Regulatory AlertsSerbia: lending & credit regulation
Partially regulatedSerbia: NBS regulates banks/lessors; non-bank lending unregulated but restricted
- Lead regulator
- National Bank of Serbia (NBS)
- Also involved
- Ministry of Finance (tax) · AML Supervision Office
- Core law
- Law on Banks (2016)
- Entry capital
- EUR 30m (Bank)
- Approval timeline
- 6-12 months (Bank license)
- Customer assets
- Segregated per Law on Banks
- Data protection
- Law on Personal Data Protection · RPAP
- Sandbox
- No
The National Bank of Serbia (NBS) exclusively regulates credit granting by banks and financial lessors. Non-bank entities (including fintechs) are not licensed for lending under current NBS frameworks, rendering the activity effectively prohibited or unregulated for non-licensed players. Recent NBS decisions heavily restrict consumer credit terms (caps, forbearance) and foreign currency exposure.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Consumer lending | LicenceBanking License[1][2] Non-banks cannot legally lend to consumers. | EUR 30m | 6-12 months | National Bank of Serbia |
| SME / commercial lending | LicenceBanking License[3] Commercial lending restricted to licensed banks. | EUR 30m | 6-12 months | National Bank of Serbia |
| Microfinance | Uncertainverify with regulator No specific microfinance license exists. | — | — | — |
| Buy-now-pay-later | Uncertainverify with regulator Unclear if BNPL constitutes lending. | — | — | — |
| P2P lending platform | Prohibited Non-bank lending is not licensed. | — | — | — |
| Credit bureau / scoring | Unregulated Scoring is a tool, not a licensed activity. | — | — | — |
| Debt collection | Uncertainverify with regulator Regulation of third-party collectors is unclear. | — | — | — |
New — what changed recently
- 2025-09-19Decision on Loan Repayment Relief — Mandates lenders to provide forbearance measures to consumers in financial hardship.[1]
- 2024-12-25Decision on Temporary Interest Rate Cap — Imposes caps on variable rates (14.75% RSD, 7.05% EUR) for consumer loans.[2]
- 2024-12-30Decision on Measures for Safeguarding Stability — Restricts FX loans to natural persons and mandates 30% downpayment for indexed loans.[4]
Market-entry checklist
- 1Secure Banking LicenseObtain NBS license with EUR 30m capital to lend legally.
- 2Comply with Rate CapsAdhere to NBS temporary caps on variable interest rates.
- 3Implement ForbearanceEstablish protocols for loan relief per NBS Decision.
- 4Manage FX ExposureRestrict FX lending to natural persons and ensure downpayments.
Sources
- Decision on Loan Repayment Relief · 2025-09-19
- Decision on Temporary Interest Rate Cap on Loan Agreements Concluded with Natural Person Consumers · 2024-12-25
- Decision on the Classification of Bank Balance Sheet Assets and Off-balance Sheet Items · 2025-08-22
- Decision on Measures for Safeguarding and Strengthening Stability of the Financial System · 2024-12-30