The Serbian Business Registers Agency (Agencija za privredne registre, APR) has reminded companies on its website that annual beneficial ownership verification becomes mandatory on 1 October 2026. Every registered legal entity must now confirm once a year that the data about its beneficial owners in the Central Records of Beneficial Owners is accurate and up to date.
The obligation applies only to legal entities, such as limited liability companies (d.o.o.). Sole proprietors (preduzetnici) do not have to register beneficial owners, so this obligation does not apply to them.
What is a beneficial owner? A beneficial owner is the natural person who ultimately owns or controls a company, directly or through other legal entities. Serbian law requires every registered legal entity to record its beneficial owners in a central register kept by the APR.
The obligation comes from Article 9 of the Serbian Law on the Central Records of Beneficial Owners (Zakon o Centralnoj evidenciji stvarnih vlasnika). Below we explain what it means for your company and how to work out your deadline.
What happened in autumn 2025, and what needs to be done now?
A new Law on the Central Records of Beneficial Owners was adopted, and all registered legal entities had to bring their records in line with it for the first time between 1 October 2025 and 1 December 2025.
During that period, companies:
- uploaded documents proving who their beneficial owners are;
- checked whether the data in the register was accurate and complete and corrected it where needed; and
- confirmed the registered data.
Once confirmed, the beneficial ownership data became publicly available in a separate online register kept by the APR.
The APR’s position is that by uploading these documents, companies also carried out their first verification of beneficial ownership data. In this article we call this process the initial verification and document upload.
The Law also requires legal entities to check their data and documents in the register once a year after that. Each year they either confirm that the data is still accurate or make the necessary changes.
If your company completed the initial verification and document upload in October or November 2025, you now need to carry out your first annual verification. This becomes possible from 1 October 2026. Your exact deadline depends on your situation, as explained below.
When is your first annual beneficial ownership verification due?
The one-year period is counted from whichever of these two events happened more recently:
- the last time beneficial ownership data was registered; or
- the last time the data was confirmed as accurate and up to date.
For this reason, your deadline may differ from other companies’ deadlines. Find your situation below.
Situation 1: You completed the initial verification and nothing has changed since
If your company uploaded its documents between 1 October and 1 December 2025 and its ownership structure has not changed at all since then, your obligation is simple.
What to do: use the APR Portal to confirm that the data in the register is correct. You do not need to upload the documents again.
Deadline: no later than 30 days after one year has passed since your initial verification.
Example: If you uploaded your documents on 20 October 2025, one year ends on 20 October 2026. You then have another 30 days, so you must submit your confirmation by 19 November 2026 at the latest.
A change of beneficial owner is not the only kind of change that counts. Any change in a complex ownership structure shown in the documents you uploaded also counts, for example a change in an intermediate holding company. If anything of this kind has changed, see Situation 3.
Situation 2: Your ownership structure changed and you reported it on time
Suppose your company’s ownership structure changed during the past year, and you registered the change and uploaded new documents within 30 days. In that case, your deadline is not counted from the initial verification.
Deadline: the one-year period runs from the date you registered the change and uploaded the documents. After that, you have another 30 days to confirm the data.
Example: You completed the initial verification on 15 November 2025. Later your beneficial owner changed, and you registered the change on 10 March 2026. Your new deadline is counted from 10 March 2026, so you must submit your confirmation within 30 days after 10 March 2027. It is not counted from November 2025.
What to do: if nothing has changed since you last registered data, simply confirm within that period that the data is correct.
Situation 3: You discover during verification that there have been changes
Some companies will only notice while checking their data that their beneficial owners or ownership structure have changed without the change being reported. In that case, do not confirm the existing data, because it is no longer accurate.
What to do:
- register the changes in the Central Records of Beneficial Owners;
- upload new documents that reflect the current situation;
- in future, report every change of beneficial owner on time.
Important: a change of beneficial owner must be reported within 30 days of the date the change occurred. Do not wait for the next annual verification to report it.
Summary
| Your situation | What you do | The one-year period runs from |
|---|---|---|
| Initial verification, no changes since | Confirm the data only | The date of the initial verification |
| Change reported within 30 days | Confirm the data (if there have been no further changes) | The date the change was registered |
| Change you are only now discovering | Register the change and upload new documents | The date of this new registration |
In every case, beneficial ownership verification must be completed within 30 days after the one-year period ends.
Beneficial ownership verification on the APR Portal: what you need?
The confirmation must be made by the company’s legal representative, usually the director. They will need:
- an account on the eID.gov.rs portal (the Serbian government’s electronic identification portal) and an account on the APR system (REID);
- a qualified electronic certificate (electronic signature) issued by a certification body in the Republic of Serbia, or ConsentID;
- an installed smart card reader and the NEXU application for electronic signing. Alternatively, cloud-based signing can be used.
Note for foreign directors: The APR requires an electronic signature issued in Serbia or ConsentID, so electronic signatures issued in other countries cannot be used for this purpose. If your legal representative is a foreign national and does not yet have a Serbian qualified certificate, contact us well in advance to check what they will need to obtain access.
Tip: check early that your legal representative has a valid electronic certificate and active accounts, so that technical problems do not put your deadline at risk.
Why meeting the deadline matters
The APR urges all registered entities to meet their obligations within the statutory deadlines to avoid misdemeanour proceedings, which are minor-offence proceedings under Serbian law that can result in fines for the company and its responsible person. The annual confirmation takes only a few minutes, but missing the deadline can have serious consequences.
For our clients: we keep track of your deadline
Last year, many clients engaged us to help with their initial beneficial ownership registration and document upload. If you are one of them, you do not need to track the deadline yourself.
As your accountants, we will:
- calculate your deadline for the annual verification, based on the date of your initial verification or of your most recent registered change;
- notify you in good time when the verification is due;
- offer help with the verification as an additional service, if you would like us to help you confirm the data, register changes or upload new documents.
To calculate your deadline correctly, please tell us about any change in your ownership structure since the initial verification that you have not yet discussed with us.
Not sure which situation applies to your company or when your deadline is? If you are our client, we will contact you in good time. If you are not, or if you would like to check your deadline right away, write to us and we will help you complete the verification on time.
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