Annual Verification of Beneficial Owners

The first year has passed since the new obligations relating to the Central Records of Beneficial Owners began to apply. These obligations were introduced by the Law on the Central Records of Beneficial Owners (“Official Gazette of the RS”, Nos 19/2025, 51/2025 and 60/2025 – corr.; hereinafter: the Law), which has applied since 1 October 2025. This means that, for companies and other registered entities, the deadlines for the first annual review and confirmation of beneficial ownership data are now beginning to fall due.

This obligation is particularly important because it applies even where nothing has changed during the previous year with regard to the beneficial owner or the ownership structure.

We covered the key changes introduced by the new Law – from the expanded circle of obliged entities and the mandatory upload of documentation to the list of high-risk obliged entities – in our article Central Records of Beneficial Owners: Key Changes, Obligations and Penalties.

IN THIS ARTICLE:

1. When is the annual verification deadline?
2. Is verification mandatory if there have been no changes?
3. What if there have been changes?
4. Who carries out the verification and how?
5. Liability for misdemeanours
6. Recommendations for companies

1. The deadline is not the same for all companies

Annual verification is not tied to a single fixed calendar date.

A registered entity is required to check the accuracy and currency of the recorded data within one year of the last registration or previous confirmation of the data, and then to confirm their accuracy and currency within the following 30 days.

For companies that complied with the Law during the transitional period (from 1 October to 1 December 2025), the deadline runs from the date on which they completed the registration and uploaded the documentation. As a result, the first deadlines fall due gradually during October, November and December 2026.

Each company should therefore first check the date on which it last registered or confirmed its data in the Central Records.

2. No changes? Verification is still mandatory

One of the most important novelties is that the absence of changes does not mean the absence of an obligation.

If the beneficial owner, the recorded data and the documentation have remained unchanged, no new registration is made; instead, the legal representative must electronically confirm their accuracy and currency via the portal of the Serbian Business Registers Agency (SBRA).

3. Where there are changes, verification is not enough

The annual review is also a good opportunity for a company to check not only who is registered as the beneficial owner, but also whether the recorded data and the uploaded documentation reflect the current situation.

If it is established that there has been a change of beneficial owner, in their data, in a complex ownership structure or in the documentation on the basis of which the beneficial owner was identified, it is necessary to register the relevant changes and, where required, upload new documentation. We explained which documentation is uploaded, and why this is particularly demanding for companies with a complex ownership structure, in our previous article on the Central Records of Beneficial Owners.

It is important to stress that annual verification does not replace the obligation to register changes in a timely manner. Once a change has been registered, a new one-year period for confirming the data starts to run from that registration.

4. Verification is carried out electronically by the legal representative

The procedure is conducted via the portal of the Serbian Business Registers Agency, the same portal through which the beneficial owner is registered.

The legal representative must have:

• an account on the eID.gov.rs portal and an account on the SBRA system;
• a qualified electronic certificate issued in the Republic of Serbia, or the ability to sign electronically via ConsentID, i.e. a cloud-based signature.

The procedure may also be prepared by a lawyer or accountant with the appropriate user role, but the confirmation is signed by the registered legal representative.

5. Liability for misdemeanours

Failure to carry out the annual review and confirmation constitutes a breach of a self-standing statutory obligation. For failure to comply with these obligations, the Law provides for misdemeanour liability of the legal entity and of the responsible person within the legal entity:

Who is fined Fine

Legal entity RSD 500,000 to RSD 2,000,000

Responsible person within the legal entity RSD 50,000 to RSD 150,000

6. Recommendations for companies

ANNUAL VERIFICATION CHECKLIST:

• Check the date of the last registration or verification of the beneficial owner.
• Determine your specific deadline – one year from that date, plus an additional 30 days for confirmation.
• Check the accuracy of the data and documentation – whether the recorded data and the uploaded documentation still reflect the actual situation.
• Register any changes – if there have been changes, instead of a confirmation, the changes are registered and new documentation is uploaded.
• Check the technical prerequisites – whether the legal representative has the necessary accounts and electronic signature.
• Confirm the data within the prescribed deadline and record the date of the next verification.

Conclusion

The first annual verification is the next step in the implementation of the new beneficial ownership records system. For most companies that have duly complied, the procedure will not be complicated, but it does require active steps even where there have been no changes during the year.

Now is therefore the right time for companies to check when they last registered their beneficial ownership data and to determine, in good time, their deadline for the first annual verification.

Not sure when your deadline expires, or whether your recorded data and documentation are still up to date? Write to us at [email protected].