Guidance

Failure to comply & discrepancy 

In the event of non-compliance, notwithstanding the criminal liability or prosecution of any person, the corporate or other legal entity shall be liable to a fine:

• of one hundred Euros (€ 100) and
• a further fine of one fifty Euros (€ 50) for each day of continuation of the violation with a maximum total fine of five thousand Euros (€ 5,000)

A director or manager of an organization who refuses or omits or neglects to fulfil the submission obligations for BO is jointly and/or severally liable with the organization for the repayment of the fine imposed on the organization.

Director or manager of a company or other legal entity shall not be held for the repayment of the fine imposed on the company or legal entity if he had exercised due diligence on the compliance and the violation is not due to any act or omission or negligence on his behalf.

Discrepancy 

In the event of a discrepancy between the information in the BO Register and the BO information at their disposal, both the Competent & Supervisory Authorities and the obliged entities, if they consider that reporting is appropriate and will not unduly interfere with its tasks, are obliged to submit a discrepancy report to the Registrar of Companies via the e-system, in which:

• The information in respect of which the discrepancy exists on the basis of the information available to it is described.
• Documents/evidence to substantiate the discrepancy are attached.

Upon receipt of the discrepancy report, the Registrar of Companies shall examine the discrepancy and if deemed appropriate, he shall send a written notice to the corporate or other legal entity informing for the following: 

• stating that the aforementioned discrepancy report has been received,
• determining the details in respect of which the discrepancy exists, 
• the submission within 30 days, of a written statement with a reasoned reply whether the discrepancy is valid and if to provide the necessary evidence 

In the event of non-compliance, notwithstanding the criminal liability or prosecution of any person, the corporate or other legal entity shall be liable to a fine.

For the time being, the provisions of the Directive regarding inconsistencies in the Register of beneficial owners, shall be submitted by the Competent - Supervisory Authorities and obliged entities upon a written request to the Registrar of Companies. The electronic submission of discrepancies is available as from 01/04/2024. 

For any questions/technical difficulties please contact Ubos@meci.gov.cy. For further information regarding the BO registry, please see the guidance and the BO FAQ's.