Annual confirmation of information in the Register of Beneficial Owners

We would like to remind you of the annual requirement for all entities registered or established under Companies Law, Cap. 113, including European Companies (SE) and Partnerships, to confirm the details of their beneficial owners, senior management officials, or due diligence, depending on the applicable requirements. This confirmation process takes place between 1 October and 31 December each year and is conducted through the electronic system accessible only to entities registered in the Government Gateway Portal (Ariadni).

If any initial entry, change, or other action related to the Register of Beneficial Owners occurs during the data confirmation period (1 October to 31 December of the current year), it should be completed prior to the confirmation deadline of 31 December of the current year.

Where changes or actions occur after the confirmation of information, there is no need to repeat the confirmation process.

Other important deadlines:

Newly incorporated or registered companies or other legal entities must disclose the details of their beneficial owners, senior management officials, or due diligence in the Register of Beneficial Owners within 90 days from the date of their incorporation or registration.

Changes to the beneficial ownership information previously disclosed must be notified to the Register of Beneficial Owners within 45 days from the date on which the relevant change became known to the entity involved.

Any discrepancies in the beneficial ownership information identified and communicated to an entity by the Registrar of Companies and Intellectual Property will need to be addressed and rectified within 30 days from the date of the relevant notification.

It is the responsibility of the new officers/partners to check, before they are appointed, whether the beneficial owners have been declared to the Register of Beneficial Owners. It has been clarified by the Registrar of Companies and Intellectual Property that the responsibility of the new officers/partners to comply with the obligations related to the Register of Beneficial Owners commences from the date they are appointed.

Penalties for non-compliance:

If the confirmation of information is not filed by 31 December 2024, regardless of the criminal responsibility or prosecution of any person, the entity and each of its officials/partners are subject to a monetary charge of €200 on the first day and a further monetary charge of €100 for each day of continued violation with a maximum total charge of €20,000. It should be noted that an officer of a corporate or other legal entity will be exempt from such fines if they have exercised due diligence in adhering to the provisions of N.188(I)/2007 and Directive P.I. 112/2021, as amended, and the violation is not attributed to their actions, omissions, or negligence.