Passport upload to the Serbian Central Records of Beneficial Owners

Foreigners who qualify as Beneficial Owner in Serbia should be aware of recent changes in regulations (foreigner from Serbia’s point of view). Changes are related to some sensitive personal data access.

Scanned passport (or foreign ID) of such foreigner need to be uploaded to the Serbian Central Records of Beneficial Owners by November 30^th 2025. Access to uploaded documents is defined by law. By my opinion, wider range of people would have access to scanned passport than until now.

Under positive regulations in Serbia, access to foreigner’s passport copy is not something new.

Serbian Business Registry Agency requires it for LLC or Entrepreneur registration process. Also, it is asked by lawyers or other people who help during LLC registration, by bank during bank account opening, by official registration body for issuing qualified certificate, by accountants for signing the contract etc. For all described situations, foreigner (or by him/her authorized person) was aware of circumstances in which access to passport was granted.

Who will now have access to scanned passport?

By regulations, access to passport can make only people who have legitimate interest.  

Technically, access to scanned passport will have all obliges by Serbian AML regulations (Article 4 of the Serbian Law on Prevention of Money Laundering and Financing of Terrorism). List is long, so here are some from it - banks, money exchange offices, investment funds, voluntary pension funds, financial leasing and insurance companies, audit companies and independent auditors,  electronic money institutions, payment institutions, intermediaries in the sale and lease of real estate, factoring companies, accountants, tax advisors, persons engaged in postal traffic, providers of services related to digital assets, lawyers, notaries etc.

Not all staff of the above listed companies will have such access, just the ones for whom their Employer have sent authorization to Serbian Business Registry Agency granting access. But more people will have access than until now.

Legitimate interest is the basis for accessing personal data, but the passport holder is unlikely to be aware that someone downloaded his/her scanned passport and under which circumstances. I am confident that government agency keeps a log file of who, when and how the scanned passport was accessed, so that interested party can react in the case of misuse.