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Payment services
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FinTechs belonging to this category offer alternative payment services which are supposed to provide a faster and cheaper way for national, European, and international payments for private and business customers by using new technologies.

For example, payment service providers hereby offer solutions to easily integrate several payment services in online shops.

Some FinTechs furthermore provide real cash register systems and online-reservation solutions for restaurants and shops providing their own payment services or making use of the payment services of FinTechs described above.

Introduction

Attitude of the country towards modern payment services

Payment services in Serbia may be provided only by the locally licensed banks, payment services providers and electronic money providers. Payment services are regulated in the Law on Payment Services (“PS Law”) which is harmonised with PSD1 (although not with PSD2). 

In case these services are provided in Serbia from abroad, besides licensing issues, the services providers must also be aware of very strict foreign exchange rules aimed at monitoring outflows of cash from the country which are set out in the Law on Foreign Exchange (“Forex Law”) and bylaws. Forex Law regulates in detail payments to/from abroad and should be observed in case of cross-border payments. This law is interpreted by the NBS restrictively in the manner that only transactions that are explicitly regulated by the law are permitted, whereas transactions which are not recognised by the law are prohibited.

The National Bank of Serbia (“NBS”) which is the regulator and the supervisor in the area of payment services, is devoted to further development of modern payment services through adoption of various strategies, such as the National Retail Payments Strategy 2019-2024 which goal is to double the current number of electronic payments per adult citizen. 

In 2018, the NBS introduced an instant payment system (IPS system) that gives users the possibility to transfer funds any time of the day, 365 days a year, through standard channels for initiating transactions (bank tellers, mobile and electronic banking applications), but many other functionalities as well. The NBS has also standardized IPS QR code which enabled instant payments at merchants’ points-of-sale, online point-of-sale as well as payment of invoices by scanning the NBS IPS QR code printed on the bills and invoices using a mobile banking application. 

Modern payment services currently centred around banks and services they are able to provide in this area. Banks are increasingly focusing on digitalization of payment services following a noticeable shift towards online payments during COVID-19 pandemic. 

Legal affairs

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 includes a fee to be paid to the NBS amounting to approximately EUR 1,900 for license for incorporation. Costs may also include tra

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