Cyprus UBO Submission Regulations

Electronic System of the Register of the Ultimate Beneficial Owners (UBO)

Introduction:  
The obligation to submit the Ultimate Beneficial Owners (“UBO”) to the Registrar of Companies’ system, falls under the Prevention and Combating of Money Laundering Law of 2007 (CAP.188(I)/2007) as well as the Directive K.Δ.Π. 112/2021.  

The provisions of the Law and Directive will officially enter into force from 01/01/2024. 

Background and Previous Submissions: 
During the Interim Solution phase, which was due by the 31st of October 2023, all Cyprus entities had the obligation to submit the UBO details free from any fees and/or penalties. 

New Submission Guidelines: 
On the 14th of November 2023, the government issued new regulations in relation to the submission of the UBO details, divided into three Phases: 

Phase A (14/11/2023 – 31/12/2023): Re-submission of UBO details without penalties. 
Phase B (01/01/2024 – 29/02/2024): All entities that did not re-submit the UBO details during Phase A, will be obliged to pay penalties. Only upon payment of the penalties, the Entities can submit the UBOs to the system. 
Phase C (01/03/2024 onwards): Implementation of Directive Κ.Δ.Π. 112/2021, including submission deadlines and annual updates. 

Penalties and Compliance: 
•  The Company and each of its officers are entitled to 200 Euro penalty and a further 100 euro penalty for each day of not submitting the UBOs. 
  Deadlines for submission to UBO system based on the Directive Κ.Δ.Π. 112/2021: 

1.  30 days from the date a Company has been incorporated;
2. 14 days from the date of change of the shareholder/UBO and/or shareholding of the company;
3. from 01/12 -31/12 each year re-submission and/or update of the details.

  In order for an entity to be able to submit the UBO to the Registrar’s system, It should have an activated and verified account in Ariadne portal. 

Access to UBO System 
The UBO system will allow other entities to make a search regarding the details of the UBO(s) of a Company by paying the amount of 3.50 euro. 

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