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Serbia: crypto & digital assets regulation

Regulated

Serbia: VASP licensing via NBS; Law on Digital Assets governs crypto services

Lead regulator
National Bank of Serbia
Also involved
Securities Commission (securities-like assets) · AML Department (AML/CFT)
Core law
Law on Digital Assets (2021)
Entry capital
EUR 20,000 (VASP)
Approval timeline
3-6 months
Customer assets
Separate bank accounts required for user funds
Data protection
Law on Personal Data Protection · Commissioner
Sandbox
No

Serbia operates a comprehensive licensing regime for Virtual Asset Service Providers (VASPs) under the Law on Digital Assets. The National Bank of Serbia (NBS) is the primary supervisor for licensing, supervision, and capital requirements, while the Securities Commission oversees securities-like digital assets. The regulatory framework is mature, requiring strict adherence to AML, capital, and operational standards.

Which licence do you need?

Your activityRequirementCapitalTimelineAuthority
Exchange / trading platformLicenceLicence to provide virtual currency services[1][2][3][4]

Requires separate bank accounts for user funds

EUR 20,0003-6 monthsNational Bank of Serbia
Custody of client assetsLicenceLicence to provide virtual currency services[1][2][4]

Part of VASP licence; strict record-keeping required

EUR 20,0003-6 monthsNational Bank of Serbia
Token issuance / public offeringLicenceLicence to provide virtual currency services[1][5]

White paper requires NBS approval

EUR 20,0003-6 monthsNational Bank of Serbia
Broker-dealer / OTC deskLicenceLicence to provide virtual currency services[1][2]

OTC desks fall under VASP licensing

EUR 20,0003-6 monthsNational Bank of Serbia
Stablecoin issuanceLicenceLicence to provide virtual currency services[1][5]

Treated as virtual currency; white paper approval needed

EUR 20,0003-6 monthsNational Bank of Serbia
Crypto payments acceptanceLicenceLicence to provide virtual currency services[1][6]

Foreign currency payments for crypto must be in EUR

EUR 20,0003-6 monthsNational Bank of Serbia
Mining / staking servicesUnregulatedverify with regulator

Mining not explicitly regulated; staking may be service

———
Advisory / portfolio managementUncertainverify with regulator

Advisory not explicitly listed; check NBS guidance

———

New — what changed recently

  • 2024-01-19Decision on Data Submission — Mandated quarterly data reporting from VASPs to NBS for statistical and supervisory purposes.[7]
  • 2021-10-21Decision on Information-Communication Systems — Established mandatory conditions for safe management of ICT systems by VASPs.[8]
  • 2021-10-18Decision on Prevention of Market Abuse — Regulated prevention of market abuse and disclosure obligations for issuers.[9]

Market-entry checklist

  1. 1Secure NBS VASP LicenceSubmit application with business plan, governance structure, and proof of capital to the National Bank of Serbia.
  2. 2Meet Minimum CapitalMaintain at least EUR 20,000 in minimum capital, calculated and reported per NBS Decision.
  3. 3Open Separate User AccountsEstablish dedicated bank accounts for holding user funds and virtual currencies, separate from company funds.
  4. 4Implement ICT SecurityAdopt comprehensive risk management and security frameworks for information-communication systems as mandated by NBS.
  5. 5Prepare White PaperIf issuing tokens, draft a white paper and obtain prior approval from the National Bank of Serbia.
  6. 6Register in VASP RegisterEnsure inclusion in the official Register of Virtual Currency Service Providers maintained by the NBS.

Sources

  1. Law on Digital Assets of the Republic of Serbia · 2021-05-24
  2. Decision on Implementation of Provisions of the Law on Digital Assets Relating to Issuing of Licence to Provide Virtual Currency Services and Consents of the National Bank of Serbia · 2021-08-09
  3. Decision on the Manner of Calculating the Minimum Capital and Reporting on Minimum Capital of a Virtual Currency Service Provider · 2021-08-09
  4. Decision on the Contents and Form of Records Kept by Virtual Currency Service Providers Holding User Funds · 2021-10-18
  5. Decision on Implementing Provisions of the Law on Digital Assets Regarding the Approval of the White Paper When Issuing Virtual Currencies · 2021-10-21
  6. Decision on Foreign Currency Payments Relating to Digital Asset Transactions · 2021-08-30
  7. Decision on the Content, Deadlines and Manner of Submitting Data on Virtual Currencies to the National Bank of Serbia · 2024-01-19
  8. Decision on Conditions of Information-Communication System Management for Virtual Currency Service Providers · 2021-10-21
  9. Decision on the Prevention of Abuse in the Virtual Currency Market · 2021-10-18
This guide is compiled automatically from 9 primary-source documents published by Serbia's regulators, reviewed by RegAlert, and refreshed monthly (last updated 2026-07-12). It is not legal advice — always confirm requirements with the regulator or local counsel before acting.