Why Serbia? The Growing E-Money Market

Serbia’s digital economy is booming, offering a lucrative opportunity for businesses looking to enter the electronic money market. With recent regulatory updates aligning with EU standards, obtaining an Electronic Money Institution (EMI) license in Serbia is now a streamlined yet structured process. If you’re considering launching your own EMI or Payment Institution, this guide will walk you through everything you need to know about obtaining an e-money license in Serbia.

What is Electronic Money?

Before diving into the licensing process, let’s define electronic money (e-money) according to Serbian law.

As per the Law on Payment Services, electronic money is:

• A monetary value stored electronically, representing a claim against the issuer.
• Issued upon receiving funds and used primarily for payment transactions.
• Accepted by individuals and businesses other than the issuer.

Common types of e-money:

• Prepaid cards (general spending, travel, gifting, etc.)
• Digital wallets (e.g., PayPal, Apple Pay, Google Pay)
• Mobile payment apps

If your business intends to issue, manage, or facilitate transactions with electronic money in Serbia, you’ll need an EMI license from the National Bank of Serbia (NBS).

Who Can Apply for an EMI License in Serbia?

Only a legal entity registered in Serbia can apply for an Electronic Money Institution (EMI) license. Additionally, the entity must meet several strict requirements, including financial stability, operational readiness, and compliance with anti-money laundering (AML) regulations.

Once licensed, an EMI can:

• Issue and redeem electronic money
• Offer and facilitate payment services (e.g., e-money transfers)
• Provide loans related to payment services
• Perform fraud prevention, transaction monitoring, and customer support
• Oversee and manage payment systems

Key Requirements for an E-Money License in Serbia

1. Initial Capital Requirement

To obtain an EMI license, your company must have at least €350,000 in initial capital, converted to Serbian dinars. This capital must remain available throughout the licensing process and after obtaining approval.

2. Application Documentation

The National Bank of Serbia requires 19 documents as part of the EMI license application process, including:

✅ Proof of business registration with the Serbian Business Registers Agency (APR)

✅ Founding act or company statute

✅ Business plan for the first three years

✅ Risk assessment and security measures

✅ Description of payment services provided

✅ Proof of initial capital (€350,000)

✅ AML and counter-terrorism financing procedures

✅ Internal control and management system details

✅ Organizational structure, including key personnel

✅ Information on external auditors and stakeholders

Missing any of these documents? The NBS will notify you within 30 days of submission and allow you to correct the issue.

Application Process and Timeline

1️⃣ Submit Application – Ensure all 19 required documents are complete.

2️⃣ Initial Review (30 days) – If anything is missing, the NBS will notify you.

3️⃣ Final Decision (3 months) – Once all documents are in order, the NBS has 90 days to approve or reject your application.

4️⃣ License Issued – If approved, your EMI can start operating immediately.

⚠️ Common Reasons for Application Denial:

• Incomplete or incorrect documentation
• Insufficient initial capital
• Business activities that conflict with financial regulations
• Issues with key personnel or company ownership

Revocation of an E-Money License

The National Bank of Serbia can revoke your EMI license if:

• You fail to start issuing e-money within 12 months of approval.
• You stop operations for more than 6 months.
• Your company engages in money laundering or financial fraud.
• Your company provides false information during the application process.

To avoid revocation, ensure full compliance with Serbian financial laws and AML regulations.

E-Money vs. Payment Institutions: What’s the Difference?

A common misconception is that Electronic Money Institutions (EMIs) and Payment Institutions (PIs) are the same. While both require licensing from the NBS, they serve different functions:

✅ EMIs issue and manage electronic money that can be used for payments.

✅ PIs focus on processing and facilitating payment transactions (without issuing e-money).

Serbia also allows hybrid payment institutions, which can both issue e-money and process payments.

Upcoming Changes: What to Expect in 2025

Serbia is implementing updates to its Law on Payment Services in May 2025, aligning with EU PSD2 regulations. Key changes include:

• Open banking services – New rules for account information and payment initiation services.
• Stronger security measures – Enhancing fraud prevention mechanisms.
• Greater interoperability – Improving integration between banks and financial technology firms.

These updates will make Serbia an even more attractive destination for fintech companies looking to launch digital payment solutions.

Need Help? Consult an E-Money Advisor

Navigating Serbia’s e-money regulations can be complex, but expert guidance can make all the difference. A specialized e-money advisor or law firm can help you:

✅ Prepare and submit your EMI application

✅ Ensure compliance with Serbian financial regulations

✅ Avoid delays and potential rejections

If you’re ready to start your EMI venture in Serbia, reach out to an experienced advisor today!

Final Thoughts

Getting an e-money license in Serbia is an exciting opportunity for businesses looking to enter the digital payment space. With clear regulations, a competitive market, and upcoming open banking reforms, Serbia is positioning itself as a key hub for electronic money services in Europe.

By following this guide and seeking expert assistance, you can navigate the application process smoothly and launch your EMI with confidence. 🚀