Serbia is not the only Western Balkan country where crypto business is discussed, but it is the country where the discussion is about a real licensing regime: the National Bank of Serbia (NBS) has been issuing licences for virtual-currency services since 2021, and compared with the record-based models of its neighbours this is a full licensing system. That contrast shapes this page: where some countries in the region sell what is merely an entry in a list under the name of a "licence", in Serbia a licence is a licence — granted by decision, with conditions and with ongoing supervision.
We tell you honestly, up front, what is not in our official material: the licence fee amount and the statutory processing time are not fixed in the sources this page is built on — both are to be confirmed with the regulator, and we do not print unofficial numbers. Nor do we invent capital thresholds. What is confirmed — the legal basis, the shape of the process, the logic of NBS screening and the public register — is detailed below.
The Legal Basis: the Digital Assets Law and the NBS Decision
The regime rests on two acts: the Law on Digital Assets (Serbian Official Gazette 153/2020) and the NBS Decision on issuing the licence for virtual-currency services (Official Gazette 49/2021). On this basis the NBS issues a licence (dozvola) for services connected with virtual currencies. An important boundary exists as well: services around digital tokens that are not virtual currency fall to the Serbian Securities Commission — so the exact classification of your business model decides which regulator your route runs to, and that classification is the first item of analysis.
The Licensing Process and What the NBS Checks
The NBS regime works along three tracks. First, the licence itself for virtual-currency services: the application goes to the NBS and must be granted before the service starts. Second, consents for people: the NBS issues consents for the appointment of management members and directors, and also for acquirers of a qualifying holding — meaning that even a change of shareholders stays under the regulator's control. Third, the functional analysis: the licence is tied to what service you will actually provide and into which category the business falls.
The assessment logic carries a pronounced AML filter: the NBS requires and screens the origins of the application — where the capital comes from and what provenance the funds have; any trace of offshore or high-risk countries in the application raises a separate flag. For a Georgian-owned group this means the documentation of sources — bank references, salary or sale history, the structure of the group — must be in order before filing; otherwise exactly this block becomes the main risk to timelines and to the outcome. As for the fee and the calendar, both are to be confirmed with the regulator, and in each case we establish the current terms directly with the NBS before filing.
The Register and Transparency on nbs.rs
The main instrument of the Serbian regime's openness is the NBS public register: the register of providers of services connected with virtual currencies and the decisions granting licences are published on nbs.rs. This gives you two opportunities: to verify from the other side the status of your future partner or counterparty, and to see what kind of companies actually receive licences. Before any filing we always refresh our working picture against that list — it is the starting point for what the NBS expects, on the example of real market participants.
The Georgian Layer: What Applies at Home Despite a Serbian Licence
A Serbian licence is for Serbia and for business oriented to its market; it does not change what applies in Georgia. The organic law on the National Bank of Georgia (No 101044): Article 52-5(2) — a virtual asset service provider registers with the National Bank; Article 52-5(3) — providing services while unregistered is impermissible; Article 52-5(4) — a provider carries on only that activity and auxiliary activity; Article 39-1 — a virtual asset is not legal tender and payments in it are prohibited; Article 48 — supervision belongs to the National Bank.
The AML law (No 4690334): Article 3(1) makes VASPs accountable persons; Article 4 assigns AML supervision to the National Bank; Article 11(1) sets the crypto KYC trigger for an occasional transaction at USD 1 000 / EUR 1 000 / GEL 3 000; Article 17¹ imposes the Travel Rule, with the accompanying-information content set by a National Bank act (Article 52-5(1) of the organic law). A Serbian licence does not cancel this layer — it recognises you on the Serbian market, while registration remains mandatory on the Georgian market.
Frequently Asked Questions
How much does the Serbian licence cost?
The amount is not published in our official material — it is to be confirmed with the regulator. We verify the current terms with the NBS before filing; we do not print unofficial figures.
How long does the Serbian licence take?
The statutory processing time is not fixed in our material — that detail is to be confirmed with the regulator. The shape of the process is known: application, consents for people and shareholders, AML screening of sources.
How does Serbia differ from the neighbouring registration models?
By issuing a genuine licence since 2021 — by decision, with conditions and subsequent supervision. Where neighbours run a general record entry, Serbia builds a full regime with licensing requirements.
Does a Serbian licence change Georgian requirements?
No. Services directed at Georgia still require registration with the National Bank under Article 52-5(2), and the KYC trigger (USD 1 000 / EUR 1 000 / GEL 3 000) and the Travel Rule remain part of the Georgian AML layer.
How We Help on Legal.ge
Legal.ge builds the Serbian route step by step: first we fix the classification of your business model — virtual-currency service or digital-token territory, which chooses between the NBS and the Securities Commission; then we set up the Serbian legal entity, prepare the application with complete documentation of sources — the AML filter bites exactly there — and run the consent cycle for management and shareholders. The fee and the timelines we verify with the NBS before filing. In parallel we build the Georgian ring — National Bank registration and AML compliance. Contact us — let us start the Serbian route with your list of services.