How to set up electronic money and payment institutions in Serbia

How to set up electronic money and payment institutions in Serbia



Electronic Money Institutions (EMIs) and Payment Institutions (PI) are instrumental in making e-commerce and electronic payment possible across SWIFT messaging networks. The electronic payments market is growing at a rapid pace with businesses and consumers relying increasingly on electronic payments.





The services offered by Payment Institutions can vary from the provision of payment infrastructures to customers (e.g., for services industries) to services enabling payments between individuals, money remittance services,  issuing and/or acquiring of payment instruments. It also includes the facilitation of secure credit and debit card transactions, both nationally and internationally.





Electronic Money Institutions are institutions issuing electronic money, or “e-money”, which is a monetary value representing a claim against an issuer, which is:


  • stored in electronic format, (including on magnetic media),
  • issued against the remittance of funds with the goal of making payments, and
  • accepted by an individual or organization other than the issuer of the e-money.


In addition to issuing electronic money, EMIs are also permitted to supply all services of Payment Institutions, to grant loans (under certain conditions) linked to payment services, to supply operational services, and other services closely linked to the issuing of electronic money  the supply of payment services.





On December 18th, 2014, the National Assembly of the Republic of Serbia adopted the Law on Payment Services which entered into force on December 26th, 2014. Implementation of the Law is scheduled for October 1st, 2015, except for provisions for which the Law provides shall become applicable after the accession of the Republic of Serbia to the European Union.


The Law introduces significant improvements to the existing system, modernizing and aligning it with the directives of the European Union (Directive 2007/64/EC on payment services in the internal market, Directive 98/26/EC on settlement finality in payment and securities settlement systems, and Directive 2009/110/EC on the taking up, pursuit, and prudential supervision of the business of electronic money institutions), creating a harmonized, modern, and comprehensive set of rules for the provision of payment services at the EU level. A set of provisions in the Law will apply once the Republic of Serbia becomes a member of the EU.


The regulator follows the requirements of European standards and regulations, therefore e-money emitters and payment service operators must meet the requirements of PCI DSS. The use of cryptography in the data exchange, control of information and payments security, transparent control of access to information, and so on are among them. If EU residents use the services, the work is carried out in one of the European Union languages, you need to protect personal data according to GDPR regulation- with a written register, special technical means PO, and privacy policy.






The National Bank of Serbia is responsible for the issuance of licenses to payment institutions, as well as for the approval of a particular institution for the issuance of electronic money.


When applying for a license, an EMI will face regulatory due diligence.


An EMI must demonstrate that it has high-quality software and strong technology infrastructure. They must establish internal controls, safety measures and a plan to manage operational risks to ensure payment security and prevent fraud. The EMI must also have several pieces of information when applying for a license. This information includes:


  • a business plan and financial projections,
  • a description of the EMI’s organizational structure,
  • procedures for monitoring, handling, and following up on security breaches and customer complaints and
  • internal protocols for combating money laundering and terrorist financing

These are just some of the requirements the EMI must meet to obtain a license. Every EMI has unique challenges in obtaining the license.


The National Bank of Serbia must decide on an application for a license to issue electronic money no later than three months following the day of receipt of a duly completed application. The register of PI and EMI is maintained by the National Bank of Serbia.






Authorization may only be granted to a legal person incorporated under Serbian law, which must be established in the form of a limited liability company  (DOO) or joint-stock company (AD).





The LPS Law requires a minimum capital of at least:

  • EUR 20,000 – 125,000 for a Payment Institution, depending on the type of payment services.,
  • EUR 350,000 for an Electronic Money Institution.


The Company must at all times respect its funds as set out by the Law.






  • Incorporation of a Company
  • Filing of the application file, with a filing fee of EUR 2,000
  • The regulator examines the application file and may come back for more information and clarification
  • In general, successful applications for PI and EMI licenses take between 6 – 12 months, depending on the complexity of the business and the quality of the application file.

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