What is the legal basis of the Transparency Register in the respective Member State?

The “Prevention of Money Laundering and Terrorist Financing Act” (Zakon o preprečevanju pranja denarja in financiranja terorizma)implements the Directive into Slovenian law. 

This Act entered into force on 19 November 2016.

Is there an obligation of a UBO or shareholder to proactively provide information on the UBO to the legal entity?

There are no such obligations of beneficial owners.

Is there an obligation of a legal entity to actively inquire with its shareholders/partners on the identity of the UBO(s)?


Who is required to make filings with the Transparency Register, the legal entity or the UBO?

The legal entity.

Are there exemptions to the filing obligation?

According to Article 44 of the Slovenian Act, independent individual entrepreneurs, individuals who independently conduct an activity, limited liability companies with a sole shareholder and direct and indirect users of the state budget and legal entities who are companies on a regulated market, where in accordance with the EU law or comparable international standards, and have to comply with disclosure requirements that ensure proper transparency of information on ownership are not obliged to file with the register.

What is the due date for the initial filing with the Transparency Register?

19 January 2018

What are the sanctions in case of a breach of the transparency obligation?

A fine of between EUR 6,000 and EUR 60,000 may be imposed on a legal entity if it, inter alia, fails to acquire or if it acquires false information regarding its beneficial owner or owners or if it fails to establish and manage a detailed record of the information regarding its beneficial owners or if it fails to update it with every change or if it does not retain the information regarding its beneficial owners for five years from the date of termination of the status of beneficial owner.

Is the Transparency Register established as a separate register or part of an existing register?

The Slovenian Act provides that the register will be maintained and managed by the Agency of the Republic of Slovenia for Public Legal Records and Related Services (AJPES) and the filing will be done through a web portal of the registry administrator. 

Based on the draft Rules on establishing, maintenance and keeping the Register of beneficial owners, the filing will be done electronically and will not include any charges.