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Company owners must confirm their UBO data. Fines of up to €5,000
As of October 1, Cypriot companies and other entities subject to the UBO obligation must confirm their data recorded in the Register of Beneficial Owners. The deadline is December 31, 2026, and the entire procedure is conducted electronically.
Confirmation is also mandatory if the ownership, shareholding, and control have not changed during the year. Failure to provide confirmation is punishable by a fine of €100 for the first day of non-compliance and €50 for each subsequent day, up to a maximum of €5,000.
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Who needs to confirm UBO data?
The obligation covers all companies incorporated or registered under the Cyprus Companies Law Cap. 113, European Public Limited Companies (SEs) and partnerships.
Depending on the type of entity and its structure, confirmation may concern:
- beneficial owners – UBO;
- persons holding senior management positions – SMO;
- due diligence procedure carried out.
The obligation also applies to companies owned by Poles or managed by Polish entrepreneurs. What matters is the entity's registration in the Republic of Cyprus, not the nationality of its owners or directors.
No changes do not release you from the obligation
Annual confirmation is not required only if a new shareholder has joined the company or the ownership structure has changed.
Each entity covered by the regulations must log into the electronic system and confirm that the information recorded is accurate and up-to-date. This also applies to companies that have not undergone any changes throughout 2026.
Confirmation is made once in the period from October 1 to December 31.
31
DECEMBER
Deadline for confirming UBO data
Data must be confirmed electronically from October 1st to December 31st, 2026.
The obligation also exists even if no changes have occurred in the company.
Who is the beneficial owner?
A beneficial owner is an individual who ultimately owns or controls a company. Control may result from direct or indirect ownership of shares, voting rights, or other rights.
In the case of a more complex structure, identifying a holding company or other entity in the ownership chain is not sufficient. The register must lead to a specific individual exercising ultimate control.
Before confirming, it is worth checking:
- whether the entry corresponds to the current structure of the company;
- whether the entire chain of ownership has been correctly demonstrated;
- whether the appropriate individuals have been reported;
- whether the shares, voting rights and method of exercising control match;
- whether the personal and address details of the beneficiaries are up to date.
Update first, confirmation later
If the data in the register is out of date, it should not be approved just to formally end the procedure.
First, you must make the appropriate changes to the Beneficial Owner Register. Only after saving these changes can you proceed to annual confirmation.
The same rule applies if the first company registration, beneficiary change, or other action falls between October 1 and December 31. The appropriate action is performed first, and then the data for 2026 is confirmed.
However, if a change occurs after the annual confirmation has been completed correctly, the entry must be updated, but there is no need to complete the confirmation again for the same year.
How to confirm data in the system?
The procedure is available only electronically in the BOR system. CY Login details are required to log in.
After entering the system you must:
- select "Organization update";
- go to "Beneficial Owners Update";
- enter the entity's registration number;
- open organization data;
- go to the beneficial owners tab;
- select "Confirmation of UBO Details";
- check the displayed data;
- approve them and perform the final submission via "Final Submission".
Simply reviewing your data or clicking the first confirmation button may not complete the process. Please ensure that you have also completed the final submission.
OFFICIAL UBO SYSTEM
Go to the Register of Beneficial Owners
The penalty can increase quickly
Failure to confirm by December 31st will result in a penalty of €100 for the first day of non-compliance. €50 will be charged for each subsequent day.
The maximum total fine is €5,000 for a single company or entity. The regulations do not exclude criminal liability or prosecution of those responsible for the failure to report.
A director or manager may also be jointly liable for payment of a penalty with the company if they refused, neglected, or failed to ensure compliance with their obligation. Exemption from liability may require proof that the person in question exercised due diligence.
This is a separate obligation of the company
Confirmation of UBO data should not be confused with the submission of the annual HE32 report, financial statements or other obligations to the Registrar of Companies or the Cyprus Tax Authority.
Performing one of these activities does not mean automatic confirmation of the data of the beneficial owners.
Company owners and directors should first clarify with their accountant, lawyer, or administrator who is responsible for carrying out the procedure. It's also a good idea to keep electronic confirmation that the data has been sent correctly.
Questions regarding the register can be directed to the Registrar of Companies at: Ubos@meci.gov.cy.
Sources: Department of the Registrar of Companies and Intellectual Property of the Republic of Cyprus, Register of Beneficial Owners, Official Guidelines on UBO
