- within International Law, Transport, Food, Drugs, Healthcare and Life Sciences topic(s)
- with readers working within the Accounting & Consultancy industries
July 2026 – Summer 2026 marks the beginning of an ambitious new phase in Serbia’s financial regulatory reform. In the context of the country’s EU accession process and the continued harmonisation of domestic legislation with that of the EU, under Negotiation Chapter 9 – Financial Services, the National Bank of Serbia ("NBS") has presented an extensive package of draft legislation affecting virtually every segment of the financial sector, including banking, insurance, consumer protection, financial conglomerates, pension funds, and financial services regulation generally.
As part of this package, the NBS has prepared amendments to the Law on Interchange Fees and Special Operating Rules for Card-based Payment Transactions ("Draft Law"). Against the backdrop of these broader financial sector reforms, we have taken a closer look at the proposed changes affecting interchange fees - paid by the acquirer’s bank to the card issuer for processing a card payment - that is addressed in the Draft Law.
The proposed changes seek to extend certain regulatory requirements to international card-based payment transactions, enhance transparency in the cards market, and reduce card acceptance costs for merchants, in line with the regulatory approach adopted within the EU.
The Draft Law introduces the distinction between card-present transactions (in-store payments where the cardholder is physically present) and card-not-present transactions (remote payments, including e-commerce transactions, where the cardholder is not physically present at the merchant's location) and, for the first time, extends interchange fee regulation to certain international card-based payment transactions involving cards issued outside Serbia and accepted by merchants in Serbia.
Under the proposed regime, interchange fees would be capped as follows:
- 2% of the transaction value for debit card card-present transactions;
- 3% of the transaction value for credit card card-present transactions;
- 15% of the transaction value for debit card card-not-present transactions (e-commerce and other remote payments);
- 5% of the transaction value for credit card card-not-present transactions.
In addition, the Draft Law amends the rules governing the issuance of payment cards that may be used to initiate payment transactions from a current account and for which the processing, clearing, and settlement of domestic payment transactions is carried out through a payment system in the Republic of Serbia (in practice, DinaCard). The proposed changes would require issuers to establish efficient card delivery procedures and maintain evidence that the card has been delivered to the payment service user. At the same time, the current requirement for a separate written customer request for the issuance of such payment cards in cases where the relevant processing, clearing, and settlement activities are not carried out in the Republic of Serbia would be removed.
Finally, the Draft Law provides for a nine-month transition period between its entry into force and the commencement of its application.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
[View Source]
