The Department of the Registrar of Companies and Intellectual Property (DRCIP) of the Republic of Cyprus has introduced significant updates to the penalties, deadlines, and overall compliance framework for the Ultimate Beneficial Ownership Register (UBO Register). Below is a summary of the key changes that are particularly relevant for companies and legal entities operating in Cyprus.
Revised Monetary Penalties: What Has Changed?
- Only Entities Are Penalised:
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- The previous penalties directly imposed on company directors and secretaries for non-compliance with the requirement to provide information for the UBOs have been abolished. From now on, only the company or legal entity will bear liability for non-compliance.
- However, a director or managing director may still be held jointly and/or severally liable with the company for the payment of any financial penalties imposed on the company in cases of refusal, omission or neglect to fulfil their obligations.
2. Reduced Penalties for Late or No Filings:
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- The penalty for the first day of non-compliance has been reduced to €100 (previously €200).
- A daily penalty of €50 (previously €100) will apply for continued non-compliance.
- The maximum penalty has been significantly reduced from €20,000 to €5,000.
3. Reimbursement of Penalties Paid Since April 2024:
Monetary penalties imposed from 1 April 2024 are being recalled, and entities that have already paid will be reimbursed.
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- Payments made via JCC will be refunded automatically.
- For payments made at the DRCIP cashier desk, entities must submit Form KE1 alongside the payment authorisation form from FIMAS, a copy of the proof of payment, and their IBAN number.
Deadlines for Compliance Extended
- Submission of Beneficial Ownership Particulars:
The new deadline for filing beneficial ownership details (1st submission) has been extended to 31 January 2025. Entities failing to meet this deadline will incur penalties starting from 1 February 2025. - Annual Review and Confirmation:
The deadline for the 2024 annual review and confirmation of beneficial ownership details has been extended to 31 March 2025.
Enhanced Powers of the Registrar of Companies
To ensure compliance with the UBO Register obligations, the Registrar of Companies now holds the following powers:
- The authority to issue Directives via Regulatory Administrative Acts (RAA), establishing procedures for reviewing objections against the imposition of financial penalties and for administrative re-examinations and/or submissions.
- The ability to strike off companies or legal entities from the registry that refuse, omit, or neglect to fulfil their obligations about submitting Beneficial Ownership Particulars.
- The right to apply to the Courts for Injunction Orders compelling compliance with UBO-related obligations.
For the full amendments published in the Government Gazette of the Republic of Cyprus dated 6 December 2024, click here.
Why Is Compliance Important?
Ensuring your entity meets the requirements of the UBO Register is essential to avoid financial penalties and administrative consequences. The revised penalties and deadlines present an opportunity for companies to address any existing delays and secure compliance before the upcoming deadlines.
Our team at Christos Patsalides LLC, in collaboration with Corporate Management Ltd, remains at your disposal to assist with UBO Register filings, annual reviews, and all related compliance matters.
If you require further guidance or clarification, please do not hesitate to contact us via phone at +357 22 677 677 or by email at info@patsalides.com.cy.
This article is intended to provide general guidance on the recent updates and does not constitute legal advice. For tailored advice based on your specific circumstances, please contact our team.
December 2024
Key Contacts:
Varteni Kasapian
Partner/AML Officer
varteni.kasapian@patsalides.com.cy
Christos Panayides 
Lawyer/Deputy AML Officer