The Decision on External Bank Audit (RS Official Gazette, No 63/2025) establishes the criteria based on which the NBS compiles and publishes the List of External Auditors who may audit financial statements of a bank (hereinafter: List).
The criteria that external auditors must fulfil in order to be listed are as follows:
- comply with the conditions prescribed for audit firms by the law governing audit;
- employ at least six certified auditors licensed to perform audit, at least three of whom have a minimum three-year work experience in auditing financial statements of banks;
- employ at least 20 staff members in the organisational unit responsible for audit operations;
- the audit firm, its legal representative and employees who are certified auditors licensed to perform audit have good business reputation.
To become listed, an audit firm shall submit to the NBS a written request together with supporting documentation proving compliance with the above criteria. The documentation must be in the Serbian language. If the original is in a foreign language, a translation into Serbian, certified by a court-appointed interpreter, must be submitted alongside the original or a certified copy of the document. If the documentation is in a language other than Serbian or English, and it is not possible to obtain a translation directly into Serbian, a translation into English must be submitted, along with a translation of that English text into Serbian, with both translations certified by a court-appointed interpreter.
To be included in the list, an audit firm shall submit the following documents to the NBS, proving the fulfilment of the above criteria:
- excerpt from the Business Entities Register certifying to the present registered status of the audit firm, including all data from that Register;
- licence to engage in audit operations issued by the ministry in charge of finance;
- certificates and audit licences issued by the Chamber of Certified Auditors for at least six certified auditors from the audit firm, and statement of a legal representative of the audit firm on banks and periods in which at least three of these persons audited financial statements of banks, documents of the audit firm setting out the internal organisation of the firm and job classification, and the statement of a legal representative of the firm, with the list of employees (specifying name, surname, personal identification number, title and years of service) working in the organisational part in charge of audit operations;
- methodology it will apply in performing the audit of the bank’s financial statements;
- a certified statement from the legal representative of the audit firm, given under criminal and material liability, proving the fulfilment of the above criteria as of 30 June of that year;
- information on whether any measures have been imposed on the audit firm, its legal representative, or the employees who are certified auditors licensed to perform audit, in a quality control review procedure in accordance with the law governing audit (including the imposition of a fine for identified irregularities in work) or other measures in accordance with regulations;
- a certificate from the competent authority of the Republic of Serbia or a foreign country, confirming that neither the audit firm, its legal representative, nor the employees who are certified auditors licensed to perform audit have been convicted by a final judgment of criminal offences rendering them unfit to audit the bank’s financial statements, or a certificate of non-conviction for these acts and proof that they have not been subject to the protective measure banning them from practising activities which are wholly or partly related to the subject of the audit of the bank’s financial statements, as well as whether proceedings for the said criminal offences are ongoing against these persons;
- proof of payment of a fee to the NBS, in accordance with Tariff Number 4, paragraph 12 of the Decision on the Single Tariff under which the National Bank of Serbia Charges Fees for the Services Provided;
- and proof of payment of the state administrative tax in accordance with Tariff Numbers 1 and 9 of Section A of the Tariff of Republic Administrative Taxes of the Law on Republic Administrative Taxes.
A listed external auditor is obliged to submit documentation to the NBS, proving that the prescribed criteria have been met as of 30 June of the current year, once annually, by no later than 15 July of that year. This shall include a statement by the audit firm’s legal representative, given under criminal and material liability, proving that the listed external auditor did not conduct audit of the bank’s financial statements during the same year, nor conduct audit for the business year in which he/she provided these services, as well as that he/she did not conduct an audit of financial statements of the bank for the business year in which one of its employees was temporarily hired to work in, or the audit of financial statements of the bank by which he/she was temporarily hired at the time of conducting the audit. In addition to this, the external audit shall submit to the NBS by no later than 31 October of the current year a plan of auditing activities including individual audits of financial statements of the bank for that business year.
In line with amendments to relevant regulations or independently thereof, the NBS will align and update the list of documents that need to be enclosed with the request for inclusion in the List, i.e. in order to prove the fulfilment of the set criteria for inclusion in the List.
