These changes will take effect on May 6, 2025. Key modifications include the following:
Foreign E-Money Issuers (EMIs): EMIs registered with the National Bank of Serbia (NBS) that currently offer limited payment services in Serbia under an exemption will need to comply with new requirements. These EMIs will be required to register with the NBS and provide additional information, including an email address for communication. The NBS will have the authority to deregister or refuse registration to EMIs involved in money laundering or terrorism financing.
Unlicenced firms: companies not currently licenced or registered with the NBS but engaged in activities covered by PSA exemptions will need to comply with the new regulations.
New service providers: firms wishing to offer account information services (AIS) or payment initiation services (PIS), which were previously unregulated, will need to meet new requirements.
Existing Payment Service Providers (PSPs): local PSPs must update their bylaws to align with the amended PSA by February 2025.
Fintech startups: new and emerging fintech startups can use a regulatory sandbox to test their business models with reduced regulatory burdens.
Cross-border transactions: foreign EMIs will not need a licence for processing cross-border payments for Serbian residents, provided they comply with foreign exchange regulations. However, Serbian residents will be restricted from funding foreign e-wallets or receiving fiat currency from unregistered EMIs.
Local transactions: the PSA exemptions will continue to exclude certain activities, including direct cash payments, cheques, cash transportation, payment services related to securities, and services by technical providers and independent ATM deployers. Exemptions related to commercial agents, limited network services, and electronic communications will be revised.
Commercial Agent Exemption (CAE): the revised PSA limits this exemption to agents acting solely on behalf of either the payer or payee, which may affect ecommerce platforms.
Limited Network Exemption (LNE): The new PSA narrows this exemption by specifying that payment instruments must be used in a ‘limited way’ and introduces a notification requirement for transactions exceeding EUR 1 million in RSD counter-value.
Electronic Communications Exemption (ECE): this exemption now applies specifically to providers of electronic communications services and includes transaction value limits. Providers must notify the NBS and submit an annual audit opinion.
AIS will allow consolidated access to information from multiple payment accounts. Providers must be registered with the NBS and meet certain conditions, including professional indemnity insurance.
PIS will enable initiation of payments from accounts held with other providers. PIS providers must be authorised by the NBS, with requirements including a comprehensive application and a capital requirement of EUR 50,000.
The amended PSA introduces a regulatory sandbox concept, allowing companies to test innovative payment services with regulatory flexibility. The NBS will establish specific conditions and timeframes for sandbox participation through implementing regulations.
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