The Cyprus UBO Register: A Simple Guide
Who counts as a beneficial owner, what must be filed in the Cyprus UBO Register and by when, who can see it, and the fines for getting it wrong.
(A) At a glance
- Every company and partnership registered in Cyprus must record the individuals who ultimately own or control it in the Registrar's UBO Register, keep the entry up to date and confirm it once a year, and the 2026 confirmation window closes on 31 December 2026.
- The rules are set by section 61A of the Prevention and Suppression of Money Laundering and Terrorist Financing Law 188(I)/2007 (the "AML Law") and the Registrar's Directive ΚΔΠ 112/2021, as amended (the "Directive").
| Item | Rule |
|---|---|
| Who must file | Companies, partnerships and European companies registered with the Registrar of Companies; companies listed on an EU regulated market are exempt |
| New entities | Within 90 days of incorporation or registration |
| Changes | Within 45 days of the entity becoming aware of them |
| Annual confirmation | Once a year, between 1 October and 31 December |
| Fines | €100, plus €50 for each day of delay, up to €5,000 |
| Public access | Suspended since November 2022 |
(B) Who is a beneficial owner
- A beneficial owner is always an individual, never a company, who ultimately owns or controls the Cyprus entity, and the AML Law identifies that person in 3 ways:
(a) by ownership, holding more than 25% of the shares or voting rights, that is 25% plus 1 share, either directly or through other companies the person controls;
(b) by control by other means, for example a right to appoint the board, a veto or an agreement giving decisive influence, even without a 25% holding; or
(c) where no one qualifies under (a) or (b), as the senior managing official, meaning the director or directors who manage the company.
Nominees
- A nominee shareholder is not the beneficial owner, so the register must show the individual on whose behalf the nominee acts.
An example
- Maria owns 60% of a BVI company, which owns all the shares in a Cyprus company, so Maria is a beneficial owner of the Cyprus company through indirect ownership and must be registered.
(C) What must be filed, by whom and when
Who files and when
- The duty to file rests with the entity itself, and a new company has 90 days from incorporation to submit the details of each beneficial owner.
Information required
- For each beneficial owner the filing must show:
(a) full name, date of birth and nationality;
(b) residential address;
(c) identity document type, number and issuing country;
(d) the nature and extent of the interest held, such as the shareholding percentage, voting rights or other control; and
(e) the date the person became a beneficial owner and the date of any later change.
How the filing is made
- The filing is made online through the Registrar's UBO system, using the company's gov.cy corporate profile, which only the company's appointed officers can hold, after authenticating through e-banking, a video call with a Citizen Service Centre or in person.
- We prepare the information and the ownership chart and, where we act as company secretary, make the submission ourselves; otherwise we guide the director through it.
(D) Keeping the register up to date
- Filing once is not enough, because the Directive requires the entry to stay accurate throughout the life of the company.
- The company must also keep its own accurate record of its beneficial owners at its registered office, and the same fines apply if it does not.
| Duty | Deadline |
|---|---|
| Report a change of beneficial owner or of their details | Within 45 days of the company becoming aware of it |
| Confirm the information, even if nothing has changed | Once a year, between 1 October and 31 December |
| Respond to a discrepancy notice raised by a bank or adviser | Within 30 days of the Registrar's notice |
| Beneficial owners to give the company the information it needs | Whenever asked, and on any change |
(E) Who can see the register
- The register is not open to the general public, since Cyprus suspended public access on 23 November 2022 following the judgment of the Court of Justice of the EU in WM and Sovim (C-37/20 and C-601/20).
Competent authorities
- Authorities such as the Unit for Combating Money Laundering, the police and supervisory bodies have full access without notice to the company.
Banks and other obliged entities
- Banks, lawyers and accountants can search the register for their due diligence checks for a fee of €3.50 per entity.
Protection in exceptional cases
- A beneficial owner exposed to a serious risk, such as fraud, kidnapping or violence, may apply to restrict access to their details, although this does not apply against banks and financial institutions.
Future changes
- The EU's latest anti-money laundering directive, Directive (EU) 2024/1640, requires access for people with a legitimate interest, such as journalists, and Cyprus is expected to legislate for this.
(F) Penalties
- Under the AML Law, as amended by Law 141(I)/2024, a company that fails to file, confirm or update its entry, or to keep its own record, is fined €100 plus €50 for each further day, up to a maximum of €5,000.
- The fine is imposed on the company, but its directors are jointly and severally liable unless they show they acted with due diligence.
- The Registrar may also strike the company off the register or apply to court.
- An inaccurate register can delay bank onboarding and transactions, because banks check it as part of their own due diligence.
(G) FAQs
Does a dormant company have to file?
The obligation applies to every company registered with the Registrar regardless of whether it trades, so a dormant company must file, update and confirm its entry like any other.
Do I need to confirm the information if nothing has changed?
The annual confirmation is required every year between 1 October and 31 December even where nothing has changed, and missing it attracts the same fines as a late filing.
What if a shareholder changes after we have confirmed for the year?
The change must be reported within 45 days of the company becoming aware of it, without waiting for the next annual confirmation.
Who is recorded if nobody owns more than 25%?
The register records any individual who controls the company by other means, and if there is no such person, the senior managing official, usually the director or directors.
Our shares are held by a nominee. Whom do we register?
The register must show the individual for whom the nominee holds the shares, not the nominee itself.
Can our lawyer or accountant file for us?
Access to the system is reserved to the company's appointed officers, so a lawyer or accountant can file only where it acts as an officer, such as the company secretary, and otherwise prepares the filing for a director to submit.
Can anyone search who owns my company?
Public access has been suspended since November 2022, so only competent authorities and obliged entities such as banks, carrying out their own checks, can see the information.
What is the maximum fine?
The fine is €100 plus €50 a day, capped at €5,000 per entity, and the directors can be held liable for it.
(H) How we can help
Lytras & Associates LLC identifies the beneficial owners in your structure, prepares the filing and ownership chart, makes the submission where we act as company secretary or guides your director through it, and tracks the annual confirmation and any changes, so that deadlines are not missed.
Talk to our corporate team
- Call +357 22 264726
- Email info@lytrasllc.com
We reply within 1 working day.
This guide is general information on Cyprus law as at October 2026 and is not legal advice.