Cyprus UBO Register: Ongoing Compliance Requirements

The Cyprus Ultimate Beneficial Owner (UBO) Register forms an important part of Cyprus’ anti-money laundering framework and reflects the country’s commitment to transparency and compliance with European Union legislation.

The electronic UBO Register is now fully operational and entities within its scope are required to ensure that beneficial ownership information is submitted, maintained and updated in accordance with the applicable legislation and guidance issued by the Registrar of Companies and Intellectual Property.

We set out below a useful summary of the main points to help ensure compliance with the relevant regulatory requirements.

I. Which entities are required to submit information

The following entities are generally required to disclose beneficial ownership information in the UBO Register:

• Companies incorporated or registered under the Companies Law, Cap. 113.
• European public limited liability companies (SE).
• Partnerships.

Unless covered by the exemptions below, these entities are required to submit beneficial ownership information to the UBO Register.

Companies currently undergoing a liquidation or strike-off process, where the relevant process commenced on or after 12 March 2021, are generally also required to comply with the UBO Register obligations.

Overseas companies that have established a place of business (branch) in Cyprus remain outside the scope of the relevant regulations.

Pursuant to the Prevention and Suppression of Money Laundering and Terrorist Financing Law and the directives issued by the Registrar of Companies, the following are generally exempt from the obligation to disclose beneficial ownership information:

• Companies listed on a regulated market subject to disclosure requirements under European Union law.
• Companies subject to equivalent international standards that ensure adequate transparency of ownership information.

II. What information should be submitted

The information to be disclosed for each beneficial owner generally includes:

• Full name.
• Date of birth.
• Nationality.
• Residential address.
• Identification document details.
• The nature and extent of the beneficial ownership or control, whether direct or indirect.
• The date on which the individual became or ceased to be a beneficial owner, or on which previously disclosed information changed.

Where the ownership structure involves a trust, foundation or similar legal arrangement, additional information may also be required, including details relating to:

• Settlors, trustees and beneficiaries (and, where applicable, protectors or other persons exercising control).
• Founders and members of the board or management of a foundation.

III. Who is a beneficial owner?

Under the applicable anti-money laundering legislation, a beneficial owner is generally any natural person who ultimately owns or controls more than 25% of a company or legal entity, whether through direct or indirect ownership of shares, voting rights or other means of control.

Where no individual beneficial owner can be identified, details of one or more senior managing officials may need to be submitted instead.

IV. Important deadlines

Newly incorporated or registered companies and other legal entities should generally submit their beneficial ownership information within 90 days from the date of incorporation or registration.

Any changes to previously submitted beneficial ownership information should generally be notified to the UBO Register within 45 days from the date on which the relevant change became known to the entity.

Annual Confirmation

Entities are also required to complete the annual confirmation of their beneficial ownership information during the annual confirmation period prescribed by the Registrar of Companies.

Before submitting the annual confirmation, entities should ensure that all information held on the UBO Register is complete, accurate and up to date.

Any discrepancies identified by the Registrar of Companies should be addressed within the applicable timeframe.

V. Penalties for Non-Compliance

Failure to comply with the UBO Register obligations may result in administrative penalties and other sanctions being imposed under the applicable anti-money laundering legislation.

As the applicable penalty provisions and compliance requirements may change from time to time, companies and other legal entities should ensure that they comply with the latest legislation and guidance issued by the Registrar of Companies.

How Cosmoserve Can Help

Maintaining accurate and up-to-date UBO information is an important part of good corporate governance and regulatory compliance.

Cosmoserve can assist with:

• Reviewing beneficial ownership structures.
• Preparing and submitting UBO filings.
• Updating changes in beneficial ownership.
• Assisting with annual confirmation requirements.
• Corporate administration and company secretarial services.
• Ongoing corporate compliance and governance support.

With decades of experience assisting both local and international clients, Cosmoserve provides practical, reliable and commercially focused advice, helping businesses meet their regulatory obligations efficiently while minimising administrative burden.

Contact Cosmoserve

If you would like to discuss your UBO Register obligations or require assistance with any Cyprus corporate, tax or advisory matters, our experienced team would be pleased to assist.

Email: consult@cosmoserve.com

The contents of this publication are provided for general information purposes only and do not constitute legal, tax or professional advice. Specific advice should always be obtained based on your individual circumstances.