Every director of their LLC must submit information for registration in the Register of Ultimate Beneficial Owners. This is not difficult and must be done, since violators face fines amounting to tens of thousands of euros. Your chosen accountant will help with this registration.

Who Must Submit Data to the Register

The obligation to submit data to the Register of Ultimate Beneficial Owners and update it annually applies to:

legal entities
business companies
associations
institutions
political parties
religious organizations
artistic organizations
chambers
trade unions
employers’ associations
funds and other entities engaged in economic activity
legal entities receiving, managing, or distributing funds for specific purposes
trusts
other persons or foreign law entities equated to them that receive, manage, or distribute property funds

They must enter data about ultimate beneficial owners and any changes within eight days from their registration in the Central Register of Business Entities (CRPS) or the taxpayer register, or within eight days from any change of such data.

Who Is Exempt from Submitting Data

The obligation does not apply to:

individual entrepreneurs
the public sector, according to the law governing timing for monetary obligations
legal entities and companies with many shareholders whose shares are traded on an organized securities market, provided they meet transparency requirements for ultimate ownership under the law

How to Submit Data to the Register

As mentioned earlier, your accountant will assist with this process. You will need to purchase a special electronic signature certificate. We have detailed instructions on how to obtain this certificate and register with the register using it. All our accounting clients can contact us for this instruction and support.

If you are not yet our client, feel free to join us. Our clients are much better informed than those at other agencies.

Another option is to have your accountant register you using their certificate, saving you the time spent acquiring your own. However, I do not recommend this and here’s why:

While your accountant can submit data using their certificate, you will not be able to print an official extract from the register.
Though rare, some organizations—such as banks—do request this extract.
During an inspection, you won’t have the extract if your accountant registered you without your certificate, and they won’t save you.

Therefore, the best option is to get the certificate yourself, with your accountant providing the instructions.

Rules for Updating the Data

Submitting the data once is not enough — it must be updated annually. Updates are required according to this schedule:

Within 8 days of any change (for example, when your temporary residence permit is renewed).
By March 31 each year, you must confirm all data is accurate. It is essential to upload a scan of the prepared confirmation document — without it, the registration will not be valid. Your accountant can provide a template for this document.

If your accountant seems unsure about what document is needed, this often reflects the difference between accountants with formal Montenegrin education and those without.

The law is lengthy and sometimes vague or contradictory. To fully comply and avoid future claims of misunderstanding, I recommend updating your data twice each year: