The Ministry of Economy of the Republic of Serbia adopted on October 13th the Guide for Recording the Beneficial Owner of a Registered Entity in the Central Registry (“Guide”).

The Guide clarifies the application of the Law on the Central Registry of Beneficial Owners (“Official Gazette of RS”, Nos. 19/25, 51/25, 60/25) (“Law”), which has been in force since October 1, 2025.

Although, by its nature, the Guide should clarify the procedures and rules established by the Law, it appears that the Guide goes beyond this, further tightening certain obligations or their aspects. Additionally, in practice, there have been observed deviations from the Law on Prevention of Money Laundering and Terrorism Financing as well as from the guidelines for the application of this regulation issued by the Ministry of Finance.

In our previous article, we covered the novelties introduced by the Law (obliged entities, grounds for registration, etc.). This article focuses on practical instructions regarding the obligation to upload documentation, noting that the deadline for fulfilling this obligation is Monday, December 1, 2025.

General Instructions:

• Uploads must be performed exclusively electronically using a qualified electronic certificate of an authorized person.
• Documents must be uploaded in PDF format (it is not required that they be previously signed with a qualified electronic signature).
• Documents must be submitted in their entirety, but parts irrelevant for determining the beneficial owner may exceptionally be redacted.
• Documents must be submitted as originals or certified copies. If foreign documents are submitted, they must be translated into Serbian by a court-certified translator.
• At the time of uploading, documents must not be older than six months from the date of issue.
• Depending on the type of document and the issuing country, it may be necessary for the document to be accompanied by an apostille.

Documents to Be Uploaded in the Central Registry

All documents based on which the beneficial owner may be determined must be submitted, including:

• Extracts from the competent register. If all data on the beneficial owner cannot be obtained from the extract, the registered entity may provide data from other business documentation submitted by the representative or proxy of a foreign person (e.g., members’ agreement, founding act, etc.). Documentation must be submitted for all companies in the upward ownership chain, up to and including the parent company.
• For companies whose members are natural persons who are also the beneficial owners, the founding act must be uploaded. Regarding this obligation, it is necessary to verify whether the founding act is consistent with the registered data of the entity, and if not, before uploading, a new founding act must be aligned and registered with the Business Registers Agency.
• If the parent company is publicly listed, a certificate or other proof of listing must be provided. If the document cannot be obtained, a statement from the legal representative, notarized by a public notary, must be submitted confirming that the company is publicly listed.
• When a foreigner is registered as the beneficial owner, a copy of a valid passport or a copy of a valid foreign identity card must be submitted. In this case, certified copies or translations are not required (a simple copy is sufficient). For domestic nationals, it is not necessary to upload an identity document.

Grounds of Predominant Influence

When the beneficial owner is determined based on predominant influence over management and decision-making, in addition to members’ agreements and the founding act, the Central Registry may also contain:

• A certified statement of the representative; and
• Other evidence confirming such influence.

Grounds of Providing Funds (Financial Influence)

When the beneficial owner is determined based on the fact that a natural person directly or indirectly provides funds and thereby significantly influences the decisions of management bodies, the documentation may include:

• Bank statements;
• Fiduciary agreements; and
• Other evidence of transactions, as well as a certified statement of the representative regarding the actual ownership.

Codes of Grounds and Method of Registration

The Guide refers to the Regulation on the Content of the Central Registry for the Implementation of Beneficial Owner Registration (Official Gazette of RS No. 83/25) (“Regulation”), which prescribes codes and sub-codes for grounds of acquiring the status of beneficial owner. The Regulation largely relies on the solutions of the previously valid subordinate legislation, with minor technical adaptations regarding foundations and endowments.

The Guide also includes steps for registering these grounds in the Central Registry.

This article is to be considered as exclusively informative, with no intention to provide legal advice. If you should need additional information, please contact us directly.