Annual Verification of Beneficial Owners: What Needs to Be Done and by When?
September 30, 2026
The first deadlines for the annual verification of beneficial ownership information recorded in the Central Register of Beneficial Owners maintained by the Serbian Business Registers Agency (“SBRA”) begin to fall due in October 2026.
This obligation was introduced by the 2025 Law on the Central Register of Beneficial Owners and applies to all registered entities subject to beneficial ownership registration requirements, including companies, associations, foundations, and other entities covered by the Law.
Annual verification is mandatory even if there have been no changes to the beneficial owners or ownership structure.
When Is the Annual Verification Deadline?
Registered entities are required to review and confirm the accuracy and currency of their registered beneficial ownership information once a year, within 30 days following the first anniversary of the most recent registration or verification of that information.
For entities that complied with the new Law between October 1 and December 1, 2025, the deadline is calculated from the date on which they registered their beneficial ownership information and uploaded the relevant supporting documentation.
This means that the deadline is not the same for all entities, but depends on the date of their most recent registration or verification.
For example, if a company registered its beneficial ownership information on October 15, 2025, it must complete its annual verification by November 14, 2026.
What Needs to Be Done?
Registered entities should review their beneficial ownership information recorded in the Central Register to ensure that it is accurate and up to date, and verify that the uploaded supporting documentation reflects the current circumstances.
Depending on the outcome of this review, the following steps are required:
- If there have been no changes – confirm the accuracy and currency of the existing information through the SBRA portal, without registering the same information again.
- If changes have occurred – register the relevant changes and, where necessary, upload new supporting documentation establishing the beneficial owner’s status.
It is important to note that registering a change in beneficial ownership is a separate statutory obligation that must be fulfilled within the prescribed period following the change. Annual verification does not replace this obligation or provide grounds for delaying the registration of changes.
The annual verification process is completed electronically through the SBRA portal, using the legal representative’s qualified electronic signature.
Why Is It Important to Meet the Deadline?
Annual verification is a separate statutory obligation, meaning that the absence of changes in beneficial ownership does not exempt a registered entity from confirming the accuracy and currency of its registered information.
Failure to meet the prescribed deadline may result in misdemeanor liability.
Registered entities should therefore check the date of their most recent registration or verification and complete the required procedure on time, even if their beneficial ownership information has remained unchanged.
This article is for informational purposes only and does not constitute legal advice. Should you require any further information, please feel free to contact us.