From 1^st October 2025, the Law on the Central Register of Beneficial Owners (“Official Gazette of the Republic of Serbia”, No. 19/2025, 51/2025 and 60/2025 – correction; “Law”) will come into effect and in this regard, it is particularly important to highlight the provision of Article 6, paragraph 4 of the Law.

The cited article introduces a novelty compared to the previously applicable law, concerning the contents of the Central Register. The Central Register now also includes the documents on the basis of which the beneficial owner has been identified, as well as a copy of a passport or foreign ID card if a foreign national is registered as a beneficial owner.

Thus, in addition to the existing obligation to register the beneficial owner through the SBRA’s electronic filing system (“SBRA’s Portal”) by indicating the basis for acquiring the status of a beneficial owner, the Law introduces a new requirement – to upload the documentation on which the beneficial ownership is based.

Considering this legislative development, the following practical questions may arise:

• Is it necessary to upload documentation already held by the SBRA (for example, an extract from the SBRA’s register of business entities)?
• Must documents issued by foreign authorities be properly legalized (either by obtaining an apostille stamp or through the process of “full legalization”) and translated into Serbian?

Until precise clarifications on the above matters are issued by the competent authorities, the most practical and secure approach seems to be uploading the same documents via the SBRA’s Portal that were previously submitted to the commercial bank as part of the “KYC procedure.”

Finally, we would like to emphasize that all companies, as well as other Registered Entities (as that term is defined by the Law), must comply with the new Law within 60 days from the date it comes into force, i.e., no later than 30^th November 2025.

The procedure for uploading the aforementioned documents will operate on the same principle as the current procedure for registering beneficial owners. In other words, the uploading of documents can only be performed by the legal representative of the Registered Entity, using their account on the SBRA’s Portal and their qualified electronic certificate.