CMS Expert Guide to the transparency register in AML directive

Transparency Register pursuant to the fourth European Money Laundering Directive – Status of Implementation in Selected EU Member States

The current legal basis of the Bulgarian Transparency Register is Chapter II, Part VI of the Bulgarian Anti-Money Laundering Measures Act (Закон за мерките срещу изпирането на пари) published in State Gazette Issue No 27/2018 on 27 March 2018, effective from 31 March 2018.

Further amendments implementing the Directive were promulgated in State Gazette Issue No 94 dated 29 November 2019.

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.

Only upon request.

The UBO is obliged to provide the legal entity with all documents and information required for the purposes of fulfilling transparency obligations upon request.  


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.


There is an obligation for the legal entity to have and to keep adequate, accurate and up-to-date information on the identity of the UBO.


The legal entity.

The legal entity.

5. Are there exemptions to the filing obligation?


There is an exemption if the required information is already available in the relevant registers.


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?

1 February 2019 – 31 May 2019.

Yes, if there is a change in circumstances.

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?

Fines range between EUR 250 and EUR 2,500 for responsible managers of a legal entity. Fines for legal entities range between EUR 500 and EUR 5,000.

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 Bulgarian Transparency Register is part of two existing public registers: the Commercial Register and the BULSTAT Register.

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.