The transparency register in the 4th AML directive in Slovenia

The "Prevention of Money Laundering and Terrorist Financing Act" (Zakon o preprečevanju pranja denarja in financiranja terorizma) is the legal basis for the Transparency Register and implements the Directive in Slovenian law.

The amendments to the Act implementing the Directive entered into force on 11 July 2020.


There is no obligation of the UBOs to proactively provide the legal entity with information, but if requested by the legal entity they must provide all the information the legal entity needs to fulfil its obligations under the Act.


The legal entity.

5. Are there exemptions to the filing obligation?


Exempted are business entities that are companies in an organised market in which they are obliged to comply with a disclosure requirement that provides suitable transparency of ownership information as per the legislation of the European Union or comparable international standards.

6. What is the due date for the initial filing? Is there an obligation to update the filing?

The initial filing must be made within 8 days of the entry in the Slovenian business register (or tax register). 

Any update of beneficial ownership information must be made within 8 days from the change. 

In cases when the filing in the Transparency Register is done automatically and the registered UBO is not the actual UBO or not all actual UBOs are registered, the legal entity must correct the filing within fifteen days of the entry of the entity in the business register and any updates must be made within fifteen days of the change occurring.

7. 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(s) or if it fails to establish and manage a detailed record of the information regarding its beneficial owner(s) or if it fails to update it with every change or if it does not retain the information regarding its beneficial owner(s) for five years from the date of termination of the status of beneficial owner.

Fines may be also imposed on responsible persons in legal entities and, if they fail to provide the relevant information to a legal entity, on UBOs.   

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

The register is established as a separate register, although it is maintained and managed by the Agency of the Republic of Slovenia for Public Legal Records and Related Services (AJPES), which also maintains a business register. Filing is done online via the AJPES web portal and is free of charge.

9. Notable amendments (including through the Directive)

In certain cases, filing in the Transparency Register is done automatically, but the legal entity must check the filing and ensure the listed UBO is also the actual UBO. With the latest amendments, the Slovenian Act now also provides a legal basis for connection to the European Central Platform.