Global FinTech Guide
Country Name
Bosnia and Herzegovina
Online banking services
FinTechs belonging to this area offer traditional banking services in a modern way, usually through online services or mobile applications as well as ancillary services – e.g. enabling customers to manage their giro- or custody-accounts online and in real time or offering e-wallet services. Keywords in this context are also API-Banking oder BaaS/BaaP.


API stands for application programming interface and is offered to access data banks and to extract and insert information. API-Banking consequently means the access to data banks of banks to offer new and innovative banking applications.

Through these services FinTechs offer services with new functions, e.g. enabling customers to manage their accounts online and in real time.

BaaS – Bank as a Service/BaaP – Bank as a Platform:
The API-based Bank as a Service platform has a full banking licence, but merely serves as the back end for standalone independent FinTechs, which “use” the licence and the back end of the bank to offer new financial services, launch additional financial products or expand into additional markets.


Attitude of the country towards online-banking services

Most banks in BiH offer to their clients the possibility of payments and money transfer via m-banking services and with the reduction of e-banking costs, it has become a popular method of payment and money transfer, especially during the COVID-19 pandemic. Therefore, the Bosnian banks do not lag behind the latest trends.

Legal affairs

Obligations and requirements to provide online-banking services described above

Online banking services in BiH can be performed only by licensed banks. The banking sector may outsource activities, provided such outsourcing complies with minimum standards and reporting obligations as stipulated in the applicable regulations. The banks are allowed to outsource activities to a legal person authorised to perform these activities, however the service provider has the obligations:

  • not to disclose or publish the visit of third parties;
  • to keep banking and business secrets;
  • to inform the principal in a timely manner about all facts and changes in circumstances that significantly affect or that could significantly affect the fulfilment of contractual obligations; and
  • to act in full compliance with the BiH legislation.

Additional comments regarding the legal situation for online-banking services or what FinTech’s must be aware of in this business area


Economic conditions

Market size for online-banking services and biggest companies in this business area

There is no real market for these kinds of services since they cannot be provided by any other entities except licenced banks and micro-credit organizations. There are 15 banks in FBiH and 8 in RS, while the largest players on the banking market are Raiffeisen Bank, UniCredit Bank, Intesa Sanpaolo Bank and Sparkasse Bank.

Additional comments regarding the economic situation for online-banking services or what FinTech’s must be aware of in this business area




© 2022, Karanovic & Partners in cooperation with local lawyers. All rights reserved by Karanovic & Partners in cooperation with local lawyers as author and the owner of the copyright in this chapter. Karanovic & Partners in cooperation with local lawyers has granted to Multilaw non-exclusive worldwide license to use and include this chapter in this guide and to sublicense Lexis Nexis, a division of RELX Inc. and its affiliates certain rights to use and distribute this guide.

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.


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