Legal Obligation to Disclose Beneficial Ownership Takes Effect

Thanks to the Act on Registration of Beneficial Owners, which has been in force since 2018, all companies and other legal entities in Serbia are required to clearly indicate who their beneficial owners are.

The act is part of a broader fight against money laundering and terrorist financing, as well as an attempt to increase transparency in economic processes.

Who is a “beneficial owner” and why is it important?
The act clearly defines who is considered a beneficial owner. It is a natural person who, directly or through other companies and structures, owns at least 25% of the property, votes at meetings or otherwise controls the company.

If such an owner cannot be identified, the legal representative is indicated as the beneficial owner.
The significance of this registration is multifaceted: it allows state authorities to track financial flows, and it also identifies the real decision-makers in companies that could previously be hidden behind complex ownership structures, often located abroad.

Registration in the APR is public and mandatory
The Central Register of Actual Owners is maintained by the Business Registration Agency (BRA). All legal entities, from business companies and cooperatives to foundations and associations, are required to report their actual owners via the APR electronic platform.
The data is entered quickly, but the legal representative is responsible for its accuracy.
Notification is mandatory both when establishing a company and at each change in the ownership structure.

Who is required to report and who is not?
The law applies to almost all legal forms in Serbia, with the exception of political parties, trade unions, government agencies and some specific entities that by their nature do not have actual owners.

Fines for concealing ownership – up to 2 million dinars
There are serious sanctions for those who ignore the law. Legal entities face fines from 500,000 to 2,000,000 dinars, and responsible persons in companies – from 50,000 to 150,000 dinars.

In addition, in the case of persistent non-cooperation, the APR may even temporarily prohibit the operation.

The law is here to stay
Although it was initially received with a certain amount of skepticism, today the law is an important part of the regulatory system of Serbia.

In addition to fulfilling international obligations, it also protects the companies themselves – ensuring more transparent business and a healthier market environment.

In an era when any information can be used for harm, but at the same time greater responsibility is required in business, knowing who is behind the company is not only a legal obligation, but also a matter of trust.