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UBO register Cyprus 2026: annual confirmation, penalties and deadlines

UBO register Cyprus: the annual confirmation runs 1 October to 31 December 2026. Penalties, liability, the 90 and 45 day deadlines, indirect ownership.

Reviewed by Ekvi editorial review on 2026-10-09 · Updated 2026-10-08 · Ελληνικά

Every Cyprus company has to tell the UBO register (the beneficial ownership register) who stands behind it, and to keep that information right. In 2026 the Registrar of Companies announced, on 16 September, that companies must access the register system between 1 October and 31 December 2026 to confirm their beneficial owners' details. This guide sets out the window, the deadlines that run alongside it, what a missed filing costs and how an indirect holding is traced to a person.

UBO register Cyprus: the window and the other deadlines

The accepted position of Ekvi's rule book, built from the Registrar's guidance, is that there are three separate clocks:

Obligation Deadline
First filing Not later than 90 days from the date the company was registered
A change in a beneficial owner's details Within 45 days of the date the change came to the knowledge of the legal entity
Annual confirmation In the period from 1 October to 31 December of each calendar year

The Registrar's news item adds that the confirmation is performed only once in the period. The annual confirmation covers the register as a whole. It does not replace the notification of an individual change, which has its own 45 days.

A worked example: a company registered on 1 September 2026 files its first beneficial owner details by 30 November 2026. If a share transfer on 10 November 2026 changes who holds more than 25 per cent, the change is due by 25 December 2026, and the annual confirmation is still due by 31 December 2026.

Who is a beneficial owner

A beneficial owner is a natural person who directly or indirectly owns or controls more than 25 per cent of the shares, of the voting rights or of the ownership interest. "More than" is strict: exactly 25 per cent is not above the threshold. The holding is measured on issued shares and their votes. Options, advance subscription agreements and convertible notes carry neither shares nor votes before they convert, so they do not count towards the 25 per cent.

What a missed filing costs

A company that refuses, omits or neglects to submit the details of its beneficial owners is charged EUR 100 and a further EUR 50 for each day the breach continues, up to EUR 5,000. The ceiling for other legal entities under s.61B of the law is EUR 2,000. The provision is s.61A(10)(ε) of the Prevention and Suppression of Money Laundering Law 188(I)/2007, inserted by N.141(I)/2024, with Directive K.D.P. 423/2024.

On liability, the law names the director or the managing director. The texts read for this guide do not name the secretary. The Directive also provides that a director who shows due diligence is not liable. The Registrar applies the penalties from 1 February 2025, after the extension of the first deadline to 31 January 2025. The law also allows the Registrar to strike a company off the register under s.327 of Cap. 113 for these breaches.

How indirect ownership is traced

When a member is a company, the register of members shows the company, not the person. A beneficial owner is always a natural person, so Ekvi follows each holding company to the people who own it. The share of each person is the product of the shares along the chain, and a person's direct and indirect interests are added.

For example, Holding Ltd holds 50 per cent of the company. Maria holds 80 per cent of Holding Ltd and also 5 per cent of the company directly. Her indirect interest is 0.50 x 0.80 = 40 per cent, her total 45 per cent, and she is above the threshold. If Holding Ltd has declared no owners, Ekvi does not name the holding company as a beneficial owner. It shows a gap for the undeclared part, so that somebody finds out who is behind it.

A nominee, a trustee or a personal representative is never shown as the beneficial owner of what it holds; Ekvi records a gap that points to the principal. A joint holding is shown as one line, and how it is split between the joint holders is not modelled. Control by other means than ownership and the fallback of naming a senior managing official are not modelled either, and the page says so.

What Ekvi records

Ekvi shows the beneficial owners it can name and the gaps it cannot, per company and per date. Each change that moves the set of holders above 25 per cent, or the extent of one of them, opens a 45-day clock on the attention screen. The company records the date it last confirmed the register, and the attention screen shows the confirmation as due soon inside the window and as missed after it closes. Put dates in your calendar with the deadline calendar.

Ekvi is a record-keeping tool and does not provide legal or tax advice.

Questions

When must Cyprus companies confirm their beneficial owner details in 2026?

Between 1 October and 31 December 2026. The confirmation is performed once in that period, in the beneficial ownership register system.

How long does a company have to report a change in a beneficial owner?

Forty-five days from the date the change came to the knowledge of the legal entity. A first filing is due not later than ninety days from registration.

Does a holding company count as a beneficial owner?

No. A beneficial owner is a natural person who directly or indirectly owns or controls more than 25 per cent. A holding company is looked through to the people behind it.

The rules behind this guide

Sources

Keep the register of members, the filing deadlines and the option plan in one place.

Ekvi is a record-keeping tool and does not provide legal or tax advice. A guide explains the rules Ekvi records; your corporate secretary or lawyer decides what applies to your company.