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How to register the beneficial owners (UBO) of a company in Serbia

A company in Serbia records its beneficial owners (UBO) in the Central Records of Beneficial Owners, which APR, the Serbian Business Registers Agency, keeps. A new company records them within 30 days of its registration, and a company records each change within 30 days of the change. The registered legal representative signs each entry, and the company checks and confirms its data once a year.

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Key facts

TopicRuleLegal basis or source
The registerCentral Records of Beneficial Owners (Centralna evidencija stvarnih vlasnika), kept by APRLaw on the Central Records of Beneficial Owners (UBO Act), Sl. glasnik RS 19/2025, 51/2025 and 60/2025
The law appliesSince 2025-10-01UBO Act Art. 27, as amended by 51/2025
New company or branch officeRecords the beneficial owners and uploads the documents within 30 days of its APR registrationUBO Act Art. 7 item 1, Art. 8(3) and (4)
Change of owners or of the bodiesWithin 30 days of the changeUBO Act Art. 7 item 2, Art. 8(4)
Company registered before 2025-10-01Aligned its entry and uploaded the documents from 2025-10-01 to 2025-11-30UBO Act Art. 24. APR questions and answers. APR news of 2025-09-22.
Annual checkCheck the data within 1 year of the last recording or confirmation, then confirm it within a further 30 daysUBO Act Art. 9(1)
RecordsKeep the data and the documents for 10 years. Give them to a supervisor within 3 working days of a request.UBO Act Art. 12(2) and (3), Art. 19(1) item 5
APR fee for the entryNone in the APR fee decisionAPR fee decision, Art. 7 items 8 and 9
Extract from the register2,500 RSDAPR fee decision, Art. 7 item 8
Certificate, per beneficial owner1,500 RSDAPR fee decision, Art. 7 item 9
Fine for the company500,000 to 2,000,000 RSDUBO Act Art. 19(1)
Fine for the responsible person50,000 to 150,000 RSDUBO Act Art. 19(2)

Who is a beneficial owner?

The Law on the Prevention of Money Laundering and the Financing of Terrorism (Zakon o sprečavanju pranja novca i finansiranja terorizma, the AML Law) defines the beneficial owner in Art. 3(1) item 11. A beneficial owner is a natural person who meets one of these conditions:

  • The person holds, directly or indirectly, 25% or more of the shares or the votes.
  • The person has a dominant influence on the business of the company.
  • The person funds the company and so has a strong influence on its decisions.

When the company cannot find such a person, the registered representative or a member of the management body counts as the beneficial owner. Indirect ownership counts. So the company follows each chain of ownership, for example through a foreign parent company, to the natural persons at its end. To find an indirect share, the company multiplies the shares along the chain. For example, a person who holds 50% of a parent company that holds 50% of the Serbian company holds 25%. Along each chain, the company follows the control as well as the shares.

Which deadline applies now?

The Law on the Central Records of Beneficial Owners (Zakon o centralnoj evidenciji stvarnih vlasnika), the UBO Act, applies since 2025-10-01. On 2026-10-17, these deadlines apply:

  • A company or a branch office registered now. It records its beneficial owners and uploads the documents within 30 days of its APR registration.
  • A d.o.o. founded electronically. The founder can record the beneficial owners in the founding application.
  • A change. A change of the owners or of the members of the bodies goes into the register within 30 days. The same deadline applies to any other change that affects who the beneficial owner is.
  • A company registered before 2025-10-01. It aligned its entry with the new law and uploaded the documents from 2025-10-01 to 2025-11-30. That window is closed.

Some pages still give the date 2026-11-13. The first text of the UBO Act, Sl. glasnik RS 19/2025, had a later timeline, and the amendment 51/2025 replaced it. The date 2026-11-13 belongs to that first timeline, and it does not apply.

What does the register hold for a foreign owner?

For a foreign beneficial owner, the register holds:

  • The name
  • The passport number or the ID number and the issuing state, or the EBS, the registration number of a foreign national in Serbia
  • The date and the place of birth
  • The state of residence and the citizenship
  • The documents that show the ownership
  • A copy of the passport or of the foreign ID card

Who prepares and signs the entry?

An authorised lawyer or accountant with the required user role can prepare the entry, and the registered legal representative signs it. The representative signs with a qualified electronic certificate issued in Serbia, or with a cloud signature. A non-resident representative can sign with a Serbian qualified certificate that carries the passport number, with no EBS.

A foreign representative logs in to eID, the portal for electronic identification, with the same passport number or EBS that the APR register holds. If the numbers differ, the representative first files a change of personal data at APR.

How does a company record its beneficial owners?

  1. Identify the beneficial owners. Follow each chain of ownership to the natural persons with 25% or more, a dominant influence, or a strong influence through funding.
  2. Collect the data and the documents of each beneficial owner, as the list above shows.
  3. Check that the passport number or the EBS of the legal representative in the APR register matches the eID login.
  4. Prepare the entry in the register and upload the documents.
  5. Sign the entry. The legal representative signs with a qualified electronic certificate issued in Serbia or with a cloud signature.
  6. Keep the data and the documents for 10 years.

How does the annual check work?

The company checks its data within 1 year of the last recording or confirmation. Then it confirms the data within a further 30 days. For a company that uploaded its documents in the alignment window of 2025, APR counts that upload as the first verification. The year runs from the day of the upload, unless the beneficial owner changed.

What happens when a company misses a deadline?

APR puts a company that did not record its beneficial owner, or did not upload the documents in time, on a public list. The list makes the company high risk under the AML Law. APR and the supervisors check the deadlines, and they can start misdemeanour proceedings.

The UBO Act sets these penalties:

  • 500,000 to 2,000,000 RSD for the company, and 50,000 to 150,000 RSD for the responsible person (Art. 19). The fine applies to a late entry, to missing documents and to wrong data. It also applies to a missed annual confirmation, to records not kept, and to data not given to a supervisor in time.
  • The same fines for wrong data in an electronic founding (Art. 20).
  • A ban on the activity or on the job for 6 months to 3 years (Art. 22).
  • Prison from 6 months to 5 years for the concealment of the beneficial owner, which is a crime (Art. 18).

What does the entry cost?

The APR fee decision lists no fee for the entry in the register. It lists only the extract, at 2,500 RSD, and the certificate, at 1,500 RSD per beneficial owner.

How RNDM handles this

Run your business

We enter the beneficial owners of a new company as part of company formation. For a company that already operates, we keep the entry up to date. We prepare each change and the annual confirmation, upload the documents, and your legal representative signs. The 30-day deadlines and the annual check go into the deadline calendar of your company.

You can order a UBO entry or change as a single service. Our Run tier includes the corporate records and the deadlines.

We handle this: see Company administration Contact usSee the tiers

Sources

The law texts are the consolidated versions on paragraf.rs, and APR publishes its own consolidated copy of the UBO Act. The AML Law was read on 2026-10-21, and all other pages on 2026-10-17.

This guide gives general information as of the date below. Your case may differ, so ask us before you act.
Last reviewed on . RNDM DOO is responsible for this page.

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