Obligations and requirements to provide payment services or ancillary services described above
In the Republic of Serbia provision of payment services is a regulated activity and may be performed only by the local entities licensed by the NBS. It is not possible to apply for a 'passport' of a foreign license in Serbia. Payment services may be provided by the banks, payment services providers and electronic money providers.
The documents necessary for obtaining the license are listed in the PS Law and relevant NBS decisions/by-laws and include for example business plan, list of payment services to be provided, as well as descriptions of risk management systems, organizational structure, internal control and audit, participation in payment systems, capital requirements proof, etc.
Registration costs include a fee to be paid to the NBS amounting to approximately EUR 1,900 for license for incorporation. 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 are EUR 10 million for ? bank, EUR 20,000 to EUR 125,000 for a payment institution (depending on the type of payment services which will be covered by the license), and EUR 350,000 for electronic money institution. All payment services within the scope of the PS Law require a license, except in cases explicitly excluded under the PS Law (e.g., payment transactions in cash, transport of cash, exchange services in cash, etc.).
Additional comments regarding the legal situation for payment services or what FinTech’s must be aware of in this business area
Amendments to the PS Law also bring a regulatory sandbox mechanism for testing new types of services without complying with the regulatory requirements and incurring associated costs. Specifically, the NBS may prescribe closer conditions under which a company or a payment service provider may be exempted from the application of all or specific provisions of the Law in a defined period, for testing of the service, if such service is by nature such to contain a certain degree of innovation due to which it could be considered as new or significantly enhanced payment service compared to payment services already provided in Serbia. Such bylaw has not yet been adopted by the NBS, however, this may be expected as part of the continued policy of the regulator to encourage innovations in the payment services area.
Economic conditions
Market size for payment services and biggest payment service providers
In July 2025, there are 19 banks, 8 payment institutions and 6 electronic money institutions. The merger of Eurobank Direktna Banka with AIK Bank was finalized on March 31, 2025, making AikBank the third largest bank in Serbia with total assets of 6.4 billion euros. According to the business results for 2024, the banks in Serbia with the highest market share remain Banca Intesa, OTP Srbija and Raiffeisen bank.
Additional comments regarding the economic situation for payment services or what FinTech’s must be aware of in this business area
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