E-money License: Guide to Obtaining One in Serbia

Looking to start your own EMI venture or Payment Institution in Serbia? You've come to the right place, then.

Serbia's growing digital economy presents a lucrative opportunity for those entering the electronic money market. In other words, with the right strategy and guidance, establishing an EMI or Payment Institution here can lead to significant financial rewards and business growth.

However, tackling Serbia's regulatory requirements for obtaining an E-money license can be quite complicated demanding. 

If you aren't prepared for the meticulous documentation and attention to detail required for a successful application, or don't have a clear roadmap to guide you through this process, you might want to hire an e-money advisor. They can help you avoid potential delays and pitfalls associated with it.

Until then, our e-money advisors have created this guide to break down the key steps and requirements for obtaining an E-money license in Serbia for you. Let's get started!

Electronic Money Definition 

Looking to snag an E-money license in Serbia and venture into the world of electronic money services? 

Chances are, you're already familiar with the concept of E-money. Still, for the sake of fully understanding the relevant Serbian laws on this matter, let's take a look at how our country's electronic money regulations define it:

According to the Law on Payment Services, which governs this area, electronic money refers to monetary value stored electronically, representing a claim against the issuer of that money. Before issuing E-money, the law mandates that actual funds must be received, and it should primarily serve for payment transactions. The law also requires that E-money is accepted by both individuals and businesses other than the electronic money issuer.

In essence, electronic money offers an alternative to traditional cash transactions, and you've likely encountered some common types such as:

• Prepaid cards (for various purposes like general spending, gifting, or travel)

• Digital Wallets (think PayPal or Apple Pay)

• Mobile Payment Apps/MobilE-money

Clear? Okay, let's move on to the electronic money institutions, then.

Electronic Money Institution (EMI)

In Serbia, only a legal entity based in the country can be an Electronic Money Institution (EMI). 

To become an EMI, you need more than just a business address though – you need the green light aka an E-money license from the National Bank of Serbia. 

Once you get that coveted license, you can provide electronic money services like:

• Issuing and redeeming electronic money

• Offering and facilitating payment services (e.g., E-money transfer between accounts), as well as loans related to payment services

• Performing operative and auxiliary tasks directly related to the issuance of E-money or the provision of payment services (e.g., customer support, fraud prevention, transaction monitoring)

• Overseeing and managing the payment systems

• Performing other business activities unrelated to issuing electronic money or providing payment services.

Now that we've got the basics covered, let's zoom in on the star of the show: the E-money licenses.

E-money Exchange License

If you're thinking of becoming an electronic money issuer in Serbia, you've got to go through the hoops of obtaining an E-money license first.

Those hoops? 

An abundant list of documents you'll need to gather before you can even think about submitting your request. Seriously, it's a whole production (19 of them, to be exact!) 

Let's break them all down, step by step, in the next section.

a) Necessary Documentation for E-Money License

Okay, buckle up because we're diving deep into the paperwork you'll need to collect if you're aiming to be an electronic money issuer in Serbia. 

Here's the simplified rundown of the 19 documents required by the National Bank of Serbia to obtain an E-money license (you can find the more legalese version in the Law on Payment Services, Article 127):

1. The Decision on registration with the Serbian Business Registers Agency (APR).

2. The founding act or statute of your aspiring company.

3. A detailed list of payment services and other activities your EMI plans to offer

4. Risk Assessment

5. A program outlining how you'll provide those services.

6. A business plan projecting & mapping out your revenue and expenses for the first three years of doing business.

7. Proof that you've got the financial muscle to back it up, aka the required initial capital. (More about this requirement in the next section)

8. A projection of your capital needs for the first year, calculated in a specific manner.

9. Planned measures to protect your clients' funds.

10. The blueprint for your management and internal control systems.

11. Measures established to comply with regulations on anti-money laundering and counter- terrorism financing.

12. The lowdown on your organizational structure and operational tasks delegation.

13. Established procedures and mechanisms of internal controls and audits to protect the interests of electronic money holders and ensure continuous, stable, and secure issuance of electronic money/provision of payment services.

14. Explanation of how your EMI will participate in payment networks, if you intend to participate in them.

15. Information about the members of the management bodies of the applicant, as well as the future managers of the electronic money institution, with data and evidence that these individuals have a good business reputation, appropriate professional qualifications and the required experience.

16. Details on your stakeholders and the amount of their participation in your EMI, along with the evidence about their suitability for the management of your payment institution.

17. Details on your external auditor, in charge of auditing your financial statements.

18. Details on anyone closely connected to your EMI, along with a description of your relationship.

19. The address of your EMI's headquarters.

As you can gather, gathering all this paperwork is no easy feat, so having the right legal expert in your corner can make all the difference in the world. If you're thinking about providing electronic money services in business, you'll need an attorney familiar with the ins and outs of electronic money regulations in Serbia. Someone who'll guide you through each document, ensuring nothing slips through the cracks.

Reach out and find out more about starting your own EMI in Serbia!

b) E-Money License Requirements

In the section above, we've mentioned that one of the necessary documents for obtaining the E-money license is a document with the proof of having the required initial capital.

Essentially, you got to show the National Bank of Serbia that you've got the cash to back up your dreams of starting an EMI in Serbia.

The required amount? At least 350,000 euros of the initial capital, converted to dinars.

It's important that you know that this initial capital must be in place both during the application process and when you receive your license from the National Bank of Serbia.

The National Bank of Serbia also has specific rules on how to calculate this initial capital, so it's important to get all the details right.

c) E-Money License Application Process and Timeline

Thinking of registering an EMI in Serbia?

The National Bank of Serbia aims to make the process as smooth as possible while ensuring everything's in order, which is why it'll review your application within 3 months of receiving it (as long as it's complete). 

If your application ends up missing something, no worries! The NBS will let you know about what needs fixing within a month. Once you submit the completed application, that 3-month review clock starts ticking again.

E-money License Denial: What Now?

So, you've applied for an E-money License, but the National Bank of Serbia has denied your request. What now?

Well, the National Bank of Serbia can reject your application if they find that you don't meet the requirements set out in Article 82 of the law.

They can also turn down your application if they believe:

• Your close relationship with other entities would make it difficult or impossible for them to supervise your EMI.

• Supervising your electronic money institution would be hindered or significantly more difficult due to the laws of a third country that apply to the entities you're closely connected with, and the way these laws are applied.

• Your non-related business activities could jeopardize the stability and security of your payment institution, or significantly hinder their supervision under the law. In this case, the NBS may suggest that you set up a separate company.

To avoid having your E-money license request denied, it's best that you consult with a lawyer who specializes in helping foreigners set up businesses in Serbia beforehand and have them guide you through the process of obtaining the license. In any case, you may appeal the decision.

Revocation of an E-money License

The National Bank of Serbia can decide to take away your license in several instances.

For starters, it can do so if you haven't started issuing electronic money within 12 months of getting the license, or if you've stopped issuing it for more than six months. The same goes if you've informed them that you don't plan to issue electronic money anymore.

NBS can also revoke your license if it finds that you no longer meet the requirements they've set or that you got your license based on false information.

Some other reasons for E-money license revocation include:

• If continuing to issue electronic money could harm the stability of the payment system.

• If your activities are linked to money laundering or terrorist financing.

• If you haven't followed their NBS's and measures within the specified time frame.

• If you don't have enough capital as required by law.

• If you've seriously violated the rules laid out in the Law or related regulations.

• If you're making the supervision of your operations impossible.

If your license is revoked, it's a serious matter and it means you'll no longer be able to operate as an electronic money institution, so be cautious as to not violate any regulations or guidelines that could lead to such an outcome.

Payment Institutions

We're only going to mention payment institutions briefly to address a common misconception that they are the same thing as E-money institutions. 

While they share similarities, they each have distinct focuses and functions, at least under the Serbian law.

See, payment institutions are primarily focused on providing payment services, such as processing and facilitating payment transactions between payers and payees, while EMI's are primarily focused on issuing electronic money, which can then be used for making payments. 

Both types need permission from NBS (EMIs to issue electronic money, and payment institutions to provide payment services), but they each have their own set of rules to follow. 

In Serbia, there are also hybrid payment institutions. These do it all – they provide payment services and issue electronic money. 

To find out which option is best for you in Serbia and how to meet the specific requirements, it's best to consult with an E-money advisor.

Online gambling and casino licenses

Online gambling and casino licenses are often confused with e-money licenses, but they are distinctly different.

If you're eyeing the lucrative online gambling or casino market in Serbia, you'll need to secure the right, specific kind of license for this sort of business – one as outlined under the Law on Games of Chance.

This license is issued by the Government to legal entities registered in Serbia, with their main business being gambling and betting. In other words, company formation in Serbia will be your step first (and by clicking on the hyperlink we'll tell you how to do it without even coming to Serbia!).

As for the key requirements and the application process for obtaining an online gambling and casino license in Serbia, we'll devote a separate article to the topic.

E-money advisor

Obtaining an E-money license in Serbia can be quite challenging due to the intricate legal and regulatory requirements of our country. As such, this process demands meticulous documentation and attention to detail for a successful application.

Without the right guidance, you might find yourself facing delays and pitfalls, wasting precious time and resources – and that's exactly why you should consider seeking the help of an E-money advisor.

An E-money advisor will provide you with the roadmap you need to start your own EMI, Payment Institution, or even your own gambling business in Serbia. Contact us by e-mail at [email protected] to find out more about how you can turn your business idea into reality.

Advokat Stefan Pekic


Attorney at Law Stefan Pekić

overtime work in serbia

Overtime work in Serbia

Overtime work and the question of its legal regulation, no matter how simple they may seem, can easily become an extremely complex area. Especially when considering various factors such as the type of job and work environment.

Learn more »