On 16 September 2026, the Cyprus Department of Registrar of Companies and Intellectual Property (“Companies Registrar”) published an announcement (hyperlink: https://www.companies.gov.cy/en/knowledgebase/news/confirmation-of-beneficial-owners-information-in-the-beneficial-ownership-register-system-for-the-year-2026reminding) reminding all companies registered in Cyprus of their obligation to annually confirm the information recorded in the Register of Beneficial Owners (“UBO Register”). The annual confirmation must be completed once during the period from 1 October to 31 December of each calendar year.
The UBO Register is an electronic register maintained through the Companies Registrar’s beneficial ownership system, containing information on the beneficial owners and, where applicable, senior management officials or other relevant due diligence information relating to companies and other relevant legal entities. Its purpose is to maintain accurate and up-to-date information on the beneficial ownership of legal entities and forms part of Cyprus’ broader framework for enhancing transparency of ownership and preventing money laundering and related financial crime.
The annual confirmation obligation exists independently of the duty to notify the Companies Registrar of any changes to UBO information. Where the information recorded in the UBO Register is incorrect or has changed, the relevant amendment or other required action must first be completed, following which the information must be confirmed within the applicable annual confirmation period. Importantly, confirmation is required only once during each annual confirmation period. Where a change occurs after completion of the annual confirmation, no further annual confirmation is required for that calendar year, without prejudice to the obligation to update the UBO Register to reflect the relevant change.
Failure to complete the annual confirmation by the applicable deadline may result in financial penalties for the relevant entity. For 2026, failure to confirm the information by 31 December 2026 will result in a €100 fine for the first day of non-compliance, followed by an additional €50 for each subsequent day that the violation continues, subject to a maximum total fine of €5,000. The Companies Registrar has also expressly noted that these administrative fines apply without prejudice to any criminal liability or prosecution that may arise.
Given the escalating daily penalties, companies registered in Cyprus and their advisors should ensure that the annual confirmation is completed within the designated period to avoid unnecessary exposure to administrative fines. Please contact a member of our team to discuss how we can assist with the relevant submissions and filings with the Companies Registrar.