Serbia has taken a decisive step toward strengthening corporate transparency and aligning with international standards in the fight against money laundering and terrorist financing. The recently adopted Central Records of Ultimate Beneficial Owners Act (“UBO Act”) has become applicable as of October 1, 2025 introducing a range of new obligations for companies and other registered entities.
Entities already operating in Serbia must ensure full compliance by 30 November 2025, or risk finding themselves on the newly established public list of non-compliant entities, a place no business wants to be.
The Act now clearly requires registration of all individuals who meet the legal criteria for beneficial ownership. This is a significant shift from the previous Act, which was less explicit. In practice, this means that companies may need to disclose multiple individuals who either:
Entities must now upload documents proving the identity and status of beneficial owners directly to the Central Records maintained by the Serbian Business Registers Agency (SBRA). Previously, such documentation was only kept internally and typically provided to banks during account opening. This change increases transparency but also raises the importance of precise and accurate recordkeeping.
The deadline for initial UBO registration has been extended from 15 to 30 days. This allows more time to gather documentation. However, this should not be mistaken for an excuse for delay, especially given the upcoming verification and compliance requirements.
All registered entities will now be required to verify their UBO data every 12 months from the date of the last registration. This creates an ongoing compliance cycle and necessitates regular internal reviews.
Financial institutions, accountants, tax advisors, real estate brokers, and other regulated entities must now cross-check UBO data in the Central Records against their own Know Your Customer (KYC) findings. If discrepancies are found, the regulated entity must:
If the discrepancy is not resolved within 30 days, the supervisory authority must be notified and will act within three days. This could trigger inspections and sanctions.
Perhaps the most reputationally damaging change is the introduction of a publicly available non-compliance list. Regulators will publicly name and flag as “high-risk” any entities that fail to register UBO data or upload documentation within 60 days under Serbia’s AML framework. This can have immediate practical consequences, including increased scrutiny from banks and business partners.
The UBO Act now extends the registration obligation, to also include trust and trust-like arrangements managed from Serbia or otherwise falling under Serbian jurisdiction. This significantly broadens the range of entities subject to the Act and, for the first time, incorporates into domestic law business structures previously unregulated. In addition to incorporation and changes in ownership, registration is now also triggered by the management of a trust from Serbia or by trust-related activities carried out by trustees within the country.
The UBO Act significantly raises penalties, with fines for companies ranging from RSD 500,000 to RSD 2 million for various breaches of registration and reporting obligations. Non-compliant entities face monetary sanctions and placement on a public list, creating serious reputational risks. Together, these measures provide a strong incentive for companies to comply promptly and accurately.
The Ministry of Economy has published two rulebooks in the Official Gazette of the Republic of Serbia No. 83/2025. These provide detailed guidance for the implementation of the new Act. These bylaws enable companies to achieve compliance with the new UBO Act.
Also, the SBRA has launched a new enhanced version of the Central Records of Ultimate Beneficial Owners Portal, for registered entities and the wider public.
The new UBO Act sends a clear message: corporate transparency is no longer optional. With the introduction of a public non-compliance list, the reputational risk is as significant as the financial penalties. Businesses should act early, gather the necessary documents, and put systems in place for ongoing compliance. Non-compliant entities risk fines and reputational damage under Serbia’s anti-money laundering regime.
To access a detailed overview of the UBO Act, click here.
Authors: Marko Jović, Živko Simijonović
