Proposed Amendments To Serbia’s Law On Payment Services

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 of reforms, the NBS has prepared amendments to the Law on Payment Services ("Draft PS Law").

The amendments proposed in the Draft PS Law represent a further step in the harmonisation of Serbian payment services legislation with the European Union regulatory framework. In particular, the Draft PS Law seeks to implement the latest EU developments in the areas of payment services, cross-border payments, SEPA integration, and settlement finality, thereby bringing the domestic legal framework closer to applicable European standards. The notable amendments and additions are: 

Enhanced fraud prevention and fund recovery mechanisms

The Draft PS Law introduces a significantly more detailed framework for dealing with payment transactions suspected of involving fraud or misuse. Once a payer reports a potentially fraudulent transaction, the payer’s payment service provider must promptly request supporting information and, where appropriate, initiate a formal fund recovery procedure with the payee’s payment service provider. The Draft PS Law provides for the obligation of the payee’s payment service provider to immediately act upon a recovery request and, where funds have already been credited to the payee, prevent their disposal for a temporary period. The Draft Law also establishes liability for payment service providers that fail to submit or process recovery requests in a timely manner in situations where fraud is subsequently confirmed. In addition, a specific legal basis is introduced for the exchange and processing of personal data for fraud prevention, detection, and fund recovery purposes.

Framework for interoperability between payment systems

The Draft PS Law introduces a comprehensive framework for interoperability between payment systems aimed at ensuring that different payment systems can communicate and exchange data using common international and European standards, thereby enabling more efficient and uninterrupted execution of payment transactions. This approach is expected to facilitate further modernisation of the Serbian payments infrastructure and its alignment with European market practices.

Broader access to significant payment systems

The existing restrictions preventing payment institutions, electronic money institutions, and public postal operators from participating in significant payment systems would be removed. Under the Draft PS Law, such entities would be able to participate directly, provided that they obtain the approval of the National Bank of Serbia and satisfy a range of operational, governance, risk management, and safeguarding requirements intended to preserve the stability and security of the payment system.

Additional compliance requirements

Payment institutions would be subject to additional compliance obligations, including certain measures linked to sanctions screening and restrictions on the disposal of assets for the purposes of combating terrorism financing and the proliferation of weapons of mass destruction. The Draft PS Law also further develops the framework for safeguarding users’ funds and broadens the range of mechanisms available for that purpose.

Increased penalties

The maximum monetary fine for violations of the Law would increase from RSD 800,000 to RSD 1 million, reflecting the regulator's intention to strengthen enforcement of payment services regulation.

EU accession-related measures

The Draft PS Law also contains a separate set of provisions that become applicable upon Serbia’s accession to the European Union. These provisions are aimed at facilitating Serbia’s integration into the European payments market and include the equalisation of fees for domestic and cross-border euro payments, enhanced transparency requirements regarding currency conversion charges, the introduction of additional information obligations in relation to currency conversion services, measures supporting the automation of payment processing through the broader use of IBAN and BIC identifiers, broader access to significant payment systems for certain EU-regulated institutions, as well as enhanced cooperation between the National Bank of Serbia and EU regulatory authorities, including ESMA, the ECB, and the national central banks of EU Member States. 

Transitional period

Market participants benefit from a nine-month implementation period following the entry into force of the Law, allowing payment service providers and other stakeholders sufficient time to align their systems, procedures, and internal governance frameworks with the new requirements.

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.