DOO beneficial owners: what to check after the APR register reform

The new procedure has applied since 1 October 2025. Existing organisations were required to bring their information into compliance by 1 December 2025: identify the beneficial owner again using the prescribed criteria and upload the documents supporting that conclusion. This verification starts the one-year period until the next check, provided the beneficial owner does not change in the meantime. If there is a change, the period starts again. Autumn 2026 is therefore important for companies that completed the initial procedure in autumn 2025. This follows from the APR instructions.

The law does not apply to sole traders, known as preduzetnik. This is specifically explained in APR’s official answers. The first step is therefore to identify the business’s legal form, and only then draw up a list of actions.

Our practical conclusion is that company registration documents and the evidence establishing who actually controls the company should be maintained as related but separate parts of the corporate file. This is especially relevant where a Serbian DOO is owned by a foreign company. For an internal review, it helps to draw the entire ownership chain and place the supporting document beside each link.

For example, if a foreign shareholder is listed in the Serbian register, its name alone does not answer the question ‘who owns our DOO?’ The team preparing the package needs to understand which individuals are behind the structure and which documents support that conclusion. This is a practical approach to preparation, not a universal determination of a particular beneficial owner.

• The latest confirmation that information was entered or verified in the register.
• A copy of the uploaded document package and a list of the files.
• Current information on shareholders, ownership interests and structural changes.
• Details of the legal representative and current electronic access.
• Information about new passports, surname changes or other changes affecting shareholders and the director.

This is a starting checklist for a review, not a statement that every client will need all these documents. The company’s structure determines the package. A simple case involving one individual and an international group require different levels of preparation.

Step one: reconstruct the timeline. Find the date of the latest verification and distinguish it from the date the DOO was established. Do not calculate the deadline from memory or rely only on the business’s registration date.

Step two: check the facts. Compare the company’s internal documents with what has actually been entered. If the structure changed during the year, provide the specialist with the full sequence of changes, rather than just the latest contract.

Step three: check the ability to sign. Ensure that the director can log in to the relevant system and complete the procedure. For a foreign director, consistency between identifiers in registers and electronic documents matters; APR draws attention to this point.

Step four: record the result. Save confirmation of completion and set a reminder for the person responsible for the next check. A draft application, an email to a contractor and finally registered information are different stages of the work.

Do not substitute a false submission date or repeat old information merely to complete the form. A more useful approach is to establish the current state of the entry, gather the evidence for correct information and agree how to rectify it. For a complex structure, pay particular attention to consistency between documents in Russian, Serbian and other languages.

For the owner, the outcome should be clear: which obligation applies to the company, what package has been prepared, who signs the application and what confirms completion. This approach reduces reliance on scattered correspondence with contractors. Keep the final package in an archive accessible to the company, with a clear date.

We will review the corporate situation, identify missing information and organise document preparation with relevant specialists. If shareholders, the director or the business structure are changing at the same time, we will coordinate these steps in a single plan. Contact us for DOO support in Serbia — we will agree the scope and price before starting.

• APR: instructions for the Central Register of Beneficial Owners
• APR: questions and answers on beneficial owners