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 and each of its officers shall be liable to a fine:

• of two hundred Euros (€ 200) and
• a further fine of one hundred Euros (€ 100) for each day of continuation of the violation with a maximum total fine of twenty thousand Euros (€ 20,000)

Provided that an officer of a corporate or other legal entity shall not be subject to a fine if he had exercised due diligence to comply with the provisions of the Directive. 

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 and each of its officers shall be liable to a fine.

For the time being, the provisions of the directive regarding inconsistencies in the 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 will be 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.