Payment and E-Money Institution licence in Serbia

Payment and E-Money Institution licence in Serbia

Payment and E-Money Institution licence in Serbia

We assist in the full licensing process of obtaining a Payment or E-money Institution licence in Serbia

If you are looking to obtain an Authorised Payment or E-money Institution licence in Serbia, Advapay can offer you its legal, technical and business expertise and consulting support.


Application preparation, communication with the regulator, business services

Filling out an application form

Communication with regulatory authority during the application phase

Assistance in the development of a business plan

Assistance in the opening of safeguarding accounts

Hiring local team and launch of the Serbian office


Preparation of legal, financial and IT documents

Legal documents – AML, KYC, IT/Security policies, etc.

Financial documentation – 3-years financial forecast, P&L statement, the flow of funds

Company operational documentation – internal policies, risk operation policies, internal audit, etc.

IT documentation

Fintech and Startups in Serbia

Serbia has emerged as a thriving startup hub, driven by its abundant pool of tech talent and the proactive support of its government. This favorable environment has yielded impressive results, as evidenced by the outstanding performance of the Serbian ecosystem in 2021. Local startups secured a remarkable €123 million ($135 million) in investments, experiencing a staggering 600% year-over-year increase. Moreover, the Serbian tech sector achieved export revenue exceeding $1.7 billion during the same year.

To further bolster the growth of the startup scene and foster innovation, the Government has devised the Strategy for the Startup Ecosystem Development of the Republic of Serbia for the period from 2021 to 2025. This strategic plan encompasses various initiatives, including the introduction of entrepreneurship education at all educational levels and the enhancement of infrastructure and support programs. The ultimate objective is to establish up to 1,200 active startups in Serbia, attracting investors from around the globe.

Serbia’s commitment to advancing AI research and applications is evident through the Science Fund, which plans to invest €5 million ($5.5 million) in startup grants by the end of 2022. Additionally, Serbia has established Science Technology Parks in collaboration with universities in four cities: Belgrade, Niš, Novi Sad, and Čačak. Notably, the Institute for Artificial Intelligence Research and Development of Serbia, founded in 2021, serves as a central hub for AI-related endeavors and is headquartered in Novi Sad.

The Innovation Fund has introduced a new acceleration program called Katapult, designed to provide mentorship, financial support, and networking opportunities to startups in both the ideation and growth stages.

The future holds immense promise in Serbia’s tech landscape, as evidenced by recent developments. The Faculty of Economics at the University of Belgrade has taken a significant step forward by establishing its own incubator. This incubator aims to nurture innovative tech solutions developed within the university, further enriching the ecosystem alongside existing incubators within Serbian universities’ tech schools.

The Digital Serbia Initiative (DSI) serves as a vital non-governmental organization with a strategic vision to cultivate a robust and globally competitive digital economy in Serbia. This non-profit entity brings together the expertise and resources of over 30 member organizations representing various sectors crucial to the growth of the digital ecosystem. These sectors include technology, banking, finance, telecommunications, consulting, legal services, education and research, media, pharmaceuticals, and startup support organizations. By fostering collaboration among these diverse stakeholders, the DSI aims to drive the digital transformation of Serbia’s economy and enhance its global competitiveness.

Regulator and legislation

The National Bank of Serbia is independent and autonomous in carrying out its tasks laid down by the NBS Law and other laws, and is accountable for its work to the National Assembly of the Republic of Serbia.

The Executive Board that consists of the Governor and Vice-Governors of the National Bank of Serbia, performs activities to maintain and strengthen the stability of the financial system. With regards to NBS’s supervisory role, the Executive Board is tasked with issuing regulations in compliance with the relevant laws. The regulations pertain to the issuance and revocation of licences for payment institutions that provide payment services or electronic money institutions that issue electronic money.

Doing business in Serbia

Companies in Serbia can take advantage of different significant tax-related benefits.

Payroll Tax Incentives
First, employers who hire individuals registered with the National Unemployment Agency for more than six months are eligible for sizeable payroll tax incentives. The amount of tax relief varies based on the number of new jobs created. A 65% reduction applies to 1-9 new jobs, a 70% reduction applies to 10-99 new jobs, and a 75% reduction applies to 100 or more new jobs. It’s important to note that payroll tax incentives cannot be combined with financial incentives.

Double Taxation Treaties
Secondly, Serbia has 62 effective double taxation treaties that cover income, capital, and property. These treaties provide tax relief to businesses that operate in Serbia and have income, capital, or property in other countries that have signed the treaties. Serbia has double taxation treaties with numerous countries in Europe, as well as in Asia and Africa.

Research and development (R&D) double deduction
For corporate income tax purposes, companies may deduct their research and development (R&D) costs related to R&D activities performed in the Republic of Serbia. This incentive allows companies to double deduct these costs. However, it’s important to note that this incentive doesn’t apply to R&D costs incurred in extractive industries such as the exploration of oil, gas, or mineral resources.

Investments into newly established companies performing innovative activities
Taxpayers can receive a tax credit worth 30% of their investments made into newly established companies that carry out innovative activities. However, the maximum amount of tax credit that can be claimed is RSD 100 million.

Corporate Income Tax Relief
Investors who invest over 8.5 million euros (equivalent to 1 billion RSD) and hire more than 100 employees are eligible for a 10-year Corporate Profit Tax Holiday. This incentive applies once the company begins to generate profits.

Terms for obtaining a licence

The deadline is three months from the moment of proper documentation filing for the NBS’ decision. If improper documentation is filed, NBS informs the applicant about it within one month and requests additional information and revisions. This process can repeat indefinitely. Three-months deadline starts from the moment of filing proper documentation.

Main requirements

A director has to evidence good business reputation and adequate professional qualifications.

Initial Capital requirements
Depending on the services a Payment Institution plans to provide, amounts of the share capital range from EUR 20.000 for the money remittance services only to EUR 125.000 for other services. The share capital necessary for obtaining an E-money licence is EUR 350.000.

Funds safeguarding requirements
To ensure the timely fulfillment of its financial obligations to users of payment services, the applicant, being a Payment or E-money Institution, has several options at its disposal. These include entering into an insurance contract with an insurance company, obtaining a suitable bank guarantee, or opening an escrow account with a bank specifically designated for depositing the funds or assets in which it plans to invest.


1) Decision on entry of the applicant in the register of business entities

2) Articles of incorporation and/or articles of association of the applicant

3) Members of managing bodies and directors of agents of payment institution and electronic money institution

4) Assessment of risks to which the payment institution will be exposed

5) Programme of activities and business plan of a payment institution

6) Evidence that the applicant holds the prescribed level of initial capital

7) Projection of the amount of capital requirements for the first year of operation of the payment institution

8) Description of planned measures for safeguarding of payment service users’ funds

9) Description of organisational structure, management system, internal controls and internal audit systems, including measures put in place in order to comply with requirements arising from regulations governing the prevention of money laundering and terrorism financing

10) Description of participation in payment systems

11) Data on persons who are members of managing bodies

12) Data on persons having a qualifying holding

13) Data on external auditor

14) Data on persons having close links with the applicant and description of such links

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We have a strong focus on fintech businesses like digital banks, e-wallets, fiat-crypto wallets & e-commerce banking with the main product Digital banking.

We do not work with businesses that ONLY provide remittance services without opening payment accounts.

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