Cyprus UBO Register – Action Required: Annual Confirmation of Information

Further to our previous legal update regarding the Cyprus Register of Beneficial Owners (the “UBO Register”) (Cyprus UBO Register – A Practical Guide), we wish to inform our clients that action is currently required for the confirmation of the accuracy of the information previously submitted to the UBO Register.

As from 1 October 2024 and until 31 December 2024, all companies incorporated or registered under the Companies Law, Cap. 113, all European public limited liability companies (SE), and all partnerships which fall within the scope of the UBO Register, must access the system and re-confirm the details of their ultimate beneficial owners, senior management officials or due diligence actions taken in lieu of disclosure, as applicable.

Failure to comply with this reporting obligation by the 31 December 2024 deadline will result in the automatic imposition of fines. A fine of EUR 200 will be imposed on the first day of non-compliance, with an additional fine of EUR 100 being imposed for each day of continued default, up to a maximum total amount of EUR 20,000. It is important to note that any applicable fines will be imposed separately and in full against each entity in default, as well as against each of its officers, unless the latter can demonstrate that they exercised due diligence to comply with their reporting obligations and the failure to do so is not due to any act, omission, or negligence on their part.

We reiterate that, as an ongoing reporting obligation which applies separately and irrespectively of the annual confirmation obligation above, any changes to beneficial ownership details previously submitted must be notified to the UBO Register within 45 days from the date on which the relevant change became known to the entity involved.

Our team remains available to advise further on the steps which should be taken for compliance with the above requirements and to provide any relevant assistance required.