The new Law on Central Records of Beneficial Owners (“New Law”) has entered into force on 14th of March 2025, while its application was initially prescribed for September 2026. Contrary to the usual practice of postponing the application of new regulations, the amendments to the New Law adopted in June 2025 accelerated its application, so that the New Law became applicable as of 1st of October 2025.

I. Reasons for Adoption of the New Law

  • Alignment with FATF (Financial Action Task Force) Recommendation 24, which requires countries to assess the risks of misuse of legal entities for money laundering or terrorist financing and take measures to prevent such misuse, whereby countries should ensure that adequate, accurate and up-to-date information on beneficial ownership and control of legal entities is available and can be accessed promptly and efficiently by the competent authorities, either through central records of beneficial owners or through an alternative mechanism.
  • Alignment with FATF (Financial Action Task Force) Recommendation 25, which requires countries to take measures to prevent the misuse of trusts for money laundering or terrorist financing, whereby countries should ensure that adequate, accurate and up-to-date information on trusts is available and can be accessed promptly and efficiently by the competent authorities.
  • Improvement of the existing framework for detecting and preventing money laundering and terrorist financing, as prescribed by the Law on Prevention of Money Laundering and Terrorist Financing.

II. Key Novelties Introduced by the New Law

Extension of Scope to Trusts

In addition to the previously prescribed entities that are subjects to registration (companies, cooperatives, branches of foreign companies, business and other associations, foundations and endowments, institutions, representative offices of foreign legal entities, associations, foundations, and endowments), the New Law introduces the obligation to register beneficial owners also for:

  1. trusts that are managed from the Republic of Serbia, or trusts whose management is located outside of the Republic of Serbia, provided that the trustee, acting on behalf of the trust, enters into a business, professional, or commercial relationship or carries out transactions, including cash transactions, with legal entities or individuals in the territory of the Republic of Serbia;

and

  1. legal arrangements similar to trusts, which are managed from the Republic of Serbia or have management outside of the Republic of Serbia, where a person equivalent to a trustee establishes a business, professional, or commercial relationship, or carries out transactions, including cash transactions, with legal entities or individuals in the Republic of Serbia.

Obligation to Submit Supporting Documentation

The New Law establishes an obligation to upload documents on the basis of which the beneficial owners have been identified, both at the time of registration of beneficial owners and upon any subsequent changes regarding the beneficial owners. If the beneficial owner is a foreign national, it is additionally required to upload a copy of the foreign national’s passport or ID card.

Extension of Deadline for Registration of Beneficial Owners

The deadline for registration of beneficial owners as prescribed by the New Law is 30 days from the date on which the basis for such registration occurs. This extension, compared to the previously applicable 15-day deadline, should allow sufficient time to collect the necessary data and documentation required for registration of beneficial owners.

List of Non-Compliant Entities

The New Law prescribes that the Serbian Business Registers Agency („SBRA”) will publish on its website a list of entities that fail to record beneficial owners within 30 days from the date of incorporation, as well as existing entities that have failed to register data on beneficial owners prior to the date of application of the New Law. This list will also include data on existing entities that fail to upload the supporting documentation based on which beneficial owners were determined within 60 days from the date of application of the New Law.

The SBRA is required to update the respective list every 48 hours, and entities listed therein will be considered as high-risk entities according to the Law on Prevention of Money Laundering and Terrorist Financing.

Obligation of Annual Verification of Data on Beneficial Owners

Existing entities are required to verify the accuracy and up-to-date of recorded data on beneficial owners within one year from the last registration of data on beneficial owners, or within one year from the last verification of accuracy and up-to-date of recorded data on beneficial owners, and then to confirm the accuracy and up-to-date of recorded data on beneficial owners within additional 30 days from such verification.

Stricter Sanctions

The definition of the previously prescribed criminal offence has been amended due to introducing trust as a subject to registration, whereby the range of imprisonment has been increased from the previously prescribed three months to five years, to now applicable six months to five years.

Misdemeanor sanctions include the same monetary fines in the range of RSD 500,000 to RSD 2,000,000 for legal entities, and RSD 50,000 to RSD 150,000 for responsible person within the legal entity, but the New Law provides for the possibility of imposing protective measures, i.e. prohibition on conducting certain activities for the legal entity and prohibition on performing specific duties in the legal entity for the responsible person within the legal entity. These protective measures may be imposed for a period ranging from six months to three years, starting from the day the judgment becomes enforceable.

III. Alignment with the New Law

Existing entities are required to align with the provisions of the New Law within 60 days starting from the date of its application. This means that all existing entities are obliged to upload documents based on which the beneficial owner is identified no later than 30th of November 2025, and in cases where the beneficial owner is a foreign national it is additionally required to upload a copy of the foreign national’s passport or ID card.