As of October 1, 2026, the mandatory annual verification of the accuracy and currency of data within the Central Records of Beneficial Owners has commenced. The Serbian Business Registers Agency (APR) urges all registered entities to fulfill this legal obligation in a timely manner to avoid substantial fines and potential misdemeanor proceedings.

Below is a detailed guide on which entities are affected, the applicable deadlines, required documentation, and the penalties for non-compliance.

Who Is Obligated to Perform the Verification?

The new Law on the Central Records of Beneficial Owners applies to a broad range of entities:

• Business Companies (d.o.o., a.d.) and Cooperatives

• Associations, Foundations, and Endowments

• Branches of Foreign Companies

• Trusts and Trust-Like Legal Arrangements (if managed from Serbia or engaged in business activities within the country).

Who is a Beneficial Owner?

A beneficial owner is always a natural person who, directly or indirectly, holds 25% or more of the equity, shares, or voting rights, or a person who exercises a controlling influence over the management and business operations of the entity.

Deadlines: When Does Your Obligation Begin?

The annual verification obligation arises exactly one year from the date of the last record of data or the last confirmation of its accuracy.

1. For entities that performed harmonization between Oct 1, 2025, and Dec 1, 2025:

   The upload of documentation during this period constituted the initial verification. The one-year deadline is calculated from that date, meaning your annual verification obligation arises in October, November, or December 2026, respectively.

2. For entities that subsequently updated their data:

   If you changed data or supplemented documentation after the initial harmonization, the one-year deadline is calculated from the date of that specific update.

Once the one-year period from the last record has elapsed, you have an additional 30-day grace period to perform the annual verification via the APR Portal.

How to Complete the Verification Process at APR

The procedure depends on whether there have been changes to the ownership structure during the preceding year:

1. If there have been NO changes:

If the data on the beneficial owner and the complex ownership structure have remained unchanged, the process is straightforward. The legal representative electronically confirms the accuracy and currency of the existing recorded data via the APR Portal.

2. If there HAVE been changes:

If there has been a change in the beneficial owner, personal data, or supporting documentation (e.g., new agreements, articles of association, ID cards), you are required to perform a new recording and upload the appropriate supporting documentation into the system.

Requirements for Accessing the APR Portal

In order for the legal representative to successfully confirm or update the data, they must possess:

• An account on the eID.gov.rs Portal and a registered account on the APR system (REID).

• A Qualified Electronic Certificate (electronic signature) issued in the Republic of Serbia, or ConsentID.

• An installed card reader and the NEXU application for electronic signing (signing in the Cloud is also enabled).

Risks and Penalties: What If You Fail to Comply?

Missing the deadlines entails serious legal and financial consequences:

• Fines for Misdemeanors: From RSD 500,000 to RSD 2,000,000 for the legal entity, and from RSD 50,000 to RSD 150,000 for the responsible person within the entity.

• Ban on Business Activities: A court may impose a protective measure banning the performance of business activities for a duration of 6 months to 3 years.

• Criminal Liability: Knowingly concealing a beneficial owner or entering false data constitutes a criminal offense punishable by imprisonment of up to 5 years.

• High-Risk Status: Entities that fail to comply are publicly listed on a special APR list, which is updated every 48 hours. In practice, this leads to frozen bank accounts, business disruptions, and the inability to participate in public procurement.

Do You Need Assistance with Verification or Documentation Review?

Given that the recording process requires a precise determination of ownership chains and the submission of proper legal grounds (agreements, decisions, excerpts from foreign registers), it can pose a challenge for business companies without internal legal support.

Our team of legal professionals is available to provide assistance with:

• Analyzing your ownership structure and identifying the beneficial owner.

• Preparing and reviewing all necessary documentation in accordance with current regulations.

• Complete handling of the verification procedure on the APR Portal.

Prevent unnecessary risks and penalties. [Contact us today] to ensure your business is fully compliant with the law.