Important Reminder for Registered Entities: Annual Review and Confirmation of Beneficial Ownership Information

As of 1 October 2026, registered entities are legally required to regularly review their beneficial ownership information to ensure that it remains accurate and up to date.

Deadlines for Reviewing and Updating Beneficial Ownership Information

A. Annual Review of Beneficial Ownership Information

• Beneficial ownership information must be reviewed annually, within one year of the date on which it was last recorded or confirmed.

• The annual review deadline is therefore entity-specific and depends on the date of the most recent registration or confirmation.

• Entities that completed their initial verification and confirmation during the compliance period from 1 October to 1 December 2025, and have made no subsequent updates, must complete their next review no later than one year from the date of that initial confirmation.

Examples:

• Change in information: If a change occurred on 10 February 2026, the updated information must be recorded by 11 March 2026.

• Annual review: If the information was last confirmed on 15 November 2025, the next confirmation is due by 15 November 2026. The confirmation may be completed during the 30-day period preceding that deadline.

Special cases:

• Following any change to beneficial ownership information, the deadline for the next annual review is calculated from the date on which the change was recorded.

• If there have been no changes, the entity must confirm that the existing information remains accurate within 30 days following the annual review deadline, via the Serbian Business Registers Agency portal.

B. Deadline for Recording Changes

Any change to beneficial ownership information must be recorded within 30 days of the date on which the change occurs.

Entities should therefore not wait until the annual review to update their information. Each change must be recorded within the applicable 30-day statutory deadline.

How to Confirm Beneficial Ownership Information

To access the portal and confirm the accuracy of beneficial ownership information, the entity’s legal representative should have:

• an account on the eID.gov.rs portal and an account in the Serbian Business Registers Agency system (REID);

• a qualified electronic certificate issued in Serbia or ConsentID; and

• the NEXU application installed for electronic signing, or access to cloud-based electronic signing.

Important Compliance Notice

Failure to comply with these obligations may result in misdemeanor liability and the entity being publicly listed as non-compliant with its statutory obligations.

Disclaimer: This information is provided for general informational purposes only and does not constitute legal advice.