🎉 Serbia 🇷🇸 introduces amendments to the PSA to implement Open Banking services

🎉 Serbia 🇷🇸 introduces amendments to the PSA to implement Open Banking services

On May 6, 2025, amendments to the "Payment Services Act" (PSA), approved by the parliament, will come into effect. These amendments include exemptions from licensing requirements for cross-border operations.

➡️ Good news‼️— Although the PSA does NOT require foreign e-money issuers (EMI) to obtain a license to process cross-border payments from Serbian residents, they must register with the National Bank of Serbia (NBS). Failure to notify the regulator will result in penalties.

➡️ Who will this affect❓

• Foreign e-money issuers already registered with the NBS, which currently provide limited payment services to Serbian residents.
• Companies that do not hold a license or are not registered with the NBS but engage in activities exempt from PSA requirements.
• Companies interested in offering account information services (AIS) and payment initiation services (PIS), which were previously unregulated by the PSA.
• Licensed PSP providers, who will need to adjust their statutes to comply with the new requirements before February 2025.
• Fintech startups that want to test their business model without incurring significant costs.

➡️ The new regulations require already registered EMIs to update the information provided to the NBS with an email address, which these EMIs will use to exchange notifications with the NBS.

➡️ The amended PSA stipulates that the NBS will cancel the EMI registration (or deny registration) if it finds that the company's activities are associated with money laundering or terrorism financing.

⚠️Exclusions from PSA activities:

• Direct cash payments between payer and payee.
• Checks and paper documents.
• Cash transportation (such as cash delivery by security companies).
• Payment services related to the management of assets in the form of securities.
• Technical service providers.
• Independent ATM operators (now required to inform customers about any fees for foreign currency conversion or cash withdrawal).

➡️ The modified PSA agreement and its licensing requirements do NOT apply to "payment operations conducted through a commercial agent authorized to negotiate or conclude purchase agreements for goods or services on behalf of only the payer or only the payee."

➡️ The amended PSA introduces new regulated services: provision of account information (AIS) and payment initiation (PIS). The need for an AIS license will depend on whether the provider has access to the payment account and if the information has been consolidated in any way. PIS providers will require authorization from the NBS under the same conditions as payment institutions.

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