Central records of beneficial owners

The Law on Central Records of Beneficial Owners (“Official Gazette of the RS”, nos. 19/2025, 51/2025 and 60/2025 – corr.) governs the establishment, content, grounds for registration, and manner of maintaining the Central Records of Beneficial Owners of legal entities, other entities registered in the Republic of Serbia in accordance with the law, trusts and legal arrangements similar to trusts, for which there is an obligation to register ultimate beneficial owners under this law, as well as other matters relevant to the registration of ultimate beneficial owners.

This law was adopted to enhance the Republic of Serbia’s mechanisms for preventing money laundering and the financing of terrorism.

Entities to Which the Law Applies

The Law on Central Records of Beneficial Owners (“Official Gazette of the RS”, nos. 19/2025, 51/2025 and 60/2025 – corr.) shall apply to the following legal entities and other entities registered in the Republic of Serbia in accordance with the law (hereinafter: registered entities):

companies, other than public joint-stock companies;
cooperatives;
branches of foreign companies;
business and other associations, other than chambers of commerce and representatives of foreign chambers of commerce, political parties, trade unions, sport organisations and associations, churches and religious communities;
foundations and endowments;
institutes;
representative offices of foreign companies, associations, foundations and endowments,
as well as to
– trusts managed from the Republic of Serbia or trusts where the administration is not located in the Republic of Serbia, if the trustee, on behalf of the trust, enters into a business, professional or commercial relationship, or performs transactions or cash transactions with legal or natural persons in the territory of the Republic of Serbia;
– legal relationships similar to trusts that are managed from the Republic of Serbia or where the administration is not located in the Republic of Serbia, if a person comparable to a trustee enters into a business, professional or commercial relationship, or performs transactions or cash transactions with legal or natural persons in the territory of the Republic of Serbia.

Cases where the beneficial owner is not identified or registered

The beneficial owner shall not be identified or registered:

for registered entities where the Republic of Serbia, autonomous province or local self-government unit is the only member or founder;
for registered entities whose sole member is another Registered Entity that is wholly owned by the Republic of Serbia, an autonomous province, or a local self-government unit, public enterprises, the Republic of Serbia, an autonomous province, or a local self-government unit;
for registered entities that are undergoing bankruptcy proceedings in accordance with the law governing bankruptcy, in cases where, before the initiation of the bankruptcy procedure, the legal representative or a member of the management body was not recorded as the beneficial owner of that registered entity;
for registered entities against which a compulsory liquidation procedure has been initiated in accordance with the law;
in relation to the Republic of Serbia, autonomous province and a local self-government unit, when they are part of the ownership structure of the capital of a registered entity;
in relation to a fund established by the Republic of Serbia, autonomous province or a local self-government unit, when they are part of the ownership structure of the capital of a registered entity;
in relation to the bankruptcy estate in accordance with the law governing bankruptcy, when the bankruptcy estate is part of the ownership structure of the capital of a registered entity;
in relation to the social capital and the Register of Shares and Stakes, when the social capital is part of the ownership structure of the capital of a registered entity.

Who is considered a beneficial owner?

Beneficial owner means:

a natural person who owns, indirectly or directly, 25% or more of the stakes, shares or voting rights, based on which they participate in controlling the registered entity;
a natural person who indirectly or directly has a dominant influence on business management and decision-making;
a natural person who has provided or provides funds to a registered entity in an indirect manner, which gives him the right to influence substantially the decisions made by the governing bodies of the registered entity concerning its financing and business operations;
a natural person who is the settlor, trustee, protector, or beneficiary of a trust, if designated, and if the beneficiary is not designated, the group of persons in whose interest the trust is established, as well as a person who holds a dominant position in the management of the trust or in a legal relationship similar to a trust;
a natural person who is the founder, beneficiary of the foundation, or endowment if designated, and if the beneficiary is not designated, the group of persons in whose interest the foundation or endowment was established, as well as the members of the governing bodies of the foundation or endowment.

Exceptionally, in the cases prescribed by the provisions of Article 3, paragraph 2 of the Law on Central Records of Beneficial Owners (“Official Gazette of the RS”, nos. 19/2025, 51/2025 and 60/2025 – corr.), the beneficial owner of the registered entity shall be the natural person registered for representation or the one registered as a member of the governing body of that entity.

What is the Central Register of Beneficial Owners?

The Central Records of Beneficial Owners means a single, public, central electronic database on natural persons who are beneficial owners of a registered entity. The Central Records of Beneficial Owners shall be kept by the Serbian Business Registers Agency in electronic form, through the registrar.

The Central Records of Beneficial Owners, apart from the data prescribed by the provisions of the Law on Central Records of Beneficial Owners (“Official Gazette of the RS”, nos. 19/2025, 51/2025 and 60/2025 – corr.), shall also contain the documents based on which the beneficial owner was determined, the dates of recording the data and documents, as well as a copy of the passport or foreign ID card, if a foreigner is registered as the beneficial owner.

Grounds for registration

The grounds for registration in the Central Records of Beneficial Owners, shall be:

entry of the registered entity in the relevant register;
changes in the ownership structure and members of the governing body of a registered entity, as well as other changes based on which it can be assessed whether the conditions for acquiring the status of beneficial owner of the registered entity are met;
management of a trust from the Republic of Serbia, or a legal relationship similar to a trust, or entering by the trustee, or a person comparable to a trustee in a legal relationship similar to a trust, into a business, professional, or commercial relationship on behalf of the trust or a legal relationship similar to a trust, or performing transactions such as acceptance, provision, exchange, custody, disposal, or other handling of assets, including a payment transaction within the meaning of the law governing the provision of payment services, as well as a transaction involving digital assets within the meaning of the law governing digital assets as well as physical acceptance or provision of cash.

Manner of keeping the Central Records of Beneficial Owners

The registration of data in the Central Records of Beneficial Owners shall be performed by:

the registrar, based on data obtained from the competent state authorities regarding the registered entity as specified in Article 6, paragraph 1 of the Law on Central Records of Beneficial Owners (“Official Gazette of the RS”, nos. 19/2025, 51/2025 and 60/2025 – corr.);
an authorised person, specifically for data under Article 6, paragraphs 2 and 3 of the Law on Central Records of Beneficial Owners (“Official Gazette of the RS”, nos. 19/2025, 51/2025 and 60/2025 – corr.).

The authorised person for entering data into the Central Records of Beneficial Owners means:

a founder in the process of establishing a registered entity electronically;
a person authorised to represent the registered entity in all other cases;
a trustee, or in the case of a legal relationship similar to a trust, a person comparable to the trustee.

The authorised person shall register data in the Central Records of Beneficial Owners no later than 30 days from the date of the occurrence of the grounds for registration and, simultaneously with the registration, upload the documents based on which the beneficial owner has been determined.

The authorised person shall perform the registration and modification of registered data using a qualified certificate for electronic signature.

Obligations and Deadlines

Entities to which the provisions of the Law on Central Records of Beneficial Owners (“Official Gazette of the RS”, nos. 19/2025, 51/2025 and 60/2025 – corr.) apply are subject to the following obligations:

Entry of data into the Central Records of Beneficial Owners must be carried out no later than 30 days from the date on which the basis for registration arises.
Annual verification and confirmation of accuracy of recorded data – The registered entity, i.e. the authorised person, is obliged to verify the accuracy and up-to-datedness of the recorded data on the ultimate beneficial owner within one year from the date of the last registration or the last confirmation of accuracy and up-to-datedness, and to confirm the accuracy and up-to-datedness within a further 30-day period;
The submitted documentation must be valid and clearly indicate the basis of ownership.
Existing registered entities are legally obliged to comply with the provisions of the Law on Central Records of Beneficial Owners (“Official Gazette of the RS”, nos. 19/2025, 51/2025 and 60/2025 – corr.) by 30 November 2025.

Simultaneously with the registration, the data is published on the official website (portal) of the Serbian Business Registers Agency.

The data on the beneficial owner becomes legally effective for third parties on the day following its publication on the Serbian Business Registers Agency’s website.

Retention of data and documents

The Serbian Business Registers Agency is required to retain the data and documents from the Central Records of Beneficial Owners for at least five and no longer than ten years after the strike–off of the registered entity, trust, or trust-like legal arrangement from the relevant register.

The registered entity, trustee of the trust, and the person comparable to the trustee in a legal relationship similar to a trust shall retain the adequate, accurate, and up-to-date data and documents based on which the beneficial owner of the registered entity, trust or legal relationship similar to a trust has been registered for ten years from the date of registration of the data on the beneficial owner, or from the date of registration of the last change in the data on the beneficial owner, unless this conflicts with the regulations on archival material.

The authorised representative of a registered entity, as well as the trustee or, in the case of a trust-like arrangement, the person comparable to a trustee, is required, in accordance with the regulations on archival material, retain the documents based on which the beneficial owner of the registered entity, trust or legal relationship similar to a trust has been registered for five years from the date of cessation of the registered entity, trust or legal relationship similar to a trust.

List of registered entities that have not registered their beneficial owner in the Central Records of Beneficial Owners

The Serbian Business Registers Agency compiles and publishes on its website (portal) the list of registered entities that have not registered their beneficial owner in the Central Records within 30 days from the day the entity was founded, or from the day the beneficial owner was deleted from the Central Records in line with Article 13, paragraph 5 of the Law on Central Records of Beneficial Owners (“Official Gazette of the RS”, nos. 19/2025, 51/2025 and 60/2025 – corr.), as well as the existing registered entities that have not registered data about their beneficial owner in the Central Records of Beneficial Owners until the start of application of the Law on Central Records of Beneficial Owners (“Official Gazette of the RS”, nos. 19/2025, 51/2025 and 60/2025 – corr.) i.e. until October 10, 2025.

The Serbian Business Registers Agency’s list shall also contain data about the existing registered entities that, within 60 days of the start of application of the Law on Central Records of Beneficial Owners (“Official Gazette of the RS”, nos. 19/2025, 51/2025 and 60/2025 – corr.) i.e. until November 30, 2025, have not uploaded documents based on which the beneficial owner was determined.

The Serbian Business Registers Agency is obliged to update the list every 48 hours.

Registered entities on the Serbian Business Registers Agency’s list shall be classified as highrisk within the meaning of the law governing the prevention of money laundering and terrorism financing.

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