The Serbian Business Registers Agency (APR) has announced that, as of 1 October 2026, registered entities must begin performing the annual verification of the accuracy and currency of their beneficial ownership data. The obligation stems from Article 9 of the Law on the Central Records of Beneficial Owners (Official Gazette of the Republic of Serbia, Nos. 19/2025, 51/2025 and 60/2025 – corr.), which has applied since 1 October 2025 and further aligns Serbia’s beneficial ownership framework with EU anti-money laundering standards.
For foreign-owned companies and branches in Serbia, the new requirement is straightforward in substance but can be demanding in practice, particularly where the legal representative resides abroad.
Every entity registered with the APR must, once a year, verify that the beneficial ownership data recorded in the Central Records of Beneficial Owners remains accurate and up to date. The verification is carried out electronically through the APR portal.
The annual obligation arises one year from the date of the last registration of beneficial ownership data, or from the date of the last confirmation of that data. From that point, the entity has a further 30 days to complete the confirmation.
The APR has clarified two points that determine the start date for most companies:
- Companies that uploaded supporting documents during the transition period under the new Law (1 October – 1 December 2025) are deemed to have completed their first verification at that time. Their one-year period runs from that date.
- Companies that registered new data or updated their documentation after the transition period calculate the one-year period from the date of that latest registration.
In practice, this means that 1 October 2026 is not a single deadline for all companies. Each entity has its own anniversary date, and most will fall between October and December 2026. Companies should check the date of their last entry in the Central Records now rather than wait for the anniversary to pass.
Where neither the beneficial owner nor the complex ownership structure reflected in the uploaded documentation has changed, the obligation is fulfilled simply by confirming the accuracy and currency of the recorded data through the APR portal within the 30-day window.
Where there has been a change in the beneficial owner, or in the documentation proving that a particular person holds that status, the entity must register the new data and/or upload the relevant documentation.
Foreign groups should pay particular attention here. A change further up the ownership chain, such as a restructuring at the level of a foreign parent or holding company, may affect the documentation on file even where the Serbian company’s direct shareholder remains the same. A simple confirmation is not appropriate in that case.
Many foreign-owned companies in Serbia are managed by directors based abroad who do not hold a Serbian qualified electronic certificate or an eID.gov.rs account. Obtaining these credentials takes time, and the 30-day window leaves little room for delay. Companies in this position should review their access arrangements well before their anniversary date.
The information contained in this document does not constitute legal advice on any specific issue and is provided solely for general informational purposes.
