register the following day.

Assistance and support of the Stevanović Law Office

If you have questions regarding:

• determining who the actual owner is,

• preparing documentation,

• technical aspects of electronic reporting,

• legal consequences of failing to report,

our team is at your disposal.

Contact for assistance:

📧 prijavavlasnika@advokati-stevanovic.com

Our office provides full legal support in completing and submitting reports, as well as in resolving any uncertainties related to the new

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"Standard Prva" LLC Bijeljina is a company registered in Bijeljina at the District Commercial Court in Bijeljina. Company’s activities are accountancy, repurchases of receivables, angel investing and other related services. Distressed debt is a part of the Group within which the company repurchases the receivables, which function and are not returned regularly.

Lawyer’s Office Stevanović is the leading lawyer’s office in the region with the seat in Bijeljina. The LO abbreviation represents Lawyer’s Office of Vesna Stevanović and Lawyer’s Office of Miloš Stevanović.

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