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Accounting

2025: Confirmation of Ultimate Beneficial Owner Information

Christopher Dosin · Founder / CTO

2025: Confirmation of Ultimate Beneficial Owner Information

Learn about the annual UBO confirmation requirement in Cyprus. Complete your Ultimate Beneficial Owner details between October 1 and December 31 to avoid penalties.

What is the UBO Confirmation Requirement?

Cyprus companies and other legal entities are required by law to maintain and annually confirm information about their Ultimate Beneficial Owners (UBOs) - the natural persons who ultimately own or control a company.

This requirement stems from the EU Anti-Money Laundering Directives (AMLD) and is implemented in Cyprus through the Prevention and Suppression of Money Laundering Law.

What is an Ultimate Beneficial Owner?

A UBO is any natural person who:

  • Directly or indirectly owns more than 25% of the shares or voting rights
  • Controls the company through other means
  • Exercises control via senior management position (when no natural person meets the above criteria)

The Annual Confirmation Window

Every year, companies registered in Cyprus must confirm their UBO information through the Registrar of Companies between October 1 and December 31.

This is not just a one-time registration - even if nothing has changed, you must actively confirm the information annually.

Who Must Comply?

The following entities must register and confirm UBO information:

  • Cyprus limited liability companies (Εταιρεία Περιορισμένης Ευθύνης)
  • Cyprus partnerships (general and limited)
  • Trusts administered in Cyprus
  • Other legal arrangements

Information to be Confirmed

For each UBO you must provide:

  1. Full name
  2. Date of birth
  3. Nationality
  4. Country of residence
  5. Nature and extent of beneficial interest (e.g., percentage of shares held)
  6. National identification or passport number

How to Submit

The confirmation is done electronically through the Registrar of Companies' online portal (companies.gov.cy).

Steps:

  1. Log in to the Registrar of Companies portal
  2. Navigate to "UBO Register"
  3. Review existing UBO information
  4. Confirm or update as necessary
  5. Submit the confirmation

Penalties for Non-Compliance

Failure to submit the annual UBO confirmation by December 31 can result in:

  • Administrative fines imposed on the company and its officers
  • Suspension of the company's ability to receive certificates of good standing
  • Potential difficulty in opening bank accounts or conducting business

Practical Tips

  • Set a reminder for October 1 each year to begin the process
  • Ensure your company's share register is up to date before starting
  • If ownership has changed, update UBO information promptly (not just annually)
  • Retain documentary evidence of ownership structure
  • Consider using a corporate services provider if your ownership structure is complex