Further to our previous newsfeed on this, the Cyprus Registrar of Companies (the “Registrar”) announced that as from 14 November 2023 the final solution of the electronic system of the Register of Beneficial Owners of Corporate and Other Legal Entities (UBO Register) has entered in to implementation.
Implementation will take place gradually as follows.
Period A: 14 November 2023 to 31 December 2023
During this period all companies that have been incorporated or registered according to the Cyprus Companies’ Law, the European public limited liability companies (SE) and the Partnerships (the “Entities”) as well as their officers/partners, will need to verify the information submitted to the interim solution of the Register or update it with any changes. No penalties will be imposed during this period.
Period B: 1 January 2024 to 29 February 2024
On 1 January 2024, the imposition of penalties in connection with any Entities that have not verified or updated the information as required during Period A will commence.
Notwithstanding the criminal liability or prosecution of any person, in the event of failure to comply, an Entity and each of its officers/partners shall be subject to a fine of €200 and a further fine of €100 for each day of continuation of the violation with a maximum charge of €20,000.
Period C: From 1 March 2024 onwards
All features of the final solution will be in effect.
This means that all changes to the information reported with the Register by an Entity need to be updated within 14 days from the time such Entity or its officers/partners become aware of the changes.
Furthermore, Entities are required to verify the information submitted with the Register annually, during the month of December. The annual verification process is mandatory irrespective of whether any changes have taken place during the year or not.
It is noted that an officer/partner of an Entity shall not be subject to a fine if he/she had exercised due diligence to comply with the provisions of the legislation and the violation is not due to any act or omission or negligence on his/her part.
