New Law on the Central Records of Beneficial Owners – Effective as of 1^st October, 2025

The Law on the Central Records of Beneficial Owners (“Official Gazette of the Republic of Serbia”, Nos. 19/2025, 51/2025 and 60/2025 – correction) entered into force on 14^th March, 2025, while its application is set to begin on 1^st October, 2025.

This Law provides a 60-day period during which existing registered entities are required to align their operations with the new provisions. The Law applies to business entities (excluding public joint-stock companies), cooperatives, associations, foundations, endowments, branches of foreign business entities, institutions, representative offices of foreign business entities, as well as trusts and similar legal arrangements managed from Serbia (which represents a novelty and an expansion compared to the previous legal framework).

The most significant new features include:

• The obligation to conduct an annual review and update of information on the ultimate beneficial owner;
• The mandatory submission of documentation proving the basis for acquiring the status of beneficial owner (as well as the obligation to retain such documentation);
• The introduction of a new legal concept – “trust” – and the expansion of the law’s scope;
• The possibility for an individual recorded as an ultimate beneficial owner to file a lawsuit in order to determine that they are not, in fact, the beneficial owner;
• Stricter oversight and control, as well as significant monetary fines and other sanctions for non-compliance with legal obligations.

In light of the above, we emphasize that, starting from 1^st October, 2025, and no later than 30^th November, 2025, legal entities are required to comply with the two key novelties introduced by the new Law:

1. Verifying the accuracy and updating of the recorded data on the beneficial owner, i.e., confirming the accuracy of such data;
2. Submitting documentation that proves the legal basis for acquiring the status of the beneficial owner, as well as providing a copy of the beneficial owner’s ID/passport, and ensuring its retention in the company’s archives.

In the coming period, it is expected that bylaws and/or official guidelines will be adopted by the competent authorities, which will further regulate certain issues and facilitate the implementation of the Law in practice. It appears that certain practical details in this area will become clearer gradually following the commencement of the Law’s application.

Should you require any assistance on this matter or have additional questions, please do not hesitate to contact us.