🇷🇸Serbia

Detailed overview

Serbia at a glance

Serbia (population approximately 6.6M) is an EU candidate country with one of the more mature crypto-licensing frameworks in the wider European region. The Law on Digital Assets in force from 29 December 2020 (applied from 29 June 2021) is among the earliest comprehensive crypto-licensing regimes in Europe, predating the EU's MiCA framework. The law is administered jointly by the National Bank of Serbia (NBS) for virtual currencies and the Securities Commission for digital tokens, with a unified web portal for applications. Operating without a permit is a criminal offence under the Serbian Criminal Code.

The Law on Games of Chance of 2020 (applied from April 2020) was substantially amended at the end of 2024 (applied from January 2025), introducing e-licensing, real-time data exchange with the Games of Chance Administration's "Mirror Server", a national player self-exclusion registry, explicit online fee structures, and stricter venue location rules (200 metre minimum distance from schools as of early 2026). The casino licence framework is capped at 10 nationwide licences.

Last verified: May 2026. Reference rate: EUR 1 = USD 1.17.

Serbia offers a clear non-EU licensing route for crypto and gambling, with low capital thresholds and a regulator-modernised online gambling regime. The licence does not confer MiCA passporting.

Is there a crypto licence in Serbia?

Yes. The Law on Digital Assets in force from 29 December 2020 (applied 29 June 2021) requires all digital-asset service providers to obtain a permit from the NBS (for virtual currencies) or the Securities Commission (for digital tokens / financial-instrument digital assets), or both for hybrid assets.

The legal framework is layered:

• Law on Digital Assets (RS Official Gazette No 153/2020): in force 29 December 2020, applied from 29 June 2021.
• Secondary legislation: NBS bylaws on virtual-currency services; Securities Commission bylaws on digital-token services.
• Unified web portal: single submission point for both regulators; documents submitted once and shared between authorities.
• Tax framework: Capital gains tax 15% on disposal of digital assets; corporate income tax framework as amended in 2021. VAT exemption applies to virtual currency transactions; VAT (20%) applies to digital tokens that are not exempt as virtual currencies.

Categories of regulated services (under the Law on Digital Assets):

• 1. Receipt, transfer and execution of orders related to the purchase and sale of digital assets on behalf of third parties
• 2. Trading services in digital assets in own name and for own account
• 3. Trading services in digital assets in own name and for the account of a third party
• 4. Reception and transmission of orders related to digital assets
• 5. Custody and administration of digital assets and related services
• 6. Services related to the issuance and offering of digital assets and ancillary services
• 7. Maintaining a register of pledges
• 8. Managing the platform for trading digital assets
• 9. Portfolio management of digital assets

Note: financial institutions supervised by the NBS (banks, insurers, financial leasing companies, voluntary pension fund management companies, payment institutions) are prohibited from holding digital assets in their balance sheets, providing digital-asset services, or being users of such services. This carve-out preserves the boundary between traditional finance and the digital-asset perimeter.

Digital Asset Service Provider Permit – Virtual Currencies (NBS)

Best for crypto exchanges, custodians, brokers and OTC desks dealing with virtual currencies.

What it is: Permit issued by the National Bank of Serbia under the Law on Digital Assets authorising provision of one or more services related to virtual currencies (cryptocurrencies).

Who it suits: Crypto exchanges, fiat-to-crypto and crypto-to-crypto trading platforms, custody providers, brokers, OTC desks, and order-execution platforms dealing in virtual currencies.

Covers: Services 1–9 above to the extent they relate to virtual currencies, as defined under the Law on Digital Assets.

Operational requirement: Serbian legal entity registered with the Serbian Business Registers Agency (legal-person status required — natural persons cannot hold the permit). Physical office in Serbia. Compliance with capital, governance, fit-and-proper, and IT security requirements. AML/CFT compliance under Serbia's Law on the Prevention of Money Laundering and Financing of Terrorism (DASPs are obliged entities). Segregation of client assets from operator's own holdings. AML/KYC and CDD/EDD framework. White paper required for digital-asset issuances.

Service-by-service capital requirements:

• Services 1–6: EUR 20,000 (about USD 23,400) minimum founding capital
• Services 7–8 (pledge register, trading platform): EUR 50,000 (about USD 58,500)
• Service 9 (portfolio management): EUR 125,000 (about USD 146,000)

Headline figures

• Decision timeline: 60 days from receipt of duly completed application
• Application portal: unified web portal (one submission for NBS + Securities Commission if applicable)
• Rejected application waiting period: 1 year before reapplication
• Minimum founding capital (services 1–6): EUR 20,000 (about USD 23,400)
• Minimum founding capital (services 7–8): EUR 50,000 (about USD 58,500)
• Minimum founding capital (service 9): EUR 125,000 (about USD 146,000)
• Capital gains tax (legal entities): 15%
• VAT on virtual currency transactions: exempt
• VAT on digital tokens (general): 20%
• Threshold for whitepaper-free token issuance: EUR 3 million in any 12-month period (subject to non-share characteristics)

Digital Asset Service Provider Permit – Digital Tokens (Securities Commission)

Best for token issuers and platforms dealing in digital tokens or financial-instrument digital assets.

What it is: Permit issued by the Securities Commission of Serbia under the Law on Digital Assets authorising services in respect of digital tokens and digital assets that have financial-instrument characteristics.

Who it suits: Token issuers, security token platforms, tokenisation projects, ICO and STO operators, and any operator dealing in digital tokens (rather than virtual currencies). If both virtual currencies and tokens are covered, both NBS and Securities Commission are involved.

Covers: Services 1–9 to the extent they relate to digital tokens. Issuance of digital tokens under the Law on Digital Assets (as opposed to the Capital Market Act) is available where the digital token (a) does not have the characteristics of shares and (b) the total value of digital assets issued by one issuer during 12 months does not exceed EUR 3 million (about USD 3.51 million).

Operational requirement: Same general framework as the NBS permit – Serbian legal entity, physical office, fit and proper directors and shareholders, AML/CFT compliance, segregation of client assets, IT security and cybersecurity standards. Whitepaper requirement applies to public digital-asset issuances.

Headline figures

• Threshold for issuance under the Law on Digital Assets (not Capital Market Act): EUR 3 million (about USD 3.51 million) per issuer over 12 months
• Decision timeline: 60 days from receipt of duly completed application
• Joint NBS + Securities Commission process: required where digital assets have characteristics of both virtual currencies and digital tokens

Tax position for digital assets

• Capital gains tax (legal entities): 15% on the difference between acquisition and selling price of digital assets
• Capital gains tax (individuals): 15% (subject to specific holding-period rules)
• VAT (virtual currencies): exempt
• VAT (digital tokens, default): 20% standard rate, with case-by-case classification
• Corporate income tax (general): 15% on profits
• In-kind capital contributions in digital tokens: permitted into companies (excluding tokens linked to services or work) under specific rules; the Securities Commission maintains a list of eligible tokens
• Mining: mining of digital assets by individuals is outside the scope of the Law on Digital Assets and is permitted; individuals are free to dispose of digital assets acquired through mining

Is there a payments licence in Serbia?

Yes. The National Bank of Serbia regulates payment services under the Law on Payment Services. The carve-out preventing financial institutions from holding digital assets means crypto and payments are kept structurally separate.

For traditional payments (account servicing, e-money, money remittance and acquiring), the NBS administers the Law on Payment Services. Article 28 of the Law on Digital Assets confirms that the payment of digital assets in funds is made in accordance with the Law on Payment Services. The Law on Payment Services regulates payment service providers, payment institutions and e-money institutions, with the NBS as supervisor. We work on payment-specific authorisations on a case-by-case basis. The strict carve-out in the Law on Digital Assets means a payment institution cannot also hold a DASP permit — businesses combining payment and crypto services must structure these in separate entities.

Is there a gambling licence in Serbia?

Yes. The Games of Chance Administration (GCA), within the Ministry of Finance, regulates all forms of gambling under the Law on Games of Chance (2020), as amended in 2024 (applied from January 2025).

The Law on Games of Chance was modernised in 2020 (Official Gazette 18/20) and substantially amended in late 2024, applied from January 2025. Key elements of the regime:

• Casino licences (10 nationwide maximum): granted by the Government, not the Administration. Each licence covers one casino.
• Slot machines and betting: granted by way of approval issued by the Administration.
• Online (electronic communication) games: granted by the Administration; real-time mirror-server data exchange mandatory since the 2024 amendments.
• Classic games of chance via electronic means: exclusively the National Lottery of Serbia.
• 2025 venue distance rule: betting shops and casinos must be at least 200 metres from schools (early 2026 enforcement).
• Self-exclusion: national registry distributed across all operators since 2025 amendments.
• AML/CFT: gambling operators are obliged entities under the Law on the Prevention of Money Laundering and Financing of Terrorism.
• Operating-hours limits: maximum 18 hours per day for betting shops and slot clubs.
• Audio-video surveillance: continuous monitoring required for casinos, with recordings kept for typically 12 months.
• Staff restrictions: gambling operator employees cannot participate in games organised by their employer; staff must be adults trained in responsible gambling.
• Alcohol restriction: alcohol with more than 5% content prohibited; alcohol prohibited for active gamblers at sports or slot-machine venues.

Casino Licence (Government)

Best for hotel-integrated land-based casino operators (limited to 10 nationwide).

What it is: Licence granted by the Government of Serbia under the Law on Games of Chance for special games of chance in casinos. The Government issues a maximum of 10 casino licences nationwide; each licence covers one casino.

Who it suits: Established casino groups with a track record of at least 5 years in operating casinos elsewhere; the legal entity (or its majority founder) must have participation in at least one casino and have organised casino games for at least 5 years.

Covers: Casino table games and slot machines at the licensed venue. Slot operations within a casino fall under the casino licence (no separate slot approval needed).

Operational requirement: Serbian-registered legal entity with gambling and betting as the primary registered activity. Track-record requirement: 5 years of casino operation by the legal entity or its majority founder. Government licence procedure with Ministry of Finance involvement. Continuous audio-video surveillance with 12-month retention. Real-time monitoring link to the Games of Chance Administration. AML/CFT compliance. Responsible gambling framework, employee training, on-premises addiction-warning signage.

Headline figures

• Minimum public-call offer (2025): EUR 1 million (about USD 1.17 million) — raised from EUR 500,000 (about USD 585,000) in the 2025 amendments
• Financial guarantee: at least EUR 300,000 (about USD 351,000) in RSD equivalent
• Maximum nationwide casino licences: 10
• Track-record requirement: 5 years of casino operations
• Surveillance retention: typically 12 months

Slot Machine Approval

Best for slot operators in licensed clubs and venues.

What it is: Approval issued by the Games of Chance Administration for special games of chance on automatic equipment (slot machines).

Who it suits: Slot-club operators wanting to run land-based slot venues across Serbia.

Covers: Slot machines at the licensed venues, subject to operational rules under the Law on Games of Chance.

Operational requirement: Serbian-registered legal entity or entrepreneur. AML/CFT compliance. Real-time monitoring link to the Administration. Maximum 18-hour daily operating window. Slot machines must be at least 200 metres from schools (early 2026 enforcement under the 2025 amendments).

Headline figures

• Slot machine GGR-base tax: 15% on the difference between total wagers and total winnings
• Operating hours: maximum 18 hours per day

Betting Shop Approval (Sports Betting)

Best for sports-betting operators (land-based and online via tied authorisation).

What it is: Approval issued by the Games of Chance Administration under the Law on Games of Chance for special games of chance involving betting.

Who it suits: Sports betting operators, totalisators, and operators offering bets on real and virtual events.

Covers: Sports betting on real upcoming events (sports and virtual sports). Land-based betting shops. Online sports betting through tied authorisation under the electronic-communication framework.

Operational requirement: Serbian-registered legal entity. AML/CFT compliance. Real-time monitoring link. Self-exclusion data exchange. Maximum 18 operating hours per day. 200-metre minimum distance from schools (2026).

Headline figures

• Minimum monthly fee per betting shop: EUR 1,000 (about USD 1,170) in RSD equivalent
• GGR-base fee (sports betting): 15% on the difference between total wagers and total winnings
• Operating hours: maximum 18 hours per day

Online (Electronic Communication) Gambling Approval

Best for online casino, online sports-betting, online slot, bingo and remote game operators.

What it is: Approval issued by the Games of Chance Administration for organising games of chance via electronic communication. Updated framework under the 2024 amendments applied from January 2025.

Who it suits: Online gambling operators (casino, slots, sports betting, bingo) with a Serbian-licensed presence and a Mirror Server in Serbia.

Covers: Online casino games, online slots, online sports betting, online bingo, and remote gaming via terminals, text messaging and internet. Classic games of chance (traditional lottery) via electronic communication are reserved to the National Lottery of Serbia.

Operational requirement: Serbian-registered legal entity. Access to the licensee's databases or a Mirror Server with replication data, located within the territory of Serbia, available to the Administration. Compliance with EU and international standards (post-2024 alignment). Monthly e-filing returns by the 5th of each month. Self-exclusion data exchange with all operators. AML/CFT compliance, staff training in problem-gambling prevention, advertising warnings.

Headline figures

• Monthly approval fee: EUR 10,000 (about USD 11,700) in RSD equivalent
• GGR-base fee (online sports betting): 15%
• GGR-base fee (other special online games, including online casino): 10%
• Minimum monthly payment: EUR 10,000 (about USD 11,700)
• Mirror Server requirement: Serbian territory, real-time data exchange
• Filing date: monthly returns by 5th of the month

Classic Games of Chance (Lottery)

State monopoly held by the National Lottery of Serbia (Državna Lutrija Srbije).

Classic games of chance (traditional, instant, and electronic lotteries) are organised exclusively by the National Lottery of Serbia. The right to organise classic games via electronic communication is reserved to the National Lottery without separate approval. Private operators cannot apply.

Costs and timelines at a glance

• DASP minimum capital (services 1–6): EUR 20,000 (about USD 23,400)
• DASP minimum capital (services 7–8): EUR 50,000 (about USD 58,500)
• DASP minimum capital (service 9 – portfolio management): EUR 125,000 (about USD 146,000)
• DASP decision timeline: 60 days from complete application
• DASP rejected-application cooling-off period: 1 year
• Token issuance ceiling under Law on Digital Assets (not Capital Market Act): EUR 3 million (about USD 3.51 million) over 12 months per issuer
• Capital gains tax on digital assets: 15%
• VAT on virtual currencies: exempt
• VAT on digital tokens (default): 20%
• Casino licence (public call minimum, 2025): EUR 1 million (about USD 1.17 million)
• Casino financial guarantee: at least EUR 300,000 (about USD 351,000)
• Maximum casino licences nationwide: 10
• Online gambling monthly approval fee: EUR 10,000 (about USD 11,700)
• GGR-base fee (online sports betting): 15%
• GGR-base fee (online casino): 10%
• Betting shop minimum monthly fee: EUR 1,000 (about USD 1,170)
• Slot machine GGR-base fee: 15%
• Operating-hours cap (betting shops and slot clubs): 18 hours per day
• Minimum distance from schools: 200 metres (from early 2026)
• Mirror Server: mandatory in Serbia for all online gambling licensees

Who Serbia suits and who it does not

Suitable for

• Crypto exchanges, custodians, brokers and OTC desks targeting the Balkans / Eastern European market with a clear regulator (NBS) and EUR-denominated capital floors as low as EUR 20,000 for first six services
• Token issuers and STO/ICO operators able to use the Securities Commission permit and benefit from the EUR 3 million 12-month issuance ceiling exempting them from the Capital Market Act
• Multi-product crypto operators (combined virtual currency + digital token services) benefiting from the unified web portal and shared documentation between NBS and Securities Commission
• Online gambling operators (casino, slots, sports betting) willing to accept Mirror Server hosting in Serbia and monthly EUR 10,000 fee structure
• Sports betting operators with a Serbian retail footprint and ability to manage the 18-hour daily operating cap, 200-metre school distance rule, and AML/CFT obligations
• Established casino groups with 5+ years of casino operating history willing to compete for one of 10 nationwide casino licences via Government public call
• Tokenisation and DLT-based platforms benefiting from Serbia's technologically-neutral framework
• Operators looking for an EU-candidate jurisdiction with a fully implemented digital-asset framework predating MiCA

Not suitable for

• Operators seeking EU MiCA passporting rights — Serbia is not an EU/EEA member and the NBS/Securities Commission permit does not confer MiCA passporting
• Financial institutions supervised by the NBS (banks, insurers, leasing companies, voluntary pension funds, payment institutions) — these are prohibited from holding digital assets, providing digital-asset services or being users of such services
• Crypto operators wanting to combine payment-services and digital-asset services in one entity — the carve-out requires separate legal entities
• Online casino operators unable to host a Mirror Server in Serbia or maintain real-time data exchange with the Administration
• New entrants wanting a quick casino licence — only 10 nationwide casino licences exist and the 5-year casino track-record requirement excludes new operators
• Betting operators serving Serbian residents without a Serbian-licensed operator (the regulator monitors and blocks unauthorised operators; criminal penalties apply)
• Crypto businesses unwilling to register a Serbian legal entity with a physical office (no virtual office permitted)
• Operators expecting to combine alcohol service with gambling beyond the 5% strength threshold (prohibited under the 2025 rules)
• Token issuers planning offerings of more than EUR 3 million in 12 months without going through the full Capital Market Act regime
• Lottery operators — classic games of chance are a state monopoly held by the National Lottery of Serbia