Launch of the final solution of the Electronic System of the Beneficial Ownership Register
The Department of the Registrar of Companies and Intellectual Property (TEEDI) announced the start of the implementation of the final solution of the electronic system of the UBO Registry as of November 14, 2023. The final solution will be implemented in its entirety within 2024.
According to the relevant announcement, all the obliged entities are invited to enter the final solution system and proceed to the “Action” of the “Initial Registration”, i.e., to update/re-register their BO, even if they have already done so in the interim solution system. Access to the relevant system(https://ubo.meci.gov.cy/) can only have those who are registered users of Cylogin.
The 3 periods of the final solution are explained below:
Period A: 14/11/2023 – 31/12/2023
All companies incorporated or registered under the Companies Law, Cap. 113, all European Public Limited Liability Companies (SEs) and all Cooperatives (hereinafter referred to as Organisations) or their officers/partners, are invited to enter the final solution system and proceed to the “Action” of “Initial Registration”, i.e. to update/re-register their BO, even if they have already done so in the intermediate solution system. For re-registration purposes, the last image of the intermediate solution’s BO elements will be presented in the ‘Intermediate system information’ tab where they can see what they have entered in the intermediate solution and re-register it. Period A will last approximately 1 1/2 months (14/11/2023 – 31/12/2023) and will not incur any charge. The way of entering the final solution system will be the same as that of the intermediate solution.
From this period as well as in subsequent periods it will be possible to:
o Exercising due diligence;
o Opt-out to disclosure of information;
o Request for access to minors’ data;
o Organizations listed on a regulated market which is subject to disclosure requirements under European Union Legislation will be able to opt out;
o Organizations subject to equivalent international standards ensuring sufficient transparency of ownership information will be able to declare their exemption;
o Obliged Entities and Competent and Supervisory Authorities will be able to conduct an electronic search of the ISPA on their own. As far as Obliged Entities are concerned, their role will be examined and then accepted or rejected by officers of the Department. The electronic survey of Obliged Entities will be completed with the payment of the corresponding fee of 3.50 euros per Organization.
Please note that those organizations that have exercised or intended to exercise due diligence in the interim solution should do so in the final solution. The same applies to Organizations that will have to declare their exemption in the final solution, whether they are listed on a regulated market, which is subject to disclosure requirements under European Union Legislation, or they are Organizations subject to equivalent international standards that ensure sufficient transparency of ownership information, which should declare their exemption in the final solution.
Period B: 01/01/2024 – 29/02/2024
o Companies incorporated or registered under the Companies Law, Cap. 113, those European Public Limited Liability Companies (SEs) and those Cooperatives or their officers/partners who have not entered during Period Ain the final solution system to proceed with the “Action” of “Initial Registration”, i.e., to update/re-register their UBO, even if they have already done so in the interim solution system, will incur a financial charge. The charge will apply from 01/01/2024 until the date of the “Action” of the “Initial Registration” when the system of the final solution will be updated with BO data. After the above Organizations have paid the resulting financial charge, they will be able to register and/or cease and/or change without any further financial charge governing these actions based on Directive K.D.P. 112/2021 as amended.
o Companies incorporated or registered under the Companies Law, Cap. 113, those European Public Limited Liability Companies (SEs) and those Cooperatives or their officers/partners, who have entered during Period Ain the final solution system and have taken the “Action” of “Initial Registration”, i.e. to update/re-register their BO, will not be charged and will be able to register and/or cease and/or change without any financial charge governing these actions based on Directive K.D.P. 112/2021 as amended.
Period C: from 01/03/2024 onwards
During Period C all actions under Directive K.D.P. 112/2021 as amended will be available as follows:
- Update of the Beneficial Ownership Register
- Confirmation of beneficial ownership
- Mismatch
- Online Survey of the Beneficial Ownership Register
- Request for disclosure exemption
- Request for access to minor’s data
- Calculations of monetary charges where applicable
For further information on this topic please contact AMG Mylonas & Associates, LLC by telephone +357 25 101080 or by e-mail [email protected]
The information provided by Mylonas Law is for general informational purposes only. It does not constitute or should not be read as a legal advice. You should not act or refrain from acting based on any information provided above without obtaining legal or other professional advice. No responsibility can be accepted by the authors or the publishers for any loss occasioned by acting or refraining from acting on the basis of this publication.
Source: Department of the Registrar of Companies (Announcement)
