Payment institutions and electronic money institutions

Adoption of the Law on Payment Services (applied as of 1 October 2015) rounded off a series of NBS activities aimed at setting up a comprehensive regulatory framework in the area of payment service provision and e-money issuance and represented a huge step forward in modernisation of the national payment system. It also instilled greater security and advanced consumer protection, in parallel with increasing the efficiency of payment transactions and creating the legal basis for the development of innovative forms of payment.

On 31 July 2024, the Serbian National Assembly adopted the Law Amending the Law on Payment Services, applied since 6 May 2025. Amendments to the Law on Payment Services aim to  further stimulate innovation in the market and ensure greater competition and transparency in the field of payment service provision, as well as improve consumer protection and payment security, introducing, among other things, two new types of payment services (payment initiation service and account information service), and two new types of payment service providers (account information service provider and payment initiation service provider).

Limited network

Service providers performing one or both activities referred to in Article 3, paragraph 1, item 11), sub-items (1) and (2) of the Law on Payment Services, where the total value of payment transactions executed during the previous 12 calendar months exceeds one million euros in the dinar equivalent at the NBS official middle exchange rate on the date of the transaction, are required to notify the NBS no later than the 15th day of the current month, specifying how and why these activities should be considered as activities under those sub-items to which the provisions of this law do not apply. This notification must also include a detailed description of how these activities are carried out. Based on the submitted notification, the NBS will decide whether the activities described therein are to be considered as activities under Article 3, paragraph 1, item 11), sub-items (1) and (2) of the Law on Payment Services to which the provisions of this law do not apply. Service providers and the description of activities that are the subject of the notification will be published in the register of payment institutions. Examples of the use of payment instruments in limited network services include: a gift card from a specific retail chain that can only be used to purchase goods and services within the premises of that retail chain; a payment instrument such as a card or application that allows the holder to purchase goods and services only within a limited network of merchants (e.g. a shopping mall), based on a contract concluded directly with the issuer, or that allows the holder to purchase a very limited range of goods and services (e.g. cards for paying transportation services).

Electronic communications operators

Service providers engaged in the activity referred to in Article 3, paragraph 1, item 12) of the Law on Payment Services are required to notify the NBS about this activity and to submit, at least once a year, an opinion from a certified auditor from an audit firm authorised to audit banks, confirming that the activity is in compliance with the limitations prescribed in that item. Service providers and the description of the activities that are the subject of such notification will be published in the register of payment institutions. This refers to payments made through electronic communications operators where the value of a single transaction does not exceed 6,000 dinars. Examples of such services, which are provided to users and charged along with electronic communication services, include the following types of payments made through mobile network service providers: purchasing digital content such as applications, music or movies; payments via SMS messages for collecting donations for humanitarian purposes or for purchasing tickets (e.g. for public transportation or parking).

Notification regarding unauthorised payment service provision  

In Serbia, without the special licensing by the NBS, payment services may be provided only by banks or a public postal operator – directly or via their authorised agents. All other entities, i.e. payment institutions and e-money institutions within the meaning of the Law on Payment Services, may provide payment services, directly or via their authorised agents – only subject to the NBS’s licensing and only those services they are licensed for.

As noted in our previous press releases regarding the implementation of the Law on Payment Services, we hereby inform the public that the NBS keeps registers of payment institutions and e-money institutions duly licensed by the NBS. Apart from data on services they are licensed to provide, the registers also contain data on the authorised agents through which these institutions may provide payment services, so that the public can be duly informed on which companies (apart from banks and the public postal operator) are authorised to provide payment services under the law.

The NBS continuously supervises the operations of entities suspected of unauthorised payment service provision and takes all measures within its remit to prevent such unlawful behaviour. We also invite citizens to share with us any information about such cases, via email platni.sistem@nbs.rs, or at the NBS address – Kralja Petra 12, 11000 Belgrade. The reports may also be submitted anonymously.