As of 1 October 2026, the first annual deadlines will begin to fall due for the review of beneficial ownership information recorded in the Central Records of Beneficial Owners maintained by the Serbian Business Registers Agency (“SBRA”).

Under the Law on the Central Records of Beneficial Owners, registered entities are required to review the accuracy and up-to-dateness of their beneficial ownership information within one year from the date of the most recent registration or verification of such information. Following this review, the entity has a further 30 days to confirm the accuracy and up-to-dateness of the recorded information through the SBRA portal.

Existing registered entities carried out their first verification under the new Law between 1 October and 1 December 2025. Accordingly, from 1 October 2026 onwards, the first one-year periods will begin to expire for entities that completed their verification at the beginning of that period.

Importantly, there is no single deadline applicable to all entities. The relevant deadline depends on the date of the entity’s most recent registration or verification. For example, if the last verification was completed on 15 October 2025, the annual review must be completed by 15 October 2026, followed by a further 30-day period for confirmation of the accuracy and up-to-dateness of the information.

If there have been no changes since the last verification, the existing information should be reviewed and confirmed. If there have been changes in the ownership structure, members of the company’s corporate bodies or other circumstances relevant to determining the beneficial owner, it should also be checked whether the relevant changes have been duly registered and the supporting documentation updated. Such changes are subject to a separate 30-day registration deadline.

Failure to complete the required verification within the statutory deadline constitutes a misdemeanor and may result in a fine of RSD 500,000 to RSD 2,000,000 for the legal entity and RSD 50,000 to RSD 150,000 for the responsible person.