The Department of the Registrar of Companies and Intellectual Property (DRCIP) has issued an updated notice on 16 September 2026 regarding the Beneficial Owners Register (BOR), setting out the annual confirmation requirements applicable for 2026.
The requirements apply to all companies incorporated or registered under the Companies Law, Cap. 113, European Public Limited Companies (SEs), and partnerships (collectively referred to as “Organizations”).
The BOR forms part of Cyprus’ broader anti-money laundering and counter-terrorist financing framework. The central register was established following the transposition of the relevant EU beneficial ownership requirements into Cyprus law, while the annual confirmation procedure is administered by the DRCIP under the applicable national framework.
Annual Confirmation Requirement
All Organizations must access the BOR system between 1 October 2026 and 31 December 2026 in order to confirm the information recorded in the system. The confirmation applies, as relevant in each case, to:
- Beneficial Owners (UBOs)
- Senior Management Officials, (SMOs); or
- Due diligence information.
The confirmation must be completed once during the above period. Importantly, where a change or other action occurs after the annual confirmation has already been completed, the confirmation does not need to be repeated.
Where an initial registration, amendment or other action relating to UBOs, SMOs or due diligence takes place during the confirmation period, the relevant action must first be completed in the BOR. The applicable information must then be confirmed no later than 31 December 2026.
In addition, where an Organisation’s deadline for its initial submission - being 90 days from the date of incorporation or registration - falls within the confirmation period, the relevant information must also be confirmed by 31 December 2026.
Consequences of Non-Compliance
Failure to complete the confirmation process by 31 December 2026 may give rise, irrespective of any potential criminal liability or prosecution of any person, to the following financial charges imposed on the company or other legal entity:
- EUR 100 for the first day of non-compliance;
- EUR 50 for each subsequent day of continued non-compliance; and
- Maximum aggregate financial charge of EUR 5,000.
The DRCIP notice places the financial charge on the company or other legal entity itself. The practical emphasis should therefore be on completing any necessary review and amendments in sufficient time to allow the annual confirmation to be submitted within the prescribed period.
Practical Considerations
Organizations should review the information currently recorded in the BOR before submitting the annual confirmation. The review should include BO and SMO information, as applicable, and should consider whether the recorded information remains accurate and consistent with the Organisation’s current ownership and control position. The confirmation is completed electronically through the BOR system within the prescribed timeframe.
Where the information is correct and up to date, the Organisation may proceed with confirmation. Where an amendment is required, the relevant update should be completed first, followed by confirmation. For more complex structures, early legal or compliance input may assist in resolving ownership or control questions and in sequencing any required filing before confirmation.
Beneficial Ownership in Practice
Under the applicable Cyprus AML framework, a beneficial owner is the natural person who ultimately owns or controls a legal entity. Ownership or control may arise directly or indirectly and may be established through shareholding, voting rights or control through other means.
A holding of 25% plus one share, or an ownership interest of more than 25%, is an indication of ownership for these purposes, whether held directly or indirectly. The assessment is not limited to percentage ownership: voting rights, contractual arrangements, significant influence and other means of control may also be relevant, depending on the circumstances.
Where no natural person is identified as the beneficial owner on the basis of ownership, or where there is doubt that the person identified is the beneficial owner, the applicable framework provides for the details of the relevant senior management official to be submitted, subject to the conditions of the legislation and DRCIP guidance.
Importance of Due Diligence
The annual confirmation requirement should be viewed alongside the broader obligation to maintain adequate, accurate and current beneficial ownership information. In practice, Organisations and, where applicable, their professional advisors should ensure that the information used for BOR purposes is consistent with the underlying corporate and due diligence records. Relevant considerations may include:
- verifying the identity of beneficial owners on the basis of appropriate information and documentation;
- understanding the direct and indirect ownership and control structure of the entity;
- identifying whether changes in shareholding, voting rights or other control arrangements affect the information recorded in the BOR; and
- maintaining records that are accurate and up to date, in accordance with the applicable legal and regulatory requirements.
The annual confirmation does not, by itself, require every Organisation to undertake a new full due diligence exercise. Its practical purpose is to confirm the relevant information recorded in the BOR after checking that it remains accurate and current.
How Legal and Compliance Advisors Can Assist
Determining beneficial ownership can require closer analysis where structures involve multiple jurisdictions, trusts, nominee arrangements, layered ownership or mechanisms of control that are not apparent from registered shareholdings alone. Legal and compliance advisors can assist by:
- reviewing existing BOR information against current corporate and ownership records;
- analysing direct and indirect ownership and control, including relevant thresholds and control through other means;
- assessing multi-layered, trust, nominee and cross-border structures;
- identifying whether an amendment or other BOR action is required before annual confirmation;
- assisting with the sequencing and timely completion of relevant filings and the annual confirmation; and
- addressing questions arising from the application of the beneficial ownership framework to particular structures and, where appropriate, communications with the DRCIP.
For straightforward ownership structures, the annual confirmation may be relatively simple. Professional input is most relevant where the ownership or control position has changed, is indirect, or requires analysis before the information recorded in the BOR can be confirmed.
Annual Compliance Cycle
The 2026 confirmation process continues the established annual compliance cycle for affected Cyprus entities. A useful practical sequence is to review the information recorded in the BOR, complete any required update and then submit the annual confirmation.
To address the 2026 requirement in an orderly manner, Organisations should:
- maintain accurate and up-to-date beneficial ownership and related records;
- complete any necessary amendments before confirmation and submit the required confirmation between 1 October and 31 December 2026; and
- seek appropriate professional support where the ownership structure, control analysis or filing position requires further consideration.
Timely preparation and proper due diligence will assist Organizations in meeting their regulatory obligations and avoiding penalties under Cyprus’ AML framework.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
