Any factual change of the beneficial owner is reported in the Beneficial Owners Register within 90 calendar days from the date it occurs (Article 5(3)(c) of Law No. 112/2020The application is made online on e-Albania, free of charge. In addition, failure to comply with the deadline is punishable by a fine of 400,000 lekë.
The case we encounter most often in practice: the company registers the sale of shares in the commercial register and considers the matter closed. In fact, the commercial register and the Register of Beneficial Owners are two separate registers. Therefore, a change in partnership is not automatically reflected in the RBO and requires a separate application. The deadline is 90 days from the date of the deed, not from the day you remember.
Below you will find the instances when the obligation arises, the application steps according to the three form scenarios, the required documents, and the consequences of delay.
Read also: Initial registration of the beneficial owner.
The obligation covers any factual change of the person registered as the beneficial owner and any other change in the recorded data. Typical cases:
The 90-day period is calculated from the date on which the actual change occurs, that is, from the date of the sales contract, the assembly's decision, or the relevant act.
Read also: Changes to the LLC at the QKB.
The application is submitted by the person authorized to represent the entity, using an electronic signature. Thus, the application is made through the “Application for Change of Information in the Beneficial Owners Register“.
After identification, the system opens the file under the case number and automatically retrieves the subject's data from the relevant registry. The form has three scenarios, and you select the one that applies to your case:
When a new individual is added as a beneficial owner to the entity, select the “Register New Beneficial Owner” option and complete his mandatory information: identification, address, ownership type and percentage, and the date of determination. If the ownership is indirect, use the “Add Person” button to complete the entire chain of legal entities up to the individual. You must do this based on the supporting documentation.
When an individual is no longer the beneficial owner, the “Departing Beneficial Owner” option is selected and their details are completed along with the document proving the departure, e.g., the share transfer agreement.
When the data of a previously registered owner change, select the “Change existing registered beneficial owner data in the register” option. Choose his name and complete the new information based on the actual situation.
After completion, the documents are uploaded, the form is electronically signed and submitted. You receive a copy by email and the application status is… Follow with the case number..
Cost: no fee. QKB decision: within 2 business days.
✔ Documentation proving the NUIS and the entity's name, with the registration date
✔ Documentation verifying the beneficial owner's identification data
✔ Documentation from the registration authority confirming ownership of 25% or more and the date of determination, or the document proving the change (share transfer agreement, assembly resolution)
✔ Power of Attorney, if the application is submitted with authorization from a third party
✔ Statement of the legal representative, only when, after the change, no individual is identified with 25% or more.
Note: the NUIS document and the document proving ownership must have been issued within 90 calendar days prior to the application date (Chapter III, letter “ç”, e Government Decree No. 1088/2020Foreign documents must be accompanied by a certified translation and either legalization or an apostille.
You can find the statement template for the case without individual 25% at Initial registration page.
Read also: How to declare the beneficial owner at the QKB.
The authorized officer decides no later than two business days from submission: approves the request or suspends it with the relevant reasons, giving you 30 calendar days to address the deficiencies. Otherwise, he may reject the request when the requested data differ from the recordable data.
If you address the deficiencies within the deadline, the registration is approved and retains the date of the original application. Thus, the 90-day period is not considered lost. The registrar verifies the form and completeness of the file, not the veracity of the documents. However, responsibility for the accuracy of the data remains with the entity and the authorized person (Article 13, paragraph 1).
Decisions are notified by publication in the register and by email. An administrative appeal is directed to the QKB holder within 30 calendar days of publication (Article 11), and thereafter to the administrative court.
Failure to register changes within the 90-day deadline is punishable by a fine of 400,000 lek (Article 13, paragraph 2, letter “d” of Law No. 112/2020, as amended).
Except for the fine, until it is paid and registration is completed, the QKB does not provide any other services to the entity, with the exception of changing the legal representative. Additionally, the status changes from active to suspended. Reapplying after a refusal does not relieve you of the fine for the expired period.
Read also: Registration of foreign businesses.
The law also has a control mechanism (Article 6, paragraph 3 and Chapter VI of Government Decree No. 1088/2020). If an obligated entity, e.g., the bank where you hold your account, finds that the data in the RPP do not match the data it holds itself, it notifies you and the QKB in writing within 10 days. Then, the QKB publishes the notice in the register within two business days.
From the date of the QKB notification, you have 20 calendar days to take one of two actions:
If you do not act within 20 days, the QKB and the OJF registry will suspend your services until the situation is clarified.
Read also: The register of beneficial owners is changing. What does the new 2026 draft law bring?.
A person who is registered as a beneficial owner of an entity without actually being one has the right to file a lawsuit against the entity in the competent court to prove that they are not the beneficial owner (Article 10). Upon filing of the final decision, the QKB corrects the information within two business days.
Every time there is a tax or financial change that affects your business, we notify you directly by email with a practical explanation.
Send me free notificationsYes. Registration in the commercial register does not automatically update the Beneficial Owners Register. A separate application must be submitted to change the information within 90 days from the date of the contract. If you do not apply, the fine is 400,000 lek.
Yes. The beneficial owner is traced to the individual at the end of the chain. When that individual changes, even if the intermediate links remain the same, the change must be reported in the RPP within 90 days.
From the date the actual change occurs: the date of the share transfer agreement, the shareholders' assembly resolution, or the relevant deed. It is not calculated from the date the change is registered in the commercial register.
You have 20 calendar days from the QKB notification to update your data or confirm the existing information using the confirmation service on e-Albania. Otherwise, failure to act will result in service interruption.
Nothing. Both changing and confirming data are free of charge on e-Albania.
Law No. 112/2020 “On the Register of Beneficial Owners,” as amended by Normative Act No. 12/2021 and Law No. 6/2022 (Article 5(3)(c); Article 6; Article 10; Article 11; Article 13)
Decision of the Council of Ministers No. 1088, dated December 24, 2020, as amended by Decisions of the Council of Ministers No. 273/2021 and No. 328/2022 (Chapters II, III, IV, VI)
Source: National Business Center.
