2024-08-16
The Executive Board of the National Bank of Serbia issued this Decision to establish minimum standards for information system management, security, and business continuity for Serbian financial institutions. It mandates that institutions implement comprehensive risk management frameworks, internal audit processes, and strict security controls including access management and malware protection. Additionally, the regulation requires the adoption of business continuity and disaster recovery plans, with mandatory annual testing and immediate notification to the regulator in the event of significant disruptions.
RS Official Gazette, Nos 23/2013, 113/2013, 2/2017, 88/2019, 37/2021 and 100/2023 – other decision Pursuant to Article 15, paragraph 1 and Article 63, paragraph 2 of the Law on the National Bank of Serbia (RS Official Gazette, Nos 72/2003, 55/2004, 85/2005 – other law, 44/2010, 76/2012 and 106/2012), the Executive Board of the National Bank of Serbia issues the following DECISION ON MINIMUM INFORMATION SYSTEM MANAGEMENT STANDARDS FOR FINANCIAL INSTITUTIONS I. INTRODUCTORY PROVISIONS
information system means a comprehensive set of technological infrastructure (hardware and software assets), organisation, people and procedures for the collection, processing, storage, transfer, presentation and use of data and information;
information system resources means software assets, hardware assets and information assets;
software assets means all types of system and application software, software development tools and other software;
hardware assets means computer equipment, communication equipment, data storage media, and other technical equipment supporting the functioning of the information system;
information assets means data in files and databases, program code, configuration of hardware assets, technical and user documentation, internal regulations, procedures etc;
information system users means all persons authorised to use the information system (employees in a financial institution, employees in other entities accessing the information system of a financial institution, clients of a financial institution accessing the institution’s information system through electronic interactive communication channels etc);
information system risk means the possibility of negative effects on the financial result and capital, achievement of business objectives, operation in accordance with regulations, and reputation of a financial institution due to inadequate information system management or other system weaknesses which negatively affect the system functionality or security, and/or jeopardise the business continuity of the financial institution;
controls means policies, procedures, practices, technologies and organisational structures relating to the information system and established to reasonably ensure that business objectives of a financial institution will be achieved and that undesired events will be prevented or detected. Controls may differ by the implementation method (administrative, technical and physical) and purpose (preventive, detective and corrective);
administrative controls means the adoption and implementation of policies, standards, plans, procedures and other internal acts, and the establishment of an adequate organisational structure, for the purpose of achieving and maintaining the adequate level of information system functionality and security;
technical controls means controls implemented in hardware and software assets of the information system;
physical controls are controls protecting the information system resources from unauthorised physical access, theft, physical damage or destruction;
preventive controls means controls aimed at the prevention of problems and incidents;
detective controls means controls aimed at the detection and recognition of problems and incidents, and the identification of problems and incidents which occurred;
corrective controls means controls aimed at the limitation and elimination of problems and consequences of incidents;
incident means every unplanned and undesired event that may jeopardise the information system security or functionality;
information system security means upholding the principles of confidentiality, integrity, availability, authenticity, accountability, nonrepudiation and reliability;
confidentiality means that data and information are not disclosed or made available to unauthorised persons;
integrity means that data, information and processes are protected from unauthorised or unforeseen modifications, or that any such modifications do not remain undetected;
availability means that data, information and processes are available and usable on request of the authorised party;
аuthenticity means that parties involved are who they claim they are;
accountability means that each activity in the information system may be traced uniquely to its source;
non-repudiation means that an activity performed in the information system or receipt of information cannot be denied;
reliability means that the information system consistently and expectedly performs the anticipated functions and provides correct information;
authorisation means granting access rights to information system users;
identification means user identity presentation upon login and in the course of activity in the information system;
authentication means user identity verification and confirmation by using one of the following elements or their combination: – something that only the user knows (e.g. the password, personal identification number etc), – something that only the user possesses (e.g. magnet card, chip card, token, cryptographic key etc), – something that only the user is (biometric characteristics such as the fingerprint, iris, voice, handwriting etc);
privileged access to the information system means access to information system resources which enables authorised users (administrators of system software, network, databases etc) to override technical controls;
remote access to the information system means access to information system resources from a remote location by using the telecommunication infrastructure over which a financial institution does not have full control;
operational and system logs means chronological logs about events and activities on information system resources (logs of operating systems, application software, databases, network devices etc);
malware means any type of program code created with the intention to gain unauthorised access to information system resources, collect information, cause unexpected behaviour or interruption in functioning of this system, and/or to otherwise potentially jeopardise the confidentiality, integrity or availability of these resources (e.g. computer viruses, worms, Trojan horses etc);
critical/key business processes means business processes or functions whose inadequate functioning may significantly jeopardise the operation of a financial institution;
maximum acceptable outage (MAO) means the maximum acceptable period of unavailability of a business process, and/or the critical time for process recovery;
service delivery objective (SDO) means the adequate level of business process recovery which should be achieved within the recovery time objective;
recovery time objective (RTO) means a period, and/or phases in the period during which the adequate level of business process recovery is to be achieved;
recovery point objective (RPO) means the longest acceptable period from the last backup copy until the occurrence of unavailability of a business process;
backup copy means the copy of at least those source data (software assets and information assets) which are needed for the recovery and/or reestablishment of business processes;
electronic services means services which clients of a bank, payment institution, electronic money institution and the public postal operator use remotely through the internet, and which include accessing a payment and another account, initiating payment transactions and other activities which involve accessing data in relation to the services of these financial institutions which could be subject to fraudulent activities or other abuse. II. INFORMATION SYSTEM MANAGEMENT FRAMEWORK
the security and functionality of the system, and shall define by an internal regulation, in accordance with law, the authorisations and responsibilities of its management and supervision bodies relating to these activities. 5. In accordance with its business strategy and the nature, volume and complexity of operation, a financial institution shall adopt the information system development strategy. In accordance with the information system development strategy, the financial institution shall adopt the appropriate strategic and operational plans. When needed, the financial institution shall amend the information system development strategy, particularly if this is required by amendments and/or supplements to its business strategy. The financial institution shall notify the National Bank of Serbia on any amendments and/or supplements to the information system development strategy, 15 days upon their adoption. 6. For the purpose of adequate information system management, a financial institution shall provide adequate organisational structure, with a clearly defined distribution of tasks and responsibilities of employees, and/or with established internal controls which prevent the conflict of interest. As part of the distribution of tasks and responsibilities referred to in paragraph 1 hereof, the financial institution shall clearly define tasks and responsibilities of employees which are directly related to efficient and appropriate management of information system security. 7. A financial institution shall ensure the application of all internal regulation and procedures relating to the information system, and shall also ensure that all system users are familiar with the content of these regulations and procedures, in accordance with their authorisations, responsibilities and needs. 8. A financial institution shall adopt and document the adequate methodology to determine the criteria, manner and procedures of managing projects related to the information system. 9. A financial institution shall determine the criteria, manner and procedures of reporting to its competent body about relevant facts relating to the information system functionality and security.
III. INFORMATION SYSTEM RISK MANAGEMENT 10. Provisions of regulations on general terms and method of managing risks in operation of financial institutions shall also apply to information system risk management, unless stipulated otherwise by this Decision. 11. Within the comprehensive risk management system, a financial institution shall establish the information system risk management process which includes risk identification, measurement, assessment, mitigation, monitoring and control. 12. A financial institution shall manage the information system risk in order to ensure smooth management of the system security and business continuity of a financial institution. Information system risk management must cover the entire information system of a financial institution and must be integrated in all phases of system development. 13. A financial institution shall adequately manage risks arising from contractual relations with legal and natural persons whose activities relate to its information system. A financial institution shall continuously supervise the manner and quality of contracted activities referred to in paragraph 1 hereof. IV. INTERNAL INFORMATION SYSTEM AUDIT 14. In accordance with the nature, volume and complexity of operation, and the complexity of the information system, a financial institution shall cover by its internal audit methodology the criteria, manner and procedures for the internal audit of this system based on the results of risk assessment. 15. Internal audit of the information system of a financial institution shall be performed in accordance with regulations on operation of financial institutions. V. INFORMATION SYSTEM SECURITY 16. In accordance with complexity of the information system, a financial institution shall adopt an internal regulation to establish the framework for system security management (hereinafter: information system security policy). The information system security policy shall define in particular the principles, manner and procedures of achieving and maintaining the
adequate level of system security, including the authorisations and responsibilities relating to system security and resources. A financial institution shall harmonise the security policy with changes in the environment and the information system. 17. A financial institution shall establish the process of information system security management as a continuous process of identifying needs for such security and achieving and maintaining the adequate level of such security. In accordance with the nature, scope and complexity of operations, as well as the information system complexity, the financial institution shall:
For the purpose of achieving and maintaining the adequate level of information system security, a financial institution shall establish adequate controls.
A financial institution shall by its internal regulations determine in more detail the criteria, manner and procedures for the classification of information assets according to the degree of sensitivity and criticality – in light of possible consequences of jeopardising their confidentiality, integrity and availability, and shall consistently implement such classification and accordingly ensure the adequate level of protection of these assets. A financial institution shall appoint a person and/or persons employed in that institution, who shall be responsible for the management, classification and protection of information assets.
A financial institution shall implement the adequate control of access to information system resources and, in relation to this, it shall establish an adequate system of managing user access rights. The system of managing user access rights shall encompass in particular the processes of registering, authorisation, identification and authentication of information system users, including the supervision of user access rights. A financial institution shall ensure that the authorisation of information system users be based on the principle of granting the minimum possible access rights to system resources, which enable the efficient performance of activities. A financial institution shall periodically and when required, but at least once a year, revise user access rights. When managing user access rights, a financial institution shall regulate in particular the privileged and remote access to the information system.
Based on the results of information system risk assessment, a financial institution shall establish an appropriate system of monitoring the information system and generating operational and system logs. A financial institution shall ensure the adequate protection, and specify the retention period, as well as the frequency, scope and manner of monitoring logs referred to in paragraph 1 hereof. The logs referred to in paragraph 1 hereof must contain a sufficient quantity of information to enable the identification of problems, reconstruction of events, detection of unauthorised access and activities relating to information system resources, as well as to enable the establishment of related responsibilities.
By applying appropriate controls, a financial institution shall protect information system resources and other systems supporting the functioning of the information system against unauthorised physical access, theft, physical damage or destruction caused by a human or natural factor. A financial institution shall in particular ensure the integrity of payment transactions data during their processing and storage, and during any other activity relating to these data.
A financial institution shall protect information system resources against malware by applying appropriate controls. VI. BUSINESS CONTINUITY MANAGEMENT AND INFORMATION SYSTEM DISASTER RECOVERY
In order to ensure smooth and continuous functioning of all its important systems and processes, and to limit losses in emergency situations, a financial institution shall establish the business continuity management process.
A financial institution shall ensure that business continuity management be based on the business impact analysis and risk assessment, which include in particular:
conditions for the recovery and availability of resources of the information system, needed for the performance of critical/key business processes. The business continuity plan shall contain in particular:
with law, shall be responsible for the implementation of plans referred to in paragraph 1 and paragraphs 4–6 hereof. 27. In managing business continuity, a financial institution shall also take into account the outsourced activities and the dependence on services of these persons. 28. In case of circumstances requiring the implementation of the business continuity plan and the disaster recovery plan, a financial institution shall inform thereof the National Bank of Serbia, by no later than the next day following the occurrence of these circumstances. The National Bank of Serbia may require additional documentation relating to relevant facts about these circumstances and may set the deadline for the submission of such documentation. 29. A financial institution shall establish the incident management process providing a timely and efficient response in the case of breach of security or functionality of information system resources. In case of an incident which seriously jeopardised or disturbed its operation or which could seriously jeopardise or disturb its operation, a financial institution shall inform the National Bank of Serbia:
The financial institution shall submit to the National Bank of Serbia the final report on the incident which occurred 15 days upon the cessation of the incident, i.e. as of the day it estimates that the financial institution has resumed its regular operations and the information system is stable. This report shall contain the final information on the incident – dates of occurrence and cessation of the incident, length of the incident, type of the incident (inaccessibility of hardware components, problems in operation of software components or security incident), description of the incident, causes of occurrence and consequences of the incident, activities taken by the financial institution in the course of the incident, plan of preventative activities to preclude repeated occurrences of the same incident, the number of users affected by the incident, the incurred financial costs connected with the incident, impact on other financial institutions and other relevant information, as needed. 29a. A financial institution shall quarterly report to the National Bank of Serbia on incidents related to abuse of sensitive data of financial service consumers, unauthorised payment transactions, abuse, theft or loss of payment instruments, including technical manipulations on ATMs, frauds and abuses of financial service consumers, abuses of authentication factors and authentication system etc. which did not directly impact its information system. The report from paragraph 1 hereof shall be submitted by no later than 10th day of the first month in the quarter and the National Bank of Serbia may regulate in more detail the manner of report submission. 30. A financial institution shall establish the backup management process, and shall for this purpose determine detailed procedures and responsibilities. Backup management must include the procedures of backup copies creation, storage and testing, as well as the restoration of data and software assets, so as to enable the reestablishment of business processes within the recovery time objective. A financial institution shall ensure that backup copies are up-to-date and adequately protected, and that recovery procedures are tested and successful. At least one up-to-date and complete backup copy must be adequately stored at an appropriate distance from the source location, based on results of information system risk assessment and taking into account the need to avoid the impact of the same risks on both locations.
The change management for software assets of the information system shall in particular include the following procedures:
hereof, and the bank shall also submit a request for enabling the functioning of an interim account of the legal successor (hereinafter: request for an interim account), which must be signed by the legal representative of the legal successor – so that National Bank of Serbia can act upon the request in the cases determined in this Section. An interim account of a legal successor shall be an account of a bank which ceases to exist due to a status change, this account being opened at the National Bank of Serbia in accordance with the regulations, and/or rules of operation of the payment system in which that bank participates, which is, due to the status change, taken over by the legal successor, for the purpose of its interim functioning within the deadline set by this Decision. A financial institution which decides to implement the plan of restoration to the status prior to data migration shall promptly inform the National Bank of Serbia thereof. If it decides to implement the plan of restoration to the status prior to data migration due to a status change, the bank shall notify the National Bank of Serbia thereof not later than the next business day after the day when it started data migration and not later than one hour prior to the start of the period set by the Daily Time Schedule of the NBS RTGS payment system (hereinafter: NBS RTGS system) for executing transfer orders in that system. The National Bank of Serbia shall enable the functioning of the interim account referred to in paragraph 4 hereof in the event that a bank decides to implement the plan of restoration to the status prior to data migration. Notwithstanding paragraph 7 hereof, if there are objective circumstances that may jeopardise the interests of clients of the bank implementing data migration due to status change, the National Bank of Serbia may, on a reasoned requested submitted by the bank along with the documentation referred to in paragraph 3 hereof, separately determine the deadline for the implementation of the data migration process and enable the functioning of the interim account within that deadline. The financial institution shall implement data migration due to status change no later than ten business days after the day it started to implement the plan, and/or within the deadline determined by the National Bank of Serbia in accordance with paragraph 8 hereof. An interim account of a legal successor referred to in this Section, as well as the actions of the National Bank of Serbia in accordance with the request for an interim account shall be regulated in more detail by the Operating Rules of the NBS RTGS Payment System.
IX. ELECTRONIC SERVICES 49. As an integral part of information system risk management, a bank, payment institution, electronic money institution and the public postal operator providing electronic services (hereinafter: electronic service provider) shall establish the process of managing risks arising from the provision of electronic services. 50. In providing electronic services, an electronic service provider shall apply secure and efficient methods for the verification and confirmation of the identity and authorisations of persons, processes and systems. An electronic service provider shall ensure that user authentication is enabled during the use of these services, and that it consists of the combination of at least two mutually-independent elements for user identity confirmation. By way of derogation from paragraph 2 hereof, an electronic service provider may apply user authentication containing a single element for user identity confirmation, in the case of:
analysis and method to manage risks arising from the provision of services in the manner specified in items 1) to 5) of that paragraph and other relevant documentation pertaining to this analysis. The analysis referred to in paragraph 4 hereof shall also include the analyses referred to in paragraph 3, items 4) and 5) hereof, if an electronic service provider intends to implement user authentication by using a single element for user identity confirmation in cases envisaged under those items. The deadline referred to in paragraph 4 hereof shall be calculated from the day of submitting complete documentation referred to in that paragraph. 51. An electronic service provider shall adopt and implement rules that shall accordingly, in line with the market practice and risk assessment, limit the number of attempts to log into the electronic services system, i.e. the number of authentication attempts, to set the longest user idle time upon logging into the system, and to define the validity period of authentication parameters. When using one time passwords for authentication (e.g. One Time Password – ОТP), an electronic service provider shall ensure that the validity time of that password is restricted to the time required to perform authentication. An electronic service provider shall set the maximum number of unsuccessful attempts to log into the electronic services system, after which that system will be permanently or temporarily blocked, and shall also set the procedures for safe re-activation of this system. An electronic service provider shall set the longest possible user idle time on the electronic services system after logging into the system, upon which the user will be automatically logged out of the system (the so-called session timeout). An electronic service provider shall make sure that appropriate confirmation of its identity is available on the electronic services distribution channel so that users can verify the authenticity of the electronic service provider. An electronic service provider shall make sure that operational and system logs are available so as to ensure, to the extent applicable, the nonrepudiation and accountability of actions relating to the provision of electronic services.
X. TRANSITIONAL AND FINAL PROVISIONS 52. An insurance undertaking, financial leasing provider and voluntary pension fund management company which outsource to a third person some of the activities referred to in Section 40 of this Decision until 30 June 2014 shall inform thereof the National Bank of Serbia by no later than 31 July 2014. Along with the notification referred to in paragraph 1 hereof, an insurance undertaking, financial leasing provider and voluntary pension fund management company shall submit to the National Bank of Serbia the documentation and data determined in Section 45, paragraph 2 of this Decision. A bank which outsources to a third person some of the activities referred to in Section 40 of this Decision until 31 December 2013, shall submit to the National Bank of Serbia, by no later than 31 January 2014, the exit strategy referred to in Section 42, paragraph 1, subparagraph 3 of this Decision. If the third person referred to in paragraph 3 hereof is headquartered outside of the Republic of Serbia or it has been agreed that it shall perform the outsourced activities outside of the Republic of Serbia, a bank shall submit to the National Bank of Serbia, along with the exit strategy referred to in paragraph 3 hereof, the evidence referred to in Section 45, paragraph 2, subparagraph 8 of this Decision. 53. Sections 17 and 18 and Sections 68–72 of the Decision on Risk Management by Banks (RS Official Gazette, Nos 45/2011, 94/2011, 119/2012 and 123/2012) shall cease to be valid as of 1 January 2014. Sections 6 and 8 of the Decision on Minimum Requirements Regarding Organisational and Technical Resources of Voluntary Pension Fund Management Company (RS Official Gazette, No 23/2006) shall cease to be valid as of 1 July 2014. 54. This Decision enters into force on the eighth day following its publication in the RS Official Gazette and shall apply as of 1 January 2014 to banks and as of 1 July 2014 to insurance undertakings, financial leasing providers and voluntary pension fund management companies. NBS Executive Board No 7 Chairman of 12 March 2013 Executive Board of Belgrade the National Bank of Serbia
Governor of the National Bank of Serbia Jorgovanka Tabaković, PhD