Increased Scrutiny of Beneficial Ownership Register (UBO register) Filings
All legal entities (companies, institutes, associations, foundations, etc.) are required to register their beneficial ownership information in the Beneficial Ownership Register (UBO register), maintained by AJPES, and to ensure that such information remains accurate and up to date at all times.
Regulatory authorities have announced increased supervisory scrutiny regarding compliance with this obligation. Non-compliance (including late filing, inaccurate, or outdated information) may result in substantial fines: EUR 3,000 to EUR 120,000 for legal entities and EUR 400 to EUR 2,000 for responsible persons of the legal entity. In addition, the Financial Administration of the Republic of Slovenia, in the course of tax inspection proceedings, as well as other supervisory authorities, regularly verify the accuracy of UBO register filings and the submission of other relevant supporting documentation. Given the complexity of the applicable requirements, this is an area where obtaining additional professional support is often advisable.
Recommended Actions
Verify your entity's current registration status in the UBO register system (eRDL);
Confirm that all registered information remains accurate and up to date (first and last name, date of birth, nationality, as well as the nature and extent of the ownership interest or control);
In the event of any change affecting the beneficial ownership structure, update the register within the statutory deadline of 8 days;
Do not overlook the obligation to maintain an internal register of beneficial owners, as required under Article 150, paragraph 18 of the Prevention of Money Laundering and Terrorist Financing Act (ZPPDFT-2). This internal register must likewise be kept current and updated without delay following any relevant change.
Should you require assistance in verifying or updating your beneficial ownership information, please do not hesitate to contact us.
