title: Serbia Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/serbia/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # Serbia RS schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 69 sourced findings · 122 sources in the cumulative register 14 Modules baseline.modules[] 69 Findings modules[].findings[] 72 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) ## Jurisdiction brief ###### Latest update · 5 October 2026 #### Lead Signal Serbia's National Bank of Serbia tabled, in July 2026, an extensive draft legislative package under EU accession Negotiation Chapter 9, Financial Services, touching payments, banking, insurance, consumer protection, financial conglomerates and pension funds. Within that package two instruments matter most for payments: a Draft Law on Payment Services and a companion Draft Law amending the Law on Interchange Fees and Special Operating Rules for Card-Based Payment Transactions. The Draft Payment Services Law introduces a formal fraud-reporting and inter-PSP fund-recovery procedure for suspected fraudulent payment transactions, targets SEPA integration, and aims at settlement-finality alignment with EU standards, with a nine-month implementation period proposed from entry into force. The companion interchange-fees instrument would, for the first time, extend Serbia's interchange-fee caps to certain international card transactions, proposing ceilings of 2 percent and 3 percent for debit and credit card-present transactions respectively, and 15 percent and 5 percent for debit and credit card-not-present transactions respectively. Taken together, these are the most significant licensing and market-access developments in Serbia's payments regime in this cycle, and they are explicitly accession-driven: the legislative vehicle is Chapter 9 of the EU accession process rather than a domestically initiated reform agenda. #### Other Developments **The interchange-fee extension marks a material scope expansion.** Until now, Serbia's interchange-fee caps have applied domestically; extending them to certain international card transactions would bring cross-border card economics for schemes and issuers operating in Serbia into closer alignment with the EU's own interchange-fee regulation framework, a change with direct relevance for scheme compliance and commercial card-issuing economics in the market. **The fraud-reporting and fund-recovery procedure is a genuinely new obligation.** Rather than an incremental tightening of existing payment-services supervision, the draft introduces a formal mechanism obliging payment service providers to report suspected fraud and participate in inter-PSP fund-recovery procedures, a structural addition to Serbia's consumer-protection and operational-conduct architecture for payments that does not currently exist in equivalent form. #### Cross-Monitor Connections The accession-driven nature of this legislative package connects directly to broader EU-accession-tracking work, since Chapter 9 compliance is a formal benchmark in Serbia's EU membership negotiations and the simultaneous modernisation of payment-services law and interchange-fee regulation signals a coordinated push to close gaps identified in that accession review. Illicit-finance use of Serbia's payment rails, to the extent it exists, is a matter for financial-crime-focused monitoring rather than a conclusion drawn here; this brief confines itself to the regulatory and market-access dimension of the draft legislation. #### Outlook Both draft instruments remain at the consultation stage, with no enacted text or confirmed commencement date identified this cycle; current indications point to legislative progress unfolding into 2027. If adopted substantially as drafted, the nine-month implementation period proposed for the Payment Services Law would mean payment service providers operating in Serbia need a credible runway to build out fraud-reporting and fund-recovery capability well ahead of any formal entry into force. The interchange-fee amendments, if enacted with the proposed caps intact, would represent the most significant change to Serbia's card-economics regulation to date and warrant close tracking as the legislative process advances toward the next stage. _6 earlier updates not shown here._ ###### Standing brief · as of 4 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Serbia's payments regulatory architecture enters this monitoring baseline in an active harmonisation phase with EU frameworks, anchored by two concurrent developments now fully operational. The Law on Payment Services, as amended 31 July 2024, harmonised the domestic payment-services regime with PSD2, introducing open banking (PISP/AISP), a regulatory sandbox and tighter foreign-EMI registration, applicable since 6 May 2025. Running alongside that market-access shift, Serbia acceded to SEPA in 2025 and became operationally live for SEPA Credit Transfer schemes as of May 2026, with 18 banks currently participating; the European Commission set the earliest operational readiness date for May 2026 following a May 2025 geographical-scope inclusion decision. The National Bank of Serbia remains the sole authorising body for Payment Institutions and Electronic Money Institutions, meaning only banks and the public postal operator may provide payment services without NBS licensing while all non-bank PIs and EMIs require separate NBS authorisation. Taken together, these developments mark Serbia's payments regime as accelerating toward EU-equivalent market structure, opening cross-border euro corridor access to Serbian PSPs on more equal terms regardless of parent-bank EU domicile. #### Other Developments A new NIS2-aligned Law on Information Security entered into force 31 October 2025, aligning Serbia's cyber-resilience regime with EU standards and introducing "priority" versus "important" ICT operator categories covering financial institutions, with priority entities facing fines up to approximately EUR 17,000, double the maximum for important entities. Serbian payment service providers must separately implement operational and security risk-management frameworks and notify the NBS of significant incidents under the existing Payment Services Act framework, and must notify the NBS in advance of intended ICT outsourcing arrangements. On the card-scheme side, the Law on Interchange Fees and Special Operating Rules for Card-Based Payment Transactions caps interchange fees at 0.2%/0.3% for debit/credit transactions and mandates co-badging and unblending, modelled on EU Regulation 2015/751; Mastercard remains subject to a Serbian Competition Commission antitrust investigation over allegedly excessive fallback interchange fees, initiated in 2018 and still the landmark card-scheme conduct case in the jurisdiction. #### Cross-Monitor Connections Serbia's AML/CFT standing, including FATF grey-list removal, ongoing MONEYVAL enhanced follow-up, and the 2024 effectiveness ratings, is carried in this cycle as Sentinel.gi-fed provenance only; deeper illicit-finance and MONEYVAL-effectiveness analysis belongs to the Financial Intelligence Monitor rather than this monitor. The correspondent-banking access structure, under which local Serbian banks rely on relationships with major US institutions in the absence of any directly operating US bank, is a structural condition relevant to any parallel sanctions or illicit-finance assessment of Serbian cross-border flows. #### Outlook The near-term horizon centres on two already-in-force milestones consolidating rather than newly emerging: full SEPA operational readiness for Serbian PSPs as of May 2026, and the close of the open-banking transitional bylaw-adjustment period on 1 January 2026, after which existing PSPs must be fully compliant with the amended Payment Services Act's open-banking provisions. Continued NBS and Competition Commission attention to card-scheme conduct, and the bedding-in of the new information-security law's priority/important entity classifications, are the primary near-term watch items for Serbia's payments regulatory trajectory. None of these items individually alters the overall assessment that Serbia's payments regime is in a period of accelerating alignment with EU market structures, a trajectory this monitor will continue to track across the licensing, corridor and resilience modules addressed in the accompanying sub-briefs. Beyond these headline items, the accompanying sub-briefs track a broader set of structural conditions worth watching in parallel, including the still-nascent non-bank fintech investment base, the unresolved Mastercard antitrust matter, the digital-asset framework's exclusion of regulated financial institutions from direct participation, and the consumer-protection gap around authorised-push-payment fraud on the domestic instant-payments rail. Taken as a whole, this baseline cycle establishes Serbia as a jurisdiction moving from a domestically-anchored payments infrastructure toward deeper integration with EU regulatory and settlement frameworks, a direction this monitor assesses as liberalising overall. trust tier: ai_unverified ###### Latest update · 8 September 2026 #### Regulatory Status Serbia's payments regulatory environment is in an active liberalisation phase. PSD2-harmonising amendments to the Payment Services Law became applicable on 6 May 2025, introducing open banking and a National Bank of Serbia regulatory sandbox for innovative payment services. A further draft package tied to EU accession (Chapter 9) would remove the restriction barring payment and e-money institutions and postal operators from significant payment systems, narrowing the bank/non-bank access gap. Separately, the NBS consolidated its founding law in April 2026, reaffirming its payment-systems mandate, and draft card-scheme amendments would impose a new card-delivery-evidence obligation on DinaCard issuers. #### Outlook The EU-accession-linked significant-payment-system access reform is the most consequential item to watch, tentatively estimated for Q4 2026 but without a firm enactment date established this cycle. The DinaCard delivery-evidence obligation is a smaller scheme-specific item pending confirmation. _2 earlier updates not shown here._ ###### Standing brief · as of 4 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status The National Bank of Serbia is the sole authorising body for Payment Institutions and Electronic Money Institutions, with only banks and the public postal operator exempt from PI/EMI-specific licensing. Serbia's payments regulatory architecture, assessed across the monitor's 14-module spine for the first time in this baseline cycle, is in an active phase of harmonisation with EU frameworks. The Law on Payment Services, as amended 31 July 2024 and applicable since 6 May 2025, harmonised the regime with PSD2, introducing open banking (PISP/AISP), a regulatory sandbox, and tighter foreign-EMI registration. Serbia acceded to SEPA in 2025 and became operationally live for SEPA Credit Transfer schemes as of May 2026 across 18 banks, building on the NBS IPS instant-payment rail launched in 2018. A new NIS2-aligned Law on Information Security entered into force 31 October 2025, extending EU-equivalent cyber-resilience obligations to financial institutions. Card-scheme compliance rests on interchange-fee caps in force since December 2018, against the backdrop of a continuing 2018 Competition Commission antitrust action against Mastercard. Digital assets remain governed solely by the Law on Digital Assets' dual NBS/Securities Commission regime, with financial institutions barred from direct digital-asset activity beyond a narrow custody exception. On financial crime, Serbia remains off the FATF grey and black lists as of June 2026 but continues in enhanced MONEYVAL follow-up. Correspondent-banking access depends on local banks' relationships with major US institutions given the absence of any directly operating US bank in Serbia. Consumer protection runs through a free NBS complaint and mediation route, though no dedicated APP-fraud reimbursement scheme exists for the irreversible IPS rail. The sole discrete commercial event identified this cycle was Paysend's Belgrade technology-hub investment, against an otherwise thin fintech funding base of approximately USD 5.6 million cumulative over ten years across a sector of 20 majority-foreign-owned banks and 74-110-plus fintech firms. #### Outlook Serbia's regulatory direction is assessed as liberalising, driven primarily by the SEPA accession, open-banking go-live, and NIS2-aligned cyber law, layered onto a stable AML/CFT backdrop that nonetheless carries a continuing MONEYVAL effectiveness gap. The principal near-term milestones are the close of the open-banking transitional period on 1 January 2026 and continued expansion of SEPA-live bank participation beyond the initial 18. Structural gaps worth continued monitoring include the absence of a dedicated APP-fraud reimbursement scheme, the absence of a dedicated stablecoin-as-payment-rail framework, and the still-nascent non-bank fintech investment base. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access moved Probable confirmed 2026-07-04 Serbia's payment-services regime is being actively re-harmonised with the EU acquis under EU accession Negotiation Chapter 9: a May 2025 amendment aligned the Law with PSD2, and in mid-2026 NBS presented a further draft-amendment package covering fraud prevention/fund recovery, broader payment-system access, and settlement finality. Movement — CHANGED W1a trajectory escalating due to comprehensive Chapter 9 legislative package._Material new legislative activity in the licensing/market-access module this cycle._ Standing sub-brief · as of 4 July 2026 346 words · last cycle 2026-10-04 #### Licensing, Authorisation & Market Access The National Bank of Serbia is the sole authorising body for Payment Institutions and Electronic Money Institutions in the jurisdiction: only banks and the public postal operator may provide payment services without NBS licensing, while all non-bank PIs and EMIs require separate NBS authorisation under the Law on Payment Services. This bank-PSP versus non-bank PI/EMI distinction is the foundational structural line running through Serbia's payments market-access regime, and it recurs across conduct, scheme-compliance and correspondent-banking questions addressed elsewhere in this brief. The Law on Payment Services, as amended 31 July 2024, harmonised that regime with PSD2, introducing open banking (PISP/AISP), a regulatory sandbox, and tighter foreign-EMI registration requirements, all applicable since 6 May 2025. Existing PSPs had until February 2025 to adjust their internal bylaws to the new requirements, and local PSPs are now barred from processing transactions with unregistered foreign EMIs. For non-bank entrants, initial capital requirements are tiered by service type: EUR 125,000 for deposit/withdrawal services, EUR 20,000 for money remittance, and EUR 50,000 for payment processing conducted via telecommunications or IT networks, with the licensing process typically running three to six months from company registration. These thresholds and timelines position Serbia within a recognisably PSD2-adjacent capital-adequacy framework while still requiring a distinct, standalone national licensing process outside any EU passporting mechanism. The practical effect is a two-track market: bank-PSPs operate under general banking authorisation, while non-bank PIs and EMIs face a dedicated, capital-tiered NBS licensing track whose terms have just been substantially rewritten by the 2024 amendments. #### Outlook With the PSD2-aligning amendments now fully applicable and the transitional bylaw-adjustment period behind existing PSPs, the near-term trajectory for this module is consolidation rather than further rule change: attention shifts to how the open-banking and sandbox provisions are operationalised in practice, and to how tightened foreign-EMI registration is enforced against unregistered providers seeking to serve Serbian customers. The trend line remains escalating, reflecting an active harmonisation phase rather than a settled steady state, and this module's trajectory should be read alongside the open-banking product-development picture in the Product Innovation module. Periodic update · new data 2026-10-05 #### Licensing, Authorisation & Market Access The National Bank of Serbia tabled a comprehensive legislative package in July 2026 under EU accession Negotiation Chapter 9, Financial Services, encompassing payments, banking, insurance, consumer protection, financial conglomerates and pension funds. For the payments market specifically, two draft instruments carry the most direct licensing and market-access implications: a Draft Law on Payment Services, and a companion Draft Law amending the Law on Interchange Fees and Special Operating Rules for Card-Based Payment Transactions. Both remain at consultation stage, with no enacted text or confirmed commencement timeline identified, though current indications point toward further legislative progress into 2027. The Draft Payment Services Law is the more structurally significant of the two for licensed payment service providers operating in Serbia. It introduces a formal fraud-reporting and inter-PSP fund-recovery procedure for suspected fraudulent payment transactions, a mechanism that does not currently exist in equivalent form under the present Law on Payment Services. The draft also targets SEPA integration and settlement-finality alignment with EU standards, signalling an intent to bring Serbia's payment-services architecture materially closer to the EU's own regulatory baseline ahead of eventual accession. A nine-month implementation period is proposed from entry into force, which, if the draft proceeds broadly as currently framed, would give payment service providers a defined but relatively short runway to build the operational, reporting and inter-institutional coordination capability that a formal fund-recovery mechanism requires. The companion Draft Law on Interchange Fees represents a comparably significant market-access and commercial-economics development. It would, for the first time, extend Serbia's existing interchange-fee caps to certain international card transactions, a scope expansion beyond the current domestic-only application of those caps. The proposed ceilings are 2 percent for debit card-present transactions and 3 percent for credit card-present transactions, alongside notably higher ceilings of 15 percent for debit and 5 percent for credit in the card-not-present channel. This differentiated treatment of card-present versus card-not-present transactions, and the extension to cross-border card transactions specifically, would bring Serbia's interchange-fee framework into closer structural alignment with the EU's own interchange-fee regulation, consistent with the broader Chapter 9 accession objective underlying the whole legislative package. Taken together, these two draft instruments indicate that Serbia's payments-licensing environment is entering an escalating phase after a period of relative stability, with the National Bank of Serbia using the accession process as the vehicle for simultaneous modernisation across payment-services conduct obligations and card-scheme fee economics. The National Bank of Serbia continues in its standing role as the central bank, primary prudential supervisor and resolution authority for the country's payments and banking sector, and will be the authority administering both instruments once and if they are enacted. #### Outlook No enacted text or confirmed commencement date exists for either draft instrument as at this cycle, and the current evidentiary basis for both rests on a single law-firm tracker rather than primary National Bank of Serbia or Official Gazette text, a sourcing gap that should be closed as the legislative process advances. If the Payment Services Law proceeds broadly as drafted, payment service providers operating in Serbia should expect a nine-month implementation runway from entry into force, meaning advance preparation for fraud-reporting and fund-recovery capability would need to begin well before any formal effective date is reached. The interchange-fee amendments, if adopted with the proposed caps intact, would represent the most significant change to Serbia's card-economics regulation identified to date and merit continued close tracking as the consultation process moves toward a further legislative stage, expected as scheduled into 2027. **5 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Servia's payment-services licensing framework has undergone its most significant harmonisation step in some years, with amendments to the Law on Payment Services applicable from 6 May 2025 bringing the Law into alignment with PSD2. The stated purpose of the harmonisation, per the National Bank of Serbia's own framing, is to enhance market innovation, competition, transparency, and payment-security and user protection. This is a licensing-and-market-access-relevant development because PSD2 alignment typically expands the categories of payment service provider eligible for authorisation and clarifies the conduct standards attached to that authorisation. A further draft amendment package was presented in summer 2026, this time explicitly framed under EU accession Chapter 9. The draft would introduce enhanced fraud-prevention and fund-recovery mechanisms, broaden payment-system access for a wider range of payment service providers, and impose stricter compliance requirements generally, with a nine-month transitional period once the package is adopted. This draft remains at proposal stage and has not been enacted; it should be tracked as a forward pipeline item rather than a current binding requirement. The direction of travel, however, is consistent across both the enacted 2025 amendments and the 2026 draft: progressive alignment of Serbian payment-services law with the EU acquis ahead of full accession, broadening market access for non-bank payment institutions and e-money institutions alongside traditional bank-provided payment services. For market entrants, the practical implication is that authorisation criteria and market-access categories under the Law on Payment Services are in a state of active convergence with PSD2 norms, meaning firms already authorised or seeking authorisation elsewhere in the EU/EEA under PSD2 should find the compliance mapping increasingly straightforward, while the pending 2026 draft package signals further tightening of compliance requirements is likely once EU accession Chapter 9 negotiations progress further. #### Outlook The draft Law on Payment Services amendment package is expected around Q4 2026, per the regulatory horizon estimate, though this remains an uncertainty-banded half-year estimate rather than a firm date. Enactment would trigger a nine-month transitional period for affected payment service providers. Market entrants should monitor both the pace of Chapter 9 accession negotiations generally and the specific progress of this draft package, since the two are explicitly linked in the drafting rationale reported this cycle. Periodic update · new data 2026-09-21 #### Licensing, Authorisation & Market Access The National Bank of Serbia presented an extensive draft legislative package in July 2026, including amendments to the Law on Payment Services, as part of the ongoing EU-accession Negotiation Chapter 9 harmonisation effort. This is a Probable-confidence, Tier-3-sourced finding reflecting a genuine regulatory development, though it is characterised in the underlying reporting as an extensive package rather than a narrowly-scoped payment-services amendment alone, and no confirmed enactment timeline accompanies it. The significance of this development lies less in any immediate change to market-access requirements and more in the direction it signals: Serbia's payment-services regime remains pre-PSD2 today, meaning the country has not yet implemented the EU's passporting and authorisation framework that governs payment institutions and e-money institutions across the European Economic Area, and this draft package is best read as the opening move in a multi-year EU-alignment trajectory rather than an imminent change of law. The practical implication for market participants is that licensing and authorisation for payment services in Serbia continues to run on the existing national framework for the foreseeable future, with the bank-versus-non-bank distinction remaining structurally significant: Serbia's nineteen licensed commercial banks form the backbone of the domestic payments infrastructure, and the current legal architecture does not yet provide the kind of standalone payment-institution or e-money-institution licensing track that PSD2 established in the EU for non-bank payment and e-money firms. Until the draft package, or some successor to it, is enacted, non-bank payment-service providers seeking to operate in Serbia should expect to work within a framework that has not been restructured to accommodate the EU's non-bank licensing categories. #### Outlook The clearest signal of forward movement will be whether the July 2026 draft package advances from consultation into a formal legislative proposal with a defined effective date; the current best estimate places any material impact around 2027, with a full-year uncertainty band reflecting how early-stage this reform track remains. Until enactment, market-access analysis for Serbia should continue to assume the pre-PSD2 status quo. Periodic update · new data 2026-09-14 #### Licensing, Authorisation & Market Access Serbia's payment-services market-access framework has moved this cycle on two fronts. First, the National Bank of Serbia has confirmed that foreign e-money issuers not registered with the NBS are expressly barred from transacting with Serbian residents, and local payment service providers are prohibited from processing transfers to or from any unregistered foreign EMI. This is a mandatory-registration barrier rather than a licensing-exemption regime, and it applies to the non-bank payment-institution and e-money-institution segment specifically, distinct from the bank-PSP channel which operates under separate authorisation. Second, and in parallel, the NBS presented an extensive Chapter 9 Financial Services draft legislative package during summer 2026, covering payment services, interchange fees, banking, insurance and pension funds as part of Serbia's EU accession harmonisation process. This package applies across both the bank-PSP and non-bank PI/EMI segments, and its scope confirms that Serbia's payments-regulatory reform this cycle is being driven by the accession process rather than by a payments-sector-specific policy trigger. The governing statutory baseline remains the Zakon o platnim uslugama, published in the Official Gazette of the Republic of Serbia at numbers 139/2014, 44/2018 and 64/2024, which continues to apply pending adoption of any Chapter 9 amendments. Taken together, this cycle's market-access picture is one of simultaneous tightening at the perimeter, via the foreign-EMI registration barrier, and prospective restructuring at the core, via the Chapter 9 package. #### Outlook The development to watch is the legislative progress of the Chapter 9 package, since its adoption would formalise both the market-access barrier for foreign EMIs and the broader restructuring of licensing categories across the payments, banking and insurance sectors simultaneously. Periodic update · new data 2026-09-08 #### Licensing, Authorisation & Market Access Serbia's Payment Services Law amendments harmonising the domestic regime with PSD2 became applicable on 6 May 2025, a Confirmed, Tier-1-sourced development with high assessed impact for market access. The amendments introduce open banking, establishing the legal basis for third-party access to payment-account data, and are paired with a National Bank of Serbia regulatory sandbox mechanism that grants time-limited exemptions for innovative payment services under NBS-defined conditions, a distinct Confirmed development applicable specifically to non-bank payment and e-money institutions seeking to trial new services ahead of full licensing. Beyond the amendments already in force, a further draft package under Serbia's EU accession process (Chapter 9) proposes a materially more significant liberalisation: removing the existing restriction that bars payment institutions, e-money institutions and postal operators from participating directly in significant payment systems, access today reserved for banks. This is assessed at Probable confidence and remains at draft stage, with content-tier dashboard status reflecting its earlier-stage nature relative to the already-applicable PSD2 amendments. Together, the in-force open-banking and sandbox reforms and the proposed significant-payment-system access liberalisation describe a market-access trajectory that is consistently opening rather than tightening, positioning Serbia's non-bank payment and e-money sector for materially expanded participation over the medium term, contingent on the accession-linked package's progress. The bank-versus-non-bank distinction is explicit across this module: the PSD2 amendments and sandbox apply to both bank and non-bank PSPs already, while the draft significant-payment-system access reform is specifically targeted at closing the participation gap that currently privileges banks over payment institutions, e-money institutions and postal operators. #### Outlook The draft EU-accession payment-systems access package is the single most consequential item to watch in this module: its enactment, expected only generally around Q4 2026 without a firmer date established this cycle, would remove a structural bank/non-bank access asymmetry. Implementation detail under the sandbox mechanism, including the specific conditions the NBS will set for time-limited exemptions, is also worth monitoring as the regime beds in following its May 2025 applicability date. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Serbia's payment-services licensing framework moved onto a new footing in this cycle's evidence base with confirmation that amendments to the Law on Payment Services, harmonising with the EU's PSD2, applied from 6 May 2025 following adoption on 31 July 2024. This is a high-confidence, primary National Bank of Serbia-sourced finding and anchors the remainder of this cycle's W1a developments. Layered on top of that harmonisation, the amended Law now explicitly prohibits local payment service providers from processing transactions with a foreign e-money institution that is not registered with the National Bank of Serbia, converting what had previously been only an NBS supervisory opinion into a binding statutory restriction. Notably, foreign e-money institutions themselves still do not require an NBS licence to conduct cross-border transactions under the exemption regime itself; the new restriction operates on the local PSP side of the relationship. A further authorisation-relevant development this cycle is confirmation that payment initiation service providers must be authorised by the National Bank of Serbia under conditions virtually identical to those applying to payment institutions generally, including a capital requirement of fifty thousand euros in dinar counter-value and enhanced payment-security standards. This places PIS providers on a comparable prudential footing to payment institutions rather than carving out a lighter-touch authorisation track. Both the PSD2-harmonising amendments and the foreign-EMI processing restriction sit within the bank-PSP versus non-bank-PI/EMI distinction that runs through Serbia's payments framework: banks retain more direct system access, while non-bank PIs and EMIs continue to operate within a more tightly bounded authorisation and registration perimeter, notwithstanding the market-access reforms proposed elsewhere in this cycle's evidence. #### Outlook The market-access question for non-bank payment institutions and e-money institutions in Serbia is now substantially a function of the Draft Law amending the Law on Payment Services moving through EU accession Chapter 9, which would extend direct payment-system participation rights beyond the licensing perimeter addressed here. Watch for further NBS guidance on the foreign-EMI registration process now that the restriction on local-PSP processing has moved from supervisory opinion to binding law. **Sources and findings (5)** 1. T1 [https://www.nbs.rs/en/finansijske-institucije/pi-ien/](https://www.nbs.rs/en/finansijske-institucije/pi-ien/) retrieved 2026-07-04 2. T1 [https://www.nbs.rs/export/sites/NBS_site/documents-eng/propisi/zakoni/law_payment_services.pdf](https://www.nbs.rs/export/sites/NBS_site/documents-eng/propisi/zakoni/law_payment_services.pdf) retrieved 2026-07-04 3. T3 [https://bdkadvokati.com/serbia-amends-payment-services-regulations-to-allow-open-banking-services/](https://bdkadvokati.com/serbia-amends-payment-services-regulations-to-allow-open-banking-services/) retrieved 2026-07-04 4. T3 [https://statt.rs/payment-institutions-in-serbia/](https://statt.rs/payment-institutions-in-serbia/) retrieved 2026-07-04 5. T3 [https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia](https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia) retrieved 2026-07-04 ### W1b Conduct, Safeguarding & Promotions Probable confirmed 2026-07-04 Serbia's Law on Interchange Fees and Special Operating Rules for Card-based Payment Transactions is subject to a new NBS-prepared draft amendment (mid-2026) introducing interchange fee caps for domestic and international card transactions, part of the EU-accession Chapter 9 legislative package; card issuers would also be required to maintain proof-of-delivery evidence for cards. Standing sub-brief · as of 4 July 2026 234 words · last cycle 2026-07-04 #### Conduct, Safeguarding & Promotions The NBS Decision on Governance, Internal Controls and Safeguarding mandates safeguarding of payment-service-user and e-money-holder funds by PIs and EMIs, sitting alongside a separate Decision on Capital and Capital Adequacy of PIs/EMIs. This conduct regime for non-bank payment providers is distinct from, but complementary to, the licensing track addressed in Licensing, Authorisation & Market Access. Together these decisions require non-bank providers to segregate customer funds from their own operating capital, addressing the core prudential risk distinct from a bank-PSP's deposit-guarantee-backed balance sheet. On the consumer-conduct side, the unauthorised-payment-transaction liability threshold above which PSPs bear the risk of stolen or abused cards was reduced from RSD 15,000 to RSD 3,000, with the NBS empowered to set an even lower threshold depending on circumstance. This reduction shifts meaningfully more of the loss burden for smaller unauthorised transactions onto PSPs rather than consumers, reinforcing the safeguarding-decision's consumer-protective orientation. No new conduct-rule changes were identified this cycle: the safeguarding, capital-adequacy and liability-threshold framework functions as an established baseline rather than an active area of reform. #### Outlook Absent a new conduct-rule trigger, this module's trajectory is assessed as stable. The principal watch item is how the safeguarding and liability-threshold rules interact with the newly live open-banking regime, given that PISP/AISP providers introduce new categories of third-party access to customer payment accounts without themselves necessarily holding customer funds under the same segregation logic as PI/EMI safeguarding. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://nbs.rs/en/drugi-nivo-navigacije/propisi/propisi-piien](https://nbs.rs/en/drugi-nivo-navigacije/propisi/propisi-piien) retrieved 2026-07-04 2. T1 [https://nbs.rs/en/drugi-nivo-navigacije/propisi/propisi-zk/](https://nbs.rs/en/drugi-nivo-navigacije/propisi/propisi-zk/) retrieved 2026-07-04 3. T3 [https://fic.org.rs/wp-content/uploads/2020/11/18-Consumer-Protection-and-Protection-of-Users-of-Financial-Services.pdf](https://fic.org.rs/wp-content/uploads/2020/11/18-Consumer-Protection-and-Protection-of-Users-of-Financial-Services.pdf) retrieved 2026-07-04 4. T3 [https://www.karanovicpartners.com/news/law-payment-services-serbia/](https://www.karanovicpartners.com/news/law-payment-services-serbia/) retrieved 2026-07-04 5. T3 [https://www.lexology.com/library/detail.aspx?g=e060c275-5dc0-4c51-8d50-4b069cc31712](https://www.lexology.com/library/detail.aspx?g=e060c275-5dc0-4c51-8d50-4b069cc31712) retrieved 2026-07-04 ### W2 Stablecoins & Digital Money Probable confirmed 2026-07-04 Digital assets (virtual currencies and digital tokens) are governed by the Law on Digital Assets (RS Official Gazette 153/2020), in force since 29 June 2021, with dual supervision split between the NBS (virtual currencies) and the Securities Commission (digital tokens/financial-instrument-like assets). NBS-supervised financial institutions are barred from holding, investing in, or providing digital-asset services (with a narrow bank custody-of-cryptographic-keys exception). Serbia has no dedicated stablecoin (as-payment-rail) regime distinct from the general LDA framework. Standing sub-brief · as of 4 July 2026 240 words · last cycle 2026-07-04 #### Stablecoins & Digital Money Serbia's digital-asset regime is governed by the Law on Digital Assets (RS Official Gazette 153/2020), which establishes dual National Bank of Serbia and Securities Commission supervision of virtual currencies and digital tokens and has been in force since 29 June 2021. There is no dedicated stablecoin, as-payment-rail regime distinct from this general Law on Digital Assets framework; any stablecoin activity in Serbia is regulated, to the extent it is regulated at all, under the same dual-regulator digital-asset structure applied to virtual currencies and tokens generally. NBS-supervised financial institutions are separately barred from holding, investing in, or providing digital-asset services, subject only to a narrow exception permitting banks to provide custody of cryptographic keys; unauthorised virtual-currency service provision is a criminal offence under the Criminal Code. This structure keeps regulated banks and non-bank PSPs at arm's length from direct digital-asset exposure while channelling licensed activity through the separate Law on Digital Assets authorisation track rather than through payment-services licensing. #### Outlook The trajectory here is stable: the dual-regulator Law on Digital Assets framework remains the sole regime, and the market is gradually maturing around it. The principal gap, noted in the underlying research, is the absence of any dedicated stablecoin-as-payment-rail framework comparable to emerging EU or UK stablecoin regimes, meaning any future stablecoin-specific payments use case in Serbia would likely require new primary or secondary legislation rather than fitting cleanly within the existing Law on Digital Assets categories. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://www.nbs.rs/export/sites/NBS_site/documents-eng/propisi/zakoni/digitalna_imovina_e.pdf](https://www.nbs.rs/export/sites/NBS_site/documents-eng/propisi/zakoni/digitalna_imovina_e.pdf) retrieved 2026-07-04 2. T1 [https://www.nbs.rs/en/scripts/showcontent/index.html?id=20378&konverzija=no](https://www.nbs.rs/en/scripts/showcontent/index.html?id=20378&konverzija=no) retrieved 2026-07-04 3. T3 [https://www.schoenherr.eu/content/the-digital-assets-act-new-tech-regulation-in-serbia/](https://www.schoenherr.eu/content/the-digital-assets-act-new-tech-regulation-in-serbia/) retrieved 2026-07-04 4. T3 [https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and-regulations/serbia/](https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and-regulations/serbia/) retrieved 2026-07-04 5. T3 [https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia](https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia) retrieved 2026-07-04 ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-04 Operational and ICT resilience for Serbian payment service providers rests on two tracks: sector-specific NBS rules under the Law on Payment Services (operational/security risk management, incident notification to the NBS) and the horizontal Law on Information Security, which entered into force 31 October 2025 and aligns Serbia's critical-infrastructure cyber regime (including financial institutions) with the EU's NIS2 Directive, introducing 'priority' vs 'important' ICT operator categories. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/serbia/) Standing sub-brief · as of 4 July 2026 205 words · last cycle 2026-08-05 #### Operational Resilience & Critical Infrastructure A new Law on Information Security entered into force on 31 October 2025, aligning Serbia's cyber-resilience regime with the EU's NIS2 Directive and introducing "priority" versus "important" ICT operator categories that cover financial institutions. Priority entities face fines of up to approximately EUR 17,000, double the maximum penalty applicable to important entities, though certain provisions of the law remain postponed pending implementing bylaws. This horizontal cyber-resilience statute sits alongside sector-specific obligations under the Payment Services Act: Serbian payment service providers must separately implement operational and security risk-management frameworks and notify the NBS of significant incidents, and must notify the NBS in advance of any intended ICT-outsourcing arrangement. The combination gives Serbia a two-layer resilience architecture, a horizontal, NIS2-modelled information-security law applicable across designated priority and important entities, and a payments-specific incident-notification and outsourcing-approval regime running through the NBS. #### Outlook This module's trajectory is escalating, reflecting the law's recent entry into force and the fact that some implementing provisions remain postponed. The near-term watch item is the finalisation of those implementing bylaws and how NBS-regulated payment institutions are classified between the priority and important tiers, which will determine the practical compliance burden and penalty exposure they face under the new regime. Periodic update · new data 2026-08-11 #### Operational Resilience & Critical Infrastructure The National Bank of Serbia published a consolidated version of the Law on the National Bank of Serbia on 20 April 2026, compiling the original 2003 statute together with all amendments through Official Gazette No. 19/2025. This is an assessed-confidence, secondary-sourced finding that functions as legislative housekeeping rather than a new operational-resilience obligation, but it carries structural significance for this domain because it confirms, in a single consolidated text, the National Bank of Serbia's supervisory perimeter over payment institutions, e-money institutions, virtual-currency service providers, and financial-leasing entities. For operators and counterparties seeking a definitive statement of which entity types fall within NBS's operational-resilience and critical-infrastructure supervisory scope, the consolidated law is now the reference point. No new resilience-specific technical standard, incident-reporting obligation, or critical-infrastructure designation was evidenced for Serbia this cycle beyond this consolidation. The development should therefore be read as a clarification of an existing supervisory perimeter rather than an expansion or tightening of operational-resilience requirements themselves. #### Outlook Because the consolidated law is a compilation rather than a new instrument, the more consequential operational-resilience question going forward is whether the National Bank of Serbia issues implementing regulation specific to virtual-currency service providers, now confirmed as falling within its supervisory perimeter. Watch for any NBS resilience-specific circular addressing this category directly. **Sources and findings (5)** 1. T3 [https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia](https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia) retrieved 2026-07-04 2. T1 [https://nbs.rs/en/drugi-nivo-navigacije/propisi/propisi-ps/](https://nbs.rs/en/drugi-nivo-navigacije/propisi/propisi-ps/) retrieved 2026-07-04 3. T3 [https://www.karanovicpartners.com/news/from-nis2-to-serbia-how-the-new-information-security-law-impacts-your-business/](https://www.karanovicpartners.com/news/from-nis2-to-serbia-how-the-new-information-security-law-impacts-your-business/) retrieved 2026-07-04 4. T3 [https://ceelegalmatters.com/briefings/27984-new-legal-framework-on-the-horizon-for-cybersecurity-in-serbia](https://ceelegalmatters.com/briefings/27984-new-legal-framework-on-the-horizon-for-cybersecurity-in-serbia) retrieved 2026-07-04 5. T3 [https://www.karanovicpartners.com/news/from-nis2-to-serbia-how-the-new-information-security-law-impacts-your-business/](https://www.karanovicpartners.com/news/from-nis2-to-serbia-how-the-new-information-security-law-impacts-your-business/) retrieved 2026-07-04 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-04 Card-scheme and network compliance in Serbia is anchored by the Law on Interchange Fees and Special Operating Rules for Card-Based Payment Transactions (in force 17 December 2018), modelled on EU Regulation 2015/751, which caps interchange fees and mandates co-badging, unblending and honour-all-cards principles, with NBS supervision extending to card schemes (Visa, Mastercard) and processors. A landmark 2018 antitrust case saw Serbia's Competition Commission investigate Mastercard over allegedly excessive fallback interchange fees. Standing sub-brief · as of 4 July 2026 219 words · last cycle 2026-08-05 #### Scheme & Network Compliance Card-scheme compliance in Serbia is anchored by the Law on Interchange Fees and Special Operating Rules for Card-Based Payment Transactions, in force since 17 December 2018, which caps interchange fees at 0.2% for debit and 0.3% for credit transactions and mandates co-badging and unblending, modelled closely on EU Regulation 2015/751. The National Bank of Serbia supervises card issuers, acquirers, schemes and processors under this law, giving it direct oversight of Visa, Mastercard and other scheme participants operating in the market. The landmark conduct matter under this framework is a Serbian Competition Commission antitrust investigation into Mastercard over allegedly excessive fallback interchange fees, initiated in 2018 and still the reference case for card-scheme conduct enforcement in Serbia; the proceeding was only the second instance of the Commission taking action against a foreign legal entity for a restrictive agreement. No new scheme-compliance developments were identified this cycle, and the interchange-fee-cap and co-badging regime continues to function as settled law rather than an active reform area. #### Outlook The trajectory here is stable. The Mastercard antitrust matter remains the key item to track for scheme-conduct enforcement direction, given its continuing status as the Commission's primary precedent in this space; any resolution or escalation of that case would be the clearest signal of a shift in Serbia's card-scheme compliance posture. Periodic update · new data 2026-08-11 #### Scheme & Network Compliance A Draft Law amending the Law on Interchange Fees and Special Operating Rules for Card-based Payment Transactions would introduce caps on interchange fees for both domestic and international card transactions. This is a high-confidence, secondary-sourced finding, part of the same EU-accession Negotiation Chapter 9 legislative package that includes the Draft Law amending the Law on Payment Services, and it is expected to progress in a summer 2026 reform phase with an estimated third-quarter 2026 impact date carrying a quarter-level uncertainty band. The proposed cap applies across both the domestic card-transaction segment and the international segment, meaning both bank-issued and non-bank-issued card products would be affected without differentiation on that basis, distinguishing this reform from the bank-versus-non-bank access questions that characterise Serbia's W1a and W12 developments this cycle. #### Outlook Firms with card-issuing or card-acquiring exposure in Serbia should treat the third-quarter 2026 estimated impact date as an active monitoring point. Because this reform and the Draft Payment Services Law originate from the same EU-accession Chapter 9 package, their legislative timelines are likely correlated, and confirmation of progress on one is a reasonable leading indicator for the other. **Sources and findings (5)** 1. T1 [https://nbs.rs/en/scripts/showcontent/index.html?id=11464&konverzija=no](https://nbs.rs/en/scripts/showcontent/index.html?id=11464&konverzija=no) retrieved 2026-07-04 2. T3 [http://www.jpm.law/new-regulations-on-interchange-fees-to-enter-into-force/](http://www.jpm.law/new-regulations-on-interchange-fees-to-enter-into-force/) retrieved 2026-07-04 3. T3 [https://www.lexology.com/library/detail.aspx?g=f53c51c4-7f91-48a6-83a4-9cef864f1293](https://www.lexology.com/library/detail.aspx?g=f53c51c4-7f91-48a6-83a4-9cef864f1293) retrieved 2026-07-04 4. T4 [https://www.researchgate.net/publication/330105954_Multilateral_Interchange_Fees_in_Serbia_and_their_impact_on_card_payment_systems_development](https://www.researchgate.net/publication/330105954_Multilateral_Interchange_Fees_in_Serbia_and_their_impact_on_card_payment_systems_development) retrieved 2026-07-04 5. T1 [https://www.nbs.rs/en/ciljevi-i-funkcije/platni-sistem/nbs-operator/](https://www.nbs.rs/en/ciljevi-i-funkcije/platni-sistem/nbs-operator/) retrieved 2026-07-04 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-04 Serbia's banking sector began operational implementation of SEPA credit-transfer inflows/outflows in EUR from 5 May 2026, following Serbia's accession to the SEPA payment area, alongside continued growth of the domestic NBS instant-payments (IPS) rail. Horizon · 2026-05 (±quarter) Serbian PSPs achieve full SEPA operational readiness_in_force · TT1_ Standing sub-brief · as of 4 July 2026 210 words · last cycle 2026-09-28 #### Payment Corridor Dynamics The NBS IPS instant payment system launched 22 October 2018 as the first instant payment system in the Balkan region, predating the ECB's TIPS system, with individual transfers capped at RSD 300,000. Banks, the NBS and the Treasury are direct participants in this rail, while PIs, EMIs and the public postal operator are only indirect participants. Building on that domestic rail, Serbia acceded to SEPA in 2025 and became operationally live for SEPA Credit Transfer schemes as of May 2026, with 18 banks currently participating; the European Payments Council set the earliest operational readiness date for May 2026, following a May 2025 decision to include Serbia within SEPA's geographical scope. The SEPA milestone materially upgrades cross-border corridor access: it opens equal-terms euro cross-border payment processing for Serbian PSPs regardless of whether their parent bank is domiciled in the EU, a meaningful change from a pre-accession position in which corridor access depended on correspondent or parent-bank arrangements. #### Outlook This module's trajectory is escalating. The principal near-term item is the pace at which additional Serbian banks beyond the initial 18 achieve SEPA operational readiness, and whether SEPA Instant Credit Transfer participation follows the initial Credit Transfer go-live, which would further integrate the domestic IPS rail with euro-area instant-payment infrastructure. Periodic update · new data 2026-09-28 #### Payment Corridor Dynamics Servia's cross-border payment corridor dynamics are being reshaped on two fronts this cycle. First, Serbia's accession to SEPA in 2025 is extending euro-denominated cross-border payment connectivity, with payment service providers in Serbia anticipated to become fully SEPA-operational by mid-2026. Full SEPA operability would allow Serbian payment service providers to process euro credit transfers and direct debits under the same technical and legal framework used across the SEPA area, materially reducing the cost and complexity of euro-corridor transactions for Serbian businesses and consumers relative to the current correspondent-banking-dependent alternative. Second, on the domestic-corridor side, Serbia's National Bank of Serbia-operated Instant Payment System continues to provide 24/7/365 credit transfers settling within seconds, supporting QR-code, person-to-person, and merchant transaction use cases, with a per-transaction limit of RSD 300,000. The system is operated centrally and solely by the National Bank of Serbia, a structural feature that distinguishes Serbia's instant-payments corridor from jurisdictions where instant-payment rails are operated by a consortium of participant banks or a separate scheme company. This centralised operating model concentrates both the operational-resilience burden and the rail-governance function within the central bank itself. The combination of expanding SEPA cross-border connectivity and a maturing domestic instant-payments rail points toward a broader liberalisation of Serbia's payment-corridor landscape, though the SEPA milestone in particular should be read as anticipated rather than confirmed, since full PSP operational rollout was not yet complete as of this cycle's research. #### Outlook Full SEPA-operational status for Serbian payment service providers is anticipated by mid-2026 (Q2 2026, per the regulatory horizon estimate), a quarter-banded uncertainty estimate. Confirmation of that milestone, once it occurs, would represent the clearest evidence yet of Serbia's cross-border payments integration with the EU ahead of full accession. The domestic Instant Payment System's RSD 300,000 transaction limit is a structural feature to monitor for any future adjustment as transaction volumes and typical payment sizes evolve. **3 earlier distinct update(s)** Periodic update · new data 2026-09-21 #### Payment Corridor Dynamics Serbia's accession to the Single Euro Payments Area is the standout corridor-level development this cycle. Reporting indicates eighteen Serbian banks went live on SEPA around 5 May 2026, converting what had previously been SWIFT-wire-based euro payments into next-day settlement under the SEPA scheme's standardised rulebook. A separate source describes official SEPA inclusion as having occurred as of May 2025, a full year earlier than the bank-level go-live date reported elsewhere; this discrepancy was not resolved by any Tier-1 EPC or SEPA scheme confirmation retrieved this cycle, and is logged as an open sourcing gap rather than adjudicated in either direction. Notwithstanding the date discrepancy, the substantive finding — that Serbian banks now operate within the SEPA framework for euro-denominated transfers — carries Probable confidence and represents a material lowering of cost and settlement-time friction for cross-border euro payment corridors touching Serbia. Running in parallel with SEPA accession, the National Bank of Serbia's domestic instant-payment system, IPS, continues to scale as a Confirmed-confidence, Tier-1-sourced feature of the corridor landscape. The IPS system carries a per-transaction limit of RSD 300,000, and all licensed banks are required to offer the service on a 24/7/365 basis, meaning instant domestic credit transfers are now a standing feature of the Serbian retail-payments landscape independent of the SEPA development. Together, SEPA accession for cross-border euro corridors and IPS scaling for domestic instant transfers describe a payments infrastructure in Serbia that is becoming measurably faster and more interoperable on two separate fronts simultaneously. #### Outlook Resolving the SEPA go-live date discrepancy through a primary EPC or NBS source would meaningfully sharpen the corridor-dynamics picture for Serbia. Beyond that, continued monitoring of IPS transaction-limit changes and any expansion of SEPA-linked services to additional Serbian financial institutions are the clearest indicators of further corridor development in coming cycles. Periodic update · new data 2026-09-14 #### Payment Corridor Dynamics The domestic DinaCard payment scheme is subject to a proposed tightening of issuer obligations this cycle. Proposed amendments to Serbia's Law on Interchange Fees would require card issuers to establish efficient delivery procedures and retain evidence that a payment card was actually delivered to the cardholder, specifically for cards processed through the domestic DinaCard system. This is a card-delivery-evidencing requirement rather than a change to interchange-fee pricing levels themselves, and it falls on the bank-PSP side of the market given DinaCard's issuer base. This development should be read as a discrete tightening of accountability within the domestic card corridor rather than as part of the broader Chapter 9 restructuring, though it originates from the same overall legislative reform cycle. The requirement to retain delivery evidence adds an operational compliance step for DinaCard issuers that did not previously exist in this form. #### Outlook The item to watch is whether the Law on Interchange Fees amendment is adopted in its current proposed form, and whether the delivery-evidencing requirement is extended to other card schemes operating in Serbia beyond DinaCard. Periodic update · new data 2026-08-25 #### Payment Corridor Dynamics Serbia's banking sector began operational implementation of SEPA credit transfers from 5 May 2026, following Serbia's accession to the SEPA payment area; Banca Intesa Beograd's customer communication describes the new rail as cheaper for euro cross-border payments than classic SWIFT transfers. This is a probable-confidence, single-source (tier-two, bank-level) finding this cycle rather than a market-wide confirmed rollout. Separately, the National Bank of Serbia's IPS domestic instant-payments rail recorded 31 percent year-on-year transaction growth in the first quarter of 2026, reaching 31.9 million transactions, continuing its established growth trajectory. #### Outlook Both corridors are on an established trajectory rather than newly emergent this cycle. The near-term item to watch is corridor uptake and confirmation of SEPA implementation across additional Serbian banks beyond Banca Intesa Beograd, since the current evidence covers a single bank's customer communication rather than sector-wide confirmation. **Sources and findings (5)** 1. T1 [https://www.nbs.rs/en/novac-i-placanja/htmlredirect-03](https://www.nbs.rs/en/novac-i-placanja/htmlredirect-03) retrieved 2026-07-04 2. T2 [https://www.europeanpaymentscouncil.eu/news-insights/insight/serbias-sepa-journey-advancing-digital-transformation-and-financial](https://www.europeanpaymentscouncil.eu/news-insights/insight/serbias-sepa-journey-advancing-digital-transformation-and-financial) retrieved 2026-07-04 3. T3 [https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia](https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia) retrieved 2026-07-04 4. T1 [https://www.nbs.rs/en/ciljevi-i-funkcije/platni-sistem/nbs-operator/](https://www.nbs.rs/en/ciljevi-i-funkcije/platni-sistem/nbs-operator/) retrieved 2026-07-04 5. T3 [https://www.trade.gov/country-commercial-guides/serbia-trade-financing](https://www.trade.gov/country-commercial-guides/serbia-trade-financing) retrieved 2026-07-04 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-04 Serbia's payments-adjacent financial sector comprises roughly 20 commercial banks (majority foreign-owned), a modest but growing fintech population (70-110+ active firms depending on classification), and a private-PSP/fintech layer increasingly engaging with the NBS regulatory sandbox and open-banking build-out. Bank-fintech competitive dynamics are expected to intensify as open banking rolls out through 2026. Standing sub-brief · as of 4 July 2026 192 words · last cycle 2026-09-28 #### Industry Structure & Commercial Dynamics Serbia's banking sector comprises approximately 20 commercial banks, the majority foreign-owned, against a stable financial-stability backdrop reflected in a non-performing-loan ratio of 2.09% as of March 2026 and an NBS reference rate of 5.75% as of May 2026. This stable banking core coexists with a considerably younger fintech population: Serbia's fintech sector comprised 74 to 110-plus active firms as of January 2026, of which only 11 had received any funding at all, with cumulative fintech-sector funding of approximately USD 5.6 million over ten years. That investment base remains in an early formation stage relative to Western Europe, indicating that most of the commercial dynamism in Serbian payments continues to run through bank-led infrastructure, the IPS rail, SEPA accession, and bank-provided card acquiring, rather than through independently capitalised non-bank challengers. #### Outlook The trajectory is stable on both the banking and fintech sides: no material change in bank count, ownership structure, or aggregate fintech funding was identified this cycle. The item to watch is whether the newly operational open-banking and sandbox provisions, and continued SEPA integration, begin to attract more third-party-provider investment activity into the still-thin non-bank funding base. Periodic update · new data 2026-09-28 #### Industry Structure & Commercial Dynamics Servia's payments industry structure is showing early signs of technological diversification, though both major threads remain at an exploratory stage rather than a committed implementation. Open banking has not been implemented via a direct transposition of PSD2's open-banking access regime, but the National Bank of Serbia has signalled plans for an open-banking API framework, without a stated implementation timeline. This places Serbia behind full PSD2-equivalent open-banking access relative to EU/EEA member states, notwithstanding the broader PSD2-harmonisation trend visible in the Law on Payment Services amendments. Separately, the National Bank of Serbia is exploring a central bank digital currency, again with no issuance timeline announced. Both the open-banking API framework and the CBDC exploration are best characterised as watch items: real enough to note as directional signals about where Serbia's payments-market structure may be heading, but not yet commitments with dates attached, and therefore not yet material changes to the commercial landscape facing payment service providers or fintech entrants today. On product innovation more specifically, Serbia has no dedicated Buy-Now-Pay-Later regulatory framework; bank-offered BNPL products currently fall within the existing consumer-credit regime and the National Bank of Serbia's responsible-lending rules rather than under any BNPL-specific regulatory structure. This is a structural, negative finding worth noting for any fintech assessing BNPL market entry into Serbia: the absence of a dedicated regime means BNPL products are regulated as consumer credit, with the compliance obligations that entails, rather than under a lighter-touch or purpose-built BNPL framework. #### Outlook Neither the open-banking API framework nor the CBDC exploration carries an announced timeline, so both should be tracked as longer-horizon structural developments rather than near-term commercial catalysts. The absence of a dedicated BNPL framework is a stable structural feature rather than an anticipated near-term change; any future shift toward a dedicated BNPL regime would represent a meaningful departure from the current consumer-credit-based treatment and should be watched for signs of regulatory appetite as European peers move on BNPL-specific rules. **1 earlier distinct update(s)** Periodic update · new data 2026-09-08 #### Industry Structure & Commercial Dynamics The National Bank of Serbia published a consolidated text of the Law on the National Bank of Serbia in April 2026, incorporating all amendments made between 2003 and 2025. This is a Confirmed, Tier-1-sourced development, though its content_tier is dashboard-level: it is an administrative consolidation exercise rather than a substantive change to the NBS's mandate, and it carries a MONITORED rather than elevated impact rating. Its significance for industry structure lies in reaffirming, in a single consolidated text, the NBS's payment-systems oversight and banking-supervision mandate, the legal foundation underpinning the PSD2-harmonisation and sandbox reforms tracked elsewhere this cycle. The consolidation applies equally to bank and non-bank participants insofar as it restates the NBS's supervisory scope generally rather than altering the bank-versus-non-bank treatment specifically. No other industry-structure development, such as a merger, market-concentration shift, or new entrant announcement, was confirmed for Serbia this cycle. #### Outlook The consolidated NBS law text itself is not expected to generate further near-term developments; it is a housekeeping artefact rather than the leading edge of change. Industry-structure attention should instead track how the PSD2-harmonisation and EU-accession-linked market-access reforms, addressed in the licensing and market-access module, reshape the competitive field between bank and non-bank payment providers over the coming cycles. **Sources and findings (5)** 1. T3 [https://www.trade.gov/country-commercial-guides/serbia-trade-financing](https://www.trade.gov/country-commercial-guides/serbia-trade-financing) retrieved 2026-07-04 2. T1 [https://www.nbs.rs/export/sites/NBS_site/documents-eng/finansijska-stabilnost/presentation_invest.pdf](https://www.nbs.rs/export/sites/NBS_site/documents-eng/finansijska-stabilnost/presentation_invest.pdf) retrieved 2026-07-04 3. T4 [https://tracxn.com/d/explore/fintech-startups-in-serbia/LuI-7EGZUl99pcA3eQLIj7SyffU4dBafCkLdm-w8FpI](https://tracxn.com/d/explore/fintech-startups-in-serbia/LuI-7EGZUl99pcA3eQLIj7SyffU4dBafCkLdm-w8FpI) retrieved 2026-07-04 4. T3 [https://qwist.com/en/resources/blog/open-banking/serbias-financial-market-in-transition/](https://qwist.com/en/resources/blog/open-banking/serbias-financial-market-in-transition/) retrieved 2026-07-04 5. T4 [https://globalfintechseries.com/fintech/paysend-invests-in-serbia-with-new-european-tech-center/](https://globalfintechseries.com/fintech/paysend-invests-in-serbia-with-new-european-tech-center/) retrieved 2026-07-04 ### W7 Legal & Litigation Probable confirmed 2026-07-04 The most significant payments-sector litigation/enforcement history in Serbia is the Competition Commission's antitrust action against Mastercard over interchange fees (initiated 2018), alongside the NBS's broad but non-transparent administrative enforcement powers (licence withdrawal, fines, account-access prohibition) and a 2025 overhaul of FX/exchange-operations enforcement mechanics. Standing sub-brief · as of 4 July 2026 212 words · last cycle 2026-07-04 #### Legal & Litigation National Bank of Serbia enforcement powers include licence withdrawal and administrative penalties, but Serbian legislation has no equivalent provision for public statements or publication of penalties, unlike the EU framework, according to an EBA equivalence assessment of the Serbian regime. This non-transparency in enforcement disclosure is a structural feature of the jurisdiction's supervisory posture rather than a recent change. Separately, 2025 amendments to the foreign-exchange and exchange-operations enforcement regime introduce administrative fines of up to 10% of prior-year revenue and establish a non-public NBS register of measures and fines under Article 46đ of the Foreign Exchange Law, expanding NBS, police and Business Register cooperation during inspections; a resulting fine decision is treated as an enforceable document. The most significant standing litigation matter remains the Competition Commission's 2018 antitrust action against Mastercard over fallback interchange fees, discussed in the Scheme & Network Compliance module, which continues as the landmark payments-sector case in the jurisdiction with no new litigation surfacing this cycle. #### Outlook The trajectory is stable, anchored by the continuing Mastercard case and the still-recent 2025 FX-enforcement amendments. The watch item is how actively the NBS uses its expanded fine and inspection-cooperation powers under the 2025 amendments, given the register of measures remains non-public and therefore difficult to monitor externally. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://www.lexology.com/library/detail.aspx?g=f53c51c4-7f91-48a6-83a4-9cef864f1293](https://www.lexology.com/library/detail.aspx?g=f53c51c4-7f91-48a6-83a4-9cef864f1293) retrieved 2026-07-04 2. T3 [https://www.mlex.com/mlex/articles/1946863/mastercard-faces-antitrust-probe-in-serbia-over-interchange-fees](https://www.mlex.com/mlex/articles/1946863/mastercard-faces-antitrust-probe-in-serbia-over-interchange-fees) retrieved 2026-07-04 3. T1 [https://eba.europa.eu/sites/default/files/document_library/News%20and%20Press/Press%20Room/Press%20Releases/2020/EBA%20acknowledges%20Commission%E2%80%99s%20decision%20on%20equivalence%20for%20Serbia%20and%20South%20Korea/Annex%20Serbia.pdf](https://eba.europa.eu/sites/default/files/document_library/News%20and%20Press/Press%20Room/Press%20Releases/2020/EBA%20acknowledges%20Commission%E2%80%99s%20decision%20on%20equivalence%20for%20Serbia%20and%20South%20Korea/Annex%20Serbia.pdf) retrieved 2026-07-04 4. T3 [https://statt.rs/foreign-exchange-operations-in-serbia-2025-new-measures-penalties-and-enhanced-nbs-oversight/](https://statt.rs/foreign-exchange-operations-in-serbia-2025-new-measures-penalties-and-enhanced-nbs-oversight/) retrieved 2026-07-04 5. T3 [https://statt.rs/foreign-exchange-operations-in-serbia-2025-new-measures-penalties-and-enhanced-nbs-oversight/](https://statt.rs/foreign-exchange-operations-in-serbia-2025-new-measures-penalties-and-enhanced-nbs-oversight/) retrieved 2026-07-04 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-04 Serbian merchant acquiring operates through bank-acquirers under the card-scheme rules constrained by the Law on Interchange Fees (unblending/transparency obligations toward merchants) and increasingly through the lower-cost NBS IPS QR-code rail as an alternative to card acquiring. Dedicated high-risk-MCC or specialised merchant-onboarding-risk rules beyond general PSA/AML requirements were not identified in the sources searched. Standing sub-brief · as of 4 July 2026 172 words · last cycle 2026-07-04 #### Merchant Acquiring & Risk Merchant acquiring in Serbia operates through bank-acquirers under transparency obligations set by the Law on Interchange Fees, which requires acquiring banks to disclose per-transaction merchant and interchange-fee information to merchants and bans a uniform merchant-fee calculation rule that ignores card type. This unblending and transparency obligation strengthens merchant negotiating power relative to acquirers. Alongside card acquiring, the NBS IPS QR-code merchant-acceptance rail offers materially lower merchant fees than card acquiring, with growing major-retailer acceptance as of 2026, giving merchants a lower-cost instant-payment alternative to traditional card rails. No dedicated high-risk-merchant-category-code or specialised merchant-onboarding-risk instrument was identified for Serbia beyond general Payment Services Act and AML requirements, which the underlying research flags as an unresolved gap rather than a confirmed absence of risk controls. #### Outlook The trajectory is stable. The principal development to track is the continued growth of IPS QR-code merchant acceptance relative to card acquiring, which, if it continues, would gradually shift merchant cost structures away from interchange-capped but still card-scheme-dependent acquiring toward the NBS-operated instant-payment rail. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://nbs.rs/en/scripts/showcontent/index.html?id=11464&konverzija=no](https://nbs.rs/en/scripts/showcontent/index.html?id=11464&konverzija=no) retrieved 2026-07-04 2. T3 [https://www.karanovicpartners.com/news/law-payment-services-serbia/](https://www.karanovicpartners.com/news/law-payment-services-serbia/) retrieved 2026-07-04 3. T1 [https://ips.nbs.rs/en/vesti/povoljnije-placanje-uz-ips-nbs-sistem-instant-placanja](https://ips.nbs.rs/en/vesti/povoljnije-placanje-uz-ips-nbs-sistem-instant-placanja) retrieved 2026-07-04 4. T4 [https://www.researchgate.net/publication/330105954_Multilateral_Interchange_Fees_in_Serbia_and_their_impact_on_card_payment_systems_development](https://www.researchgate.net/publication/330105954_Multilateral_Interchange_Fees_in_Serbia_and_their_impact_on_card_payment_systems_development) retrieved 2026-07-04 ### W9 Product Innovation & Market Development limited signal Probable confirmed 2026-07-04 NBS continues to operate and grow the IPS instant-payments rail as the country's primary payments-innovation vehicle; secondary reporting also describes an NBS pilot-phase blockchain-based digital-currency initiative not yet public-facing. Horizon · 2026-01-01 (±quarter) Open-banking transitional bylaw-adjustment period ends for existing PSPs_in_force · TT3_ Horizon · 2026-01-01 (±quarter) Open-banking transitional bylaw-adjustment period ends for existing PSPs_in_force · TT3_ Standing sub-brief · as of 4 July 2026 210 words · last cycle 2026-09-21 #### Product Innovation & Market Development Open banking (PISP/AISP) became effective in Serbia on 6 May 2025, with a transitional period running until 1 January 2026 for existing PSPs to complete compliance; payment initiation and account information services may be provided by banks, EMIs, PIs and the public postal operator, with flexible entrepreneur eligibility rules for AIS-only providers. This go-live opens bank payment-account access to third-party providers and is expected to intensify bank-fintech competitive dynamics through 2026. A payment regulatory sandbox, introduced by the 2024 Payment Services Act amendments, allows firms to test innovative payment services with a reduced compliance burden and is intended to benefit fintech startups and new market entrants; it has already been adopted by entrants such as Paysend. No NBS retail or wholesale central bank digital currency pilot was identified in the sources reviewed, which the underlying research treats as an unresolved gap rather than a confirmed absence of CBDC exploration. #### Outlook The trajectory is escalating. The transitional period's close on 1 January 2026 is the key near-term milestone, after which all existing PSPs must operate under the full open-banking regime; the extent to which sandbox participation converts into commercial product launches, and whether any CBDC pilot activity surfaces, are the module's principal watch items going forward. Periodic update · new data 2026-09-21 #### Product Innovation & Market Development The National Bank of Serbia has signalled plans for a future open-banking API framework, though this remains in early development with no confirmed implementation timeline, per Tier-3 reporting carrying Uncertain confidence. This sits alongside Serbia's continued pre-PSD2 regulatory status: without a PSD2-equivalent legal basis, an open-banking framework in Serbia would need to be built on a bespoke national legal foundation rather than transposing an existing EU directive, which likely explains both the early-stage nature of the initiative and the absence of a confirmed timeline. Separately, the National Bank of Serbia is reported to be exploring central-bank digital-currency issuance, again with no announced timeline and again resting on Tier-3, Uncertain-confidence market commentary rather than a confirmed NBS policy statement or consultation document. Both threads — open banking and CBDC exploration — represent genuine but early-stage product-innovation signals rather than active regulatory developments with near-term market impact. Serbia also has no dedicated Buy-Now-Pay-Later regulatory framework; BNPL activity in the jurisdiction currently sits within the general consumer-credit regime rather than under a bespoke payments-innovation rulebook, which means BNPL providers operating in Serbia face the same consumer-credit compliance obligations as traditional lenders rather than a payments-specific overlay. #### Outlook Any NBS consultation paper or draft framework specifically addressing open banking or CBDC would represent the clearest signal that either initiative is moving from exploratory to active status. Given the current evidentiary base, neither should be expected to produce a near-term operational change for market participants; both remain firmly in the watch category for coming cycles. **3 earlier distinct update(s)** Periodic update · new data 2026-09-14 #### Product Innovation & Market Development The draft Payment Services Law amendments under Serbia's Chapter 9 package introduce a regulatory sandbox mechanism that would allow the National Bank of Serbia to exempt innovative payment services from specific regulatory requirements for a defined testing period. This is a liberalising signal that sits alongside the broader Chapter 9 package's tightening elements, such as the foreign-EMI registration barrier, indicating that Serbia's payments reform is not uniformly restrictive but instead combines tightened market-access controls with a deliberate space for controlled fintech experimentation. The sandbox proposal applies primarily to the non-bank payment-institution and e-money-institution segment, where innovative product development is most likely to originate, and its introduction under the EU-accession-driven Chapter 9 package suggests it is modelled on comparable EU-member-state sandbox regimes rather than being a purely domestic policy innovation. #### Outlook The item to watch is whether the sandbox mechanism survives the legislative process in its currently proposed form, and, if adopted, what the NBS's initial criteria for admission to the sandbox will require of applicant firms. Periodic update · new data 2026-08-25 #### Product Innovation & Market Development The National Bank of Serbia's IPS instant-payments system remains Serbia's primary payments-innovation vehicle. The scheme operates around the clock, caps individual transactions at RSD 300,000, requires all licensed banks to connect, and offers a Central Addressing Scheme that lets payers direct funds to a registered alias rather than a full account number. NBS functions as both the lead payments regulator and the sole operator of the IPS system, with no subsidiary clearing houses; direct participants are Serbian banks, the NBS itself, and the Treasury Administration. This is a high-confidence, primary-source finding and represents the standing-brief-tier core of Serbia's product-innovation landscape. Separate from the IPS system, secondary reporting describes a blockchain-based digital-currency pilot under development at the National Bank of Serbia, with a pilot phase reported across 2023-2025 and a regulatory framework said to be under finalisation. Public launch has not been confirmed. This item rests on a single tier-four secondary source with low confidence and has not been independently corroborated this cycle; it is carried here as a dashboard-level watch item rather than a confirmed product launch. #### Outlook The IPS system's mandatory bank connectivity and alias-based addressing scheme are settled, standing-brief features of Serbia's payments infrastructure and are not expected to change materially in the near term. The unconfirmed digital-currency pilot is the item most likely to generate a material update: a primary NBS statement or public launch announcement would be the trigger to upgrade this from a dashboard entry to a full standing-brief narrative. Periodic update · new data 2026-08-11 #### Product Innovation & Market Development The National Bank of Serbia has established a regulatory sandbox for payment services, allowing companies to test new or improved payment services without an immediate obligation to meet all regulatory requirements or bear the full associated compliance costs. This is an assessed-confidence, secondary-sourced finding, and the sandbox operates under NBS-defined exemption conditions designed, per this cycle's evidence, to foster non-discriminatory bank access for payment institutions and e-money institutions specifically. This is a content-tier dashboard item this cycle rather than a full standing-brief development: the sandbox's existence and its exemption-conditions rationale are confirmed, but no detail on specific cohorts, applicant numbers, or products tested under the sandbox was located in this cycle's research sweep. #### Outlook Watch for the first cohort of sandbox participants or products to be publicly identified, which would allow this dashboard-tier item to be upgraded to a full standing-brief development. The sandbox's stated non-discriminatory-access rationale is also worth tracking against the Draft Payment Services Law's own non-bank market-access provisions, since both instruments address the same underlying bank-versus-non-bank asymmetry from different angles. **Sources and findings (5)** 1. T3 [https://www.karanovicpartners.com/news/harmonisation-of-serbian-law-on-payment-services-with-psd2/](https://www.karanovicpartners.com/news/harmonisation-of-serbian-law-on-payment-services-with-psd2/) retrieved 2026-07-04 2. T3 [https://www.lexology.com/library/detail.aspx?g=763c5618-b8cd-4622-b14f-1b86d1b0d792](https://www.lexology.com/library/detail.aspx?g=763c5618-b8cd-4622-b14f-1b86d1b0d792) retrieved 2026-07-04 3. T3 [https://www.ekapija.com/en/news/3466959/system-for-instant-payments-of-nbs-modern-way-of-payment-used-for](https://www.ekapija.com/en/news/3466959/system-for-instant-payments-of-nbs-modern-way-of-payment-used-for) retrieved 2026-07-04 4. T4 [https://globalfintechseries.com/fintech/paysend-invests-in-serbia-with-new-european-tech-center/](https://globalfintechseries.com/fintech/paysend-invests-in-serbia-with-new-european-tech-center/) retrieved 2026-07-04 5. T3 [https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia](https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia) retrieved 2026-07-04 ### W10 Consumer Protection & APP Fraud Probable confirmed 2026-07-04 Consumer protection for financial-services users runs through a dedicated NBS Department for Financial Consumer Protection with a free complaint/mediation route and NBS decisions on complaint handling; APP-fraud-specific reimbursement rules are limited, with IPS instant payments designed to be final/irreversible and consumer recourse depending on individual bank agreements under the Law on Payment Services rather than a mandatory reimbursement scheme. Standing sub-brief · as of 4 July 2026 196 words · last cycle 2026-07-04 #### Consumer Protection & APP Fraud The NBS Department for Financial Consumer Protection provides a free complaint and mediation route for financial-service consumers, governed by the Decision on Handling Complaints of Financial Service Consumers, with findings resolved within three months. This complaint mechanism is the principal formal consumer-recourse channel in the Serbian payments market. Set against it, the NBS IPS system is designed to be final and irreversible with no reversal function, and consumer recourse for authorised-push-payment disputes depends on individual bank agreements rather than on a mandatory reimbursement scheme; this is a notable consumer-protection gap relative to UK- and EU-style mandatory APP-fraud reimbursement regimes and is flagged as an under-indexed risk area in the underlying research. The reduced RSD 3,000 unauthorised-transaction liability threshold discussed in the Conduct, Safeguarding & Promotions module provides some consumer protection for unauthorised card transactions, but does not extend to authorised-but-fraudulently-induced IPS transfers. #### Outlook The trajectory is stable. The absence of a dedicated APP-fraud reimbursement scheme for the irreversible IPS rail is the clearest structural gap in Serbia's consumer-protection architecture and is the item most likely to attract future regulatory attention as IPS transaction volumes continue to grow relative to card payments. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://www.nbs.rs/en/ciljevi-i-funkcije/zastita-korisnika/prigovor/](https://www.nbs.rs/en/ciljevi-i-funkcije/zastita-korisnika/prigovor/) retrieved 2026-07-04 2. T1 [https://nbs.rs/en/drugi-nivo-navigacije/propisi/propisi-zk/](https://nbs.rs/en/drugi-nivo-navigacije/propisi/propisi-zk/) retrieved 2026-07-04 3. T3 [https://www.karanovicpartners.com/news/law-payment-services-serbia/](https://www.karanovicpartners.com/news/law-payment-services-serbia/) retrieved 2026-07-04 4. T3 [https://www.lexology.com/library/detail.aspx?g=e060c275-5dc0-4c51-8d50-4b069cc31712](https://www.lexology.com/library/detail.aspx?g=e060c275-5dc0-4c51-8d50-4b069cc31712) retrieved 2026-07-04 5. T4 [https://www.lightspark.com/knowledge/instant-payments-serbia](https://www.lightspark.com/knowledge/instant-payments-serbia) retrieved 2026-07-04 ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/serbia/#sec-dom-D7) Probable confirmed 2026-07-04 Serbia's AML/CFT posture is Sentinel.gi-fed for illicit-finance analysis; this baseline carries only the payments-context standing position drawn from public FATF/MONEYVAL status records, since the dedicated Sentinel.gi feed payload was not retrievable within this research pass. Serbia was removed from the FATF grey list in June 2019 and remains off both the June 2026 FATF grey list and blacklist, though it remains in enhanced MONEYVAL follow-up. Standing sub-brief · as of 4 July 2026 203 words · last cycle 2026-07-04 #### AML/CFT & Financial Crime Serbia was removed from the FATF grey list in June 2019 and, as of the 19 June 2026 FATF Plenary, remains off both the grey list and the blacklist. This module is sourced from the Sentinel.gi feed; the analysis carries that intelligence with attribution rather than re-analysing illicit-finance substance, which remains the Financial Intelligence Monitor's domain. Despite that favourable list status, Serbia remains in enhanced MONEYVAL follow-up, rated Compliant for 5 and Largely Compliant for 35 of the 40 FATF Recommendations in the 2024 assessment, with zero Highly or Substantially Effective ratings across the 11 effectiveness areas assessed. This pattern, combining strong technical-compliance ratings with a complete absence of top-tier effectiveness ratings, signals a continued implementation-effectiveness gap notwithstanding the jurisdiction's technical-compliance progress. The native Sentinel.gi illicit-finance feed payload for Serbia was not retrievable this pass, so this module's findings rely on public FATF and MONEYVAL status records only; this is flagged as an under-indexing risk pending fuller Sentinel.gi feed integration for the jurisdiction. #### Outlook The trajectory is stable. For deeper illicit-finance-specific analysis, readers should refer to Sentinel.gi and the Financial Intelligence Monitor directly; this module will continue to track headline FATF/MONEYVAL list-status and effectiveness-rating developments as they are published. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T1 [https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) retrieved 2026-07-04 2. T? FIM (sentinel.gi) per-JID baseline profile — Serbia — Serbia is a MONEYVAL member with a UBO registry, an FIU (APML) and a 2025 5th-round Mutual Evaluation Report just adopted. Off FATF's ICRG monitoring since 2019, but effectiveness gaps persist: politicized enforcement, an FIU historically overseen by a minister previously investigated for laundering, and non-alignment with EU Russia sanctions. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: sourcing-thinness 4. T3 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: U.S. Attorney's Office, Northern District of California (DOJ) — Nemanja Popov, Serbian national, Global Account Manager at GOTBIT 5. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: enforcement-absence 6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: political-constraint ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-04 Draft PS Law would remove restrictions blocking non-bank PIs/EMIs/postal operators from direct participation in significant payment systems, subject to NBS approval — a material access/interoperability shift from the current bank-centric access model; Serbia's non-EU status continues to preclude EU-style passporting. Standing sub-brief · as of 4 July 2026 210 words · last cycle 2026-09-14 #### Correspondent Banking, Settlement & Access NBS-authorised banks are required to establish correspondent relations within 90 days, and, because no US banks operate directly in Serbia, local banks rely on correspondent relationships with major US institutions for dollar-denominated and other international settlement. Citibank and Deutsche Bank maintain only non-banking representative offices in the jurisdiction rather than operating branches. The analytical spine of this module is the bank versus non-bank access asymmetry in Serbia's correspondent-banking structure: non-bank PIs and EMIs, discussed in the Licensing, Authorisation & Market Access module, sit outside this direct correspondent-banking access structure and depend instead on partnering banks for cross-border settlement, reinforcing the bank-PSP versus non-bank-PI/EMI asymmetry that runs through Serbia's payments regime. Separately, 2025 amendments to Article 45 of the Foreign Exchange Law expand NBS authority to act against banks performing international payments contrary to law or NBS regulations, extending Chapter VIII of that law to cover both foreign-exchange control and exchange-operations control together. #### Outlook The trajectory is stable. The absence of any directly operating US bank in Serbia, and the resulting dependency structure for both bank and non-bank PSPs, remains the defining structural condition for this module; the 2025 FX-oversight amendments give the NBS a stronger enforcement hand over how banks conduct that correspondent-dependent international-payments activity. Periodic update · new data 2026-09-14 #### Correspondent Banking, Settlement & Access Serbia's core settlement infrastructure continues to operate on a stable basis, with the National Bank of Serbia serving as system operator for real-time gross settlement, executing transactions on a real-time gross basis up to account cover under the NBS's own Operating Rules. This structural arrangement is unchanged this cycle and continues to define the settlement-access landscape for bank-PSP participants specifically, since RTGS access in Serbia, as in most jurisdictions, runs through the bank channel rather than being directly available to non-bank payment institutions. What has moved this cycle is the cooperation architecture around this infrastructure: the draft Chapter 9 Financial Services package proposes enhanced NBS cooperation with EU regulatory authorities, explicitly naming ESMA, the European Central Bank, and the national central banks of EU Member States. This proposal, if adopted, would deepen the cross-border regulatory-cooperation framework surrounding Serbia's settlement and correspondent-banking access ahead of any formal EU accession milestone, addressing the structural bank-versus-non-bank access asymmetry indirectly by strengthening the supervisory-cooperation layer around the bank-centric settlement system rather than by extending direct settlement access to non-banks. #### Outlook The item to watch is whether the proposed EU-regulator cooperation provisions are adopted as drafted, and whether any accompanying reform extends settlement-system access considerations to the non-bank PI/EMI segment, which currently remains outside direct RTGS participation. **2 earlier distinct update(s)** Periodic update · new data 2026-09-08 #### Correspondent Banking, Settlement & Access The defining analytical spine for this module in Serbia is the bank-versus-non-bank access asymmetry in significant payment systems, and this cycle offers two data points on it. First, a draft package under the EU accession process (Chapter 9) proposes removing the existing restriction barring payment institutions, e-money institutions and postal operators from participating directly in significant payment systems, an access channel currently reserved for banks; this is assessed at Probable confidence and remains at proposal stage. Second, and separately, draft amendments to the Law on Interchange Fees and Special Operating Rules for Card-based Payment Transactions would require issuers to maintain evidence that DinaCard-processed cards were actually delivered to payment service users, an Uncertain-confidence, draft-stage obligation specifically affecting bank and PSP card issuers within the domestic DinaCard scheme rather than significant-payment-system access generally. These two items sit at different points on the settlement-and-scheme-access spectrum: the significant-payment-system access reform is a structural settlement-access question determining who can participate directly, while the DinaCard delivery-evidence obligation is a narrower scheme-compliance requirement for existing issuers. Neither has been confirmed as enacted this cycle; both remain proposals. #### Outlook The significant-payment-system access liberalisation, if enacted, would be the more structurally consequential of the two developments, directly narrowing the bank/non-bank settlement-access gap that currently defines this module for Serbia. The DinaCard card-delivery-evidence obligation, by contrast, would add a documentation burden for existing card issuers without altering the underlying access structure. Both are Q4 2026-estimated, year-band-uncertainty items pending further confirmation. Periodic update · new data 2026-08-11 #### Correspondent Banking, Settlement & Access The most significant W12 development this cycle is the Draft Law amending the Law on Payment Services, which would remove restrictions currently preventing payment institutions, e-money institutions, and the public postal operator from participating directly in significant payment systems, subject to National Bank of Serbia approval. This is a high-confidence, secondary-sourced finding, and it is part of Serbia's EU-accession Negotiation Chapter 9 legislative package. This module's analytical spine is the bank-versus-non-bank access asymmetry, and this cycle's development goes directly to that asymmetry: today, direct participation in Serbia's significant payment systems is effectively bank-centric, with non-bank payment institutions and e-money institutions accessing settlement infrastructure indirectly, through bank intermediation. The draft reform would materially improve non-bank competitive positioning by opening a route to direct participation, subject to NBS discretion on approval, a structural access shift rather than an incremental conduct change. Serbia's continued status as a non-EU member state is the countervailing structural fact: it precludes EU-style licence passporting, meaning that even a successfully enacted reform of this kind remains a domestic-transposition exercise rather than an automatic mutual-recognition arrangement. #### Outlook The draft law is expected to progress under EU accession Chapter 9 with an estimated fourth-quarter 2026 impact date, carrying a half-year uncertainty band. Watch for NBS approval criteria for direct system participation to be published alongside or following the law's passage, since the practical value of the reform to non-bank payment institutions and e-money institutions will depend heavily on how restrictively NBS exercises that approval discretion. **Sources and findings (5)** 1. T1 [https://nbs.rs/en/finansijske-institucije/banke/banke-ino-spisak/](https://nbs.rs/en/finansijske-institucije/banke/banke-ino-spisak/) retrieved 2026-07-04 2. T3 [https://www.trade.gov/country-commercial-guides/serbia-trade-financing](https://www.trade.gov/country-commercial-guides/serbia-trade-financing) retrieved 2026-07-04 3. T1 [https://www.nbs.rs/en/finansijske-institucije/banke/predstavnistva/](https://www.nbs.rs/en/finansijske-institucije/banke/predstavnistva/) retrieved 2026-07-04 4. T3 [https://statt.rs/foreign-exchange-operations-in-serbia-2025-new-measures-penalties-and-enhanced-nbs-oversight/](https://statt.rs/foreign-exchange-operations-in-serbia-2025-new-measures-penalties-and-enhanced-nbs-oversight/) retrieved 2026-07-04 5. T2 [https://www.state.gov/reports/2025-investment-climate-statements/serbia](https://www.state.gov/reports/2025-investment-climate-statements/serbia) retrieved 2026-07-04 ### W13 Commercial Intelligence (M&A, Investment & Product) limited signal Probable confirmed 2026-07-04 Within the trailing 12 months (July 2025-July 2026), Serbia's payments-sector commercial intelligence is dominated by regulatory-driven market development (SEPA accession operationalisation, open-banking go-live, new cybersecurity law) rather than large payments-specific M&A/funding events; broader Serbian fintech investment activity remained modest relative to other startup verticals. Standing sub-brief · as of 4 July 2026 174 words · last cycle 2026-09-21 #### Commercial Intelligence (M&A, Investment & Product) Paysend opened its primary European technology hub in Belgrade and engaged with the NBS payment regulatory sandbox, marking the only identified discrete commercial event in this module meeting the trailing-12-month evidentiary threshold for Serbia. The transaction's value was not publicly disclosed. This inward investment signals continued fintech-sector interest in Serbia's payments market despite the thin broader funding base described in the Industry Structure & Commercial Dynamics module. Other candidate developments this cycle, including the SEPA accession rollout, the open-banking go-live, and the new information-security law, were reframed to the Payment Corridor Dynamics, Product Innovation and Operational Resilience modules respectively as structural or regulatory developments rather than discrete commercial deals, consistent with this module's scope as limited to specific announced transactions. #### Outlook The trajectory is thin. Given Serbia's still-nascent fintech funding base, additional discrete M&A, investment or product-release events meeting this module's evidentiary bar may remain infrequent; the Paysend hub's continued engagement with the NBS sandbox is the item most likely to generate a follow-on commercial development to track. Periodic update · new data 2026-09-21 #### Commercial Intelligence & Fintech Proposed amendments to the Law on Interchange Fees and Special Operating Rules for Card-Based Payment Transactions were published as part of the Summer-2026 National Bank of Serbia reform package, per Tier-3 reporting carrying Probable confidence. This is a discrete regulatory-development event distinct from the broader structural EU-accession harmonisation narrative discussed under W1a: it specifically targets the rules governing interchange fees and the operating practices for card-based payment transactions in Serbia, an area of direct commercial relevance to card issuers, acquirers, and scheme participants operating in the Serbian market. No further detail on the substantive content of the proposed amendments — such as specific interchange-fee caps, the scope of affected card products, or an effective-date estimate beyond the general 2027 horizon associated with the broader NBS reform package — was available in the sourcing this cycle. This is logged as an open item: the existence and general direction of the proposed amendment is confirmed at Probable confidence, but the granular commercial impact on any specific card scheme or acquirer relationship in Serbia cannot yet be assessed from the available evidence. #### Outlook The clearest indicator of forward movement on this specific development would be publication of the full amendment text or a Tier-1 NBS consultation document setting out the proposed interchange-fee structure. Until that occurs, card issuers and acquirers with Serbian exposure should treat this as a development to monitor rather than one requiring immediate operational response. **Sources and findings (4)** 1. T3 [https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia](https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia) retrieved 2026-07-04 2. T3 [https://qwist.com/en/resources/blog/open-banking/serbias-financial-market-in-transition/](https://qwist.com/en/resources/blog/open-banking/serbias-financial-market-in-transition/) retrieved 2026-07-04 3. T3 [https://www.karanovicpartners.com/news/from-nis2-to-serbia-how-the-new-information-security-law-impacts-your-business/](https://www.karanovicpartners.com/news/from-nis2-to-serbia-how-the-new-information-security-law-impacts-your-business/) retrieved 2026-07-04 4. T4 [https://tracxn.com/d/explore/fintech-startups-in-serbia/LuI-7EGZUl99pcA3eQLIj7SyffU4dBafCkLdm-w8FpI](https://tracxn.com/d/explore/fintech-startups-in-serbia/LuI-7EGZUl99pcA3eQLIj7SyffU4dBafCkLdm-w8FpI) retrieved 2026-07-04 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for Serbia| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. 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