Serbia#
NBS is sole authorising body for PIs/EMIs; the Law on Payment Services (amended 31 July 2024, applicable since 6 May 2025) harmonised with PSD2. A further NBS draft amendment package (public consultation closed 11 June 2026) aims at full EU-acquis alignment implementing Regulation (EU) 2024/886, raising maximum administrative penalties from 800,000 to 1,000,000 RSD; not yet confirmed adopted by the Assembly.
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.
Licensing, Authorisation & Market Access
The National Bank of Serbia has published a draft amendment to the Law on Payment Services that aims at full harmonisation with the European Union acquis in payment services. The draft covers instant credit transfers under EU Regulation 2024/886, the second Payment Services Directive, the cross-border payments regulation 2021/1230, the SEPA regulation 260/2012, and the Settlement Finality Directive. Public comment on the draft closed on 11 June 2026, and the draft has not been confirmed adopted by the Assembly, so it remains at the consultation stage rather than in force.
The substance of the draft extends well beyond a technical transposition exercise. It raises the maximum administrative fine applicable to payment service providers that breach any of approximately ninety listed provisions, from 800,000 to 1,000,000 dinars. A near-25-percent increase in the statutory penalty ceiling, applied across a wide span of specific obligations rather than a narrow subset, indicates that the drafters intend the raised ceiling to bite across the regime generally rather than targeting one specific compliance failure mode. This is the kind of detail that is easy to read as a minor technical adjustment but that in practice resets the deterrence calculus for the entire licensed population, since a provider now faces materially higher downside across the full range of conduct obligations the law already lists.
The draft also proposes a fee-parity rule for cross-border euro payments: a payment service provider would be barred from charging more for a euro-denominated payment sent outside Serbia than it charges for an equivalent domestic payment. This provision, if adopted, would directly target one of the more persistent frictions in cross-border retail and commercial payments — the tendency for cross-border transfers to carry a meaningfully higher fee than a domestic transfer of identical value and currency, even where the underlying processing cost difference does not justify the gap. Pairing this fee-parity requirement with the broader EU acquis alignment suggests the draft is not simply a compliance-catchup exercise but an attempt to bring the practical cost experience of cross-border payment users in Serbia closer to what EU-area users experience under the existing acquis.
It is worth being precise about what stage this sits at. The draft has cleared public consultation, which closed on 11 June 2026, but there is no confirmation that the draft has advanced to or been adopted by the Assembly. The absence of a confirmed adoption date is itself informative: licensing and market-access requirements that remain in draft form are not yet enforceable, and payment service providers operating in or into Serbia should treat the fine increase and fee-parity requirement as prospective rather than current obligations until adoption is confirmed. The direction of travel, however, is unambiguous — the National Bank of Serbia has committed, in a formal draft text subjected to public consultation, to a comprehensive EU acquis alignment programme covering some of the most consequential pieces of the payments acquis, including the instant-payments regulation that has reshaped retail payments expectations across the European Union itself.
This licensing and market-access tightening should also be read alongside Serbia's parallel integration into the SEPA payment corridor, which is an operational fact already in force rather than a proposal. The two developments reinforce each other: a jurisdiction integrating operationally into the SEPA corridor while simultaneously drafting the domestic statutory alignment needed to support that integration on a legal basis is behaving consistently with a genuine, rather than symbolic, EU-alignment trajectory.
Outlook
The principal item to track is whether and when the draft Law on Payment Services proceeds from the closed consultation stage to Assembly submission and adoption. No expected adoption date has been confirmed. Once adoption is confirmed, the raised penalty ceiling and the fee-parity requirement would take effect as binding obligations on the licensed population, and the practical compliance burden for payment service providers — particularly around pricing structures for cross-border euro transfers — would shift from a planning exercise to an active implementation requirement. Given the direction already established by the SEPA accession, continued legislative progress toward adoption is the more likely trajectory, though the absence of a stated timeline means the pace of that progress cannot be assessed with confidence at this point.
6 earlier distinct update(s)
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.
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.
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.
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.
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.
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)
- T1https://www.nbs.rs/en/finansijske-institucije/pi-ien/retrieved
- T1https://www.nbs.rs/export/sites/NBS_site/documents-eng/propisi/zakoni/law_payment_services.pdfretrieved
- T3https://bdkadvokati.com/serbia-amends-payment-services-regulations-to-allow-open-banking-services/retrieved
- T3https://statt.rs/payment-institutions-in-serbia/retrieved
- T3https://practiceguides.chambers.com/practice-guides/fintech-2026/serbiaretrieved