Canada    FinTech Guide    Chapter 6    Serbia

6. Virtual Currency - Bitcoin
Serbia  Serbia

So far, only few Serbian companies have chosen to accept e-currency as a method of payment.

Legal Affairs

In the Republic of Serbia, issuing virtual currencies is a regulated activity and may be performed only after the license from the NBS for an electronic money has been obtained. The license may be issued after the applicant for the license fulfil all necessary requirements. After obtaining the license the applicant may be inscribed as an electronic money institution in the register of the electronic money institutions held by the NBS.

For virtual currency issuing, the applicant has to submit relevant documentation to the NBS based on which the NBS will decide on issuing of license. The documents necessary for obtaining the license are enlisted in the PS Law and include the request for obtaining the license for issuance of electronic money in a form provided by the NBS, decision on registration in companies register, articles of association (and memorandum of association), business plan, list of payment services to be performed as well as descriptions of risk management systems, organizational structure, internal control and audit, participation in payment systems, capital requirements proof, etc. All documentation should be submitted to the NBS in original or certified copy in Serbian language or accompanied with the official translation in Serbian and should not be older than 6 months in the moment of delivery to the NBS. Registration costs include fee to be paid to the NBS, which amounts to approximately EUR 650 for license for incorporation, and fee for each amendment to the license, amounting to approximately EUR 330. Costs may also include translation services for the documents required from the NBS and lawyers’ and financial advisors’ costs for preparation of these documents. Minimum capital requirements for the electronic money institution in Serbia amounts to EUR 350,000. The capital of the electronic money institution cannot in any moment be lower than minimum capital requirements stated above increased for the capital requirement calculated in accordance with the formulas provided in the relevant NBS decision.

Economic Conditions

Based on the PS Law which was adopted in 2014 and came into force on 1 October 2015, and was amended in 2018 a new type of payment service has been introduced to the PS Law. At the session held on 13 October 2016, the Executive Board of the NBS made the decision to award a license to issue electronic money to the company iPay See d.o.o. Beograd (“iPay See”). By this decision iPay See became the first e-money institution and in 2019 Preduzeće za telekomunikacije Telekom Srbija akcionarsko društvo, Beograd obtained the e-money license and became the second company enlisted on the website of NBS.

Additionally, the list of electronic money institutions from third countries that operate in accordance with the FX Law in Serbia is below: (1) Payoneer (EU) Limited, (2) PayPal Pte. Ltd., (3) Skrill Limited, (4) Paysafe Financial Services Limited, (5) Google Payment Corp., (6) Payeer Ltd. To clarify, in order for Serbian residents to be allowed to perform payment transactions with each other through, for example, PayPal Pte. Ltd. or Skrill Limited, it is necessary that these are licensed with the NBS as an electronic money institution. To date, none of the foreign electronic money institutions did not submit a request for license with the NBS, therefore, these currently serve to residents (both natural and legal persons) for performing payment transactions abroad, in accordance with FX Law, but not for their mutual payments in domestic payment transactions.

Contributing Authors

Karanovic & Nikolic

Marko Ketler
Belgrade, Serbia

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Chapter Index:

1. Payment Services / Mobile Payment

2. Asset and Portfolio Management

3. Consulting and Broking Services / Robo-advisory / Auto-trading

4. Trading Platforms / Social Trading Platforms / Signal Following

5. Crowdfunding / Crowdinvesting / Crowdlending

6. Virtual Currency - Bitcoin

7. Loan Services / Factoring / Loan Broking / Finetrading

8. Online Banking Services

9. Analytics and Research / Data Management / Risk Management

10. Accounting

11. Identification

12. Online-pawning

13. InsurTech

14. RegTech

15. Initial Coin Offerings (ICOs)

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.

Publication Date: 1 August 2019