Serbia

## Report on Retail_Trading_Status in Serbia

**Date:** 2025-06-26

**Topic:** Retail_Trading_Status

**Description:** Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

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### Retail_Trading_Status: Allowed-Regulated

**Narrative Explanation:**

Individual citizens and residents in Serbia are legally permitted to buy, sell, and hold cryptocurrencies. This activity is regulated under the **Law on Digital Assets**, which came into effect on June 29, 2021. This law established a comprehensive legal framework for digital assets, including cryptocurrencies (referred to as virtual currencies) and digital tokens.

Prior to the enactment of this law, the cryptocurrency space in Serbia operated in a largely unregulated "gray area". The National Bank of Serbia (NBS) had issued warnings regarding the risks associated with cryptocurrency trading but had not outright banned it. The Law on Digital Assets aimed to provide legal certainty, encourage innovation in the blockchain sector, and protect investors. Some sources indicate the law was adopted in 2023 and amended in 2025, however, primary Serbian government sources and legal analyses confirm the initial enactment in late 2020 and entry into force in mid-2021. It's possible these later dates refer to subsequent amendments or full implementation phases.

The regulatory framework designates the **National Bank of Serbia (NBS)** as the supervisory authority for virtual currencies and the **Securities Commission** as the authority for digital tokens. In cases where a digital asset exhibits characteristics of both, both institutions share jurisdiction.

**Key aspects of the regulatory environment include:**

*   **Licensing:** Entities providing services related to digital assets, such as exchanges, wallet providers, and organizers of Initial Coin Offerings (ICOs), must obtain a license from the relevant supervisory body (NBS or Securities Commission). Operating without a license is a criminal offense. Foreign crypto companies can operate in Serbia if they register locally and comply with Serbian law, including obtaining necessary licenses.
*   **KYC/AML Requirements:** The Law on Digital Assets and related anti-money laundering (AML) and counter-terrorism financing (CFT) regulations impose strict Know Your Customer (KYC) and AML/CFT obligations on licensed entities. Transactions exceeding certain thresholds (e.g., €1,000) are subject to AML/CFT compliance reporting. The AML Act was updated in December 2019 to include "virtual currency" and stipulates NBS supervision over entities providing services related to them.
*   **Taxation:** Profits from the sale of cryptocurrencies are subject to a capital gains tax of 15%. The tax is applied to the difference between the selling price and the documented acquisition cost. If the acquisition cost cannot be documented, the tax implications might differ. Inheritance and gift tax may also apply. The transfer and sale of cryptocurrencies are exempt from VAT.
*   **Payment Restrictions:** While cryptocurrencies are recognized as digital property and can be bought, sold, and held as investments, they are not considered legal tender in Serbia. Businesses are prohibited from pricing goods or services directly in cryptocurrencies, and their use for daily payments by individuals is strictly prohibited. The National Bank of Serbia introduced a specific payment code for transactions involving digital assets to improve monitoring.
*   **Consumer Protection and Warnings:** Both the NBS and the Securities Commission have issued warnings to the public regarding the risks associated with investing in crypto-assets, including price volatility, fraud, and lack of information. They advise caution and recommend that transactions be conducted through licensed entities.
*   **Mining:** Cryptocurrency mining is explicitly permitted and is not directly regulated by the Law on Digital Assets, although miners are still subject to other legal obligations, such as tax.

The Serbian government's approach aims to foster innovation within a regulated environment, balancing the potential of blockchain technology with the need to protect the financial system and investors. Challenges remain, including banking barriers for crypto businesses and the slow pace of licensing.

**Relevant Text Excerpts:**

*   **Ministry of Finance of Serbia (2021):** "The Law on Digital Assets, which regulates the field of digital assets and operations in Serbia, entered into force today... By adopting the Law on Digital Assets, we have once again shown that Serbia is keeping pace with the development of IT technologies, with innovations and changes in the digital world, we have become part of the growing segment of the digital economy and a member of the rare club of countries that have comprehensively regulated this area..."
*   **Law on Digital Assets (as per Paragraf Lex):** "This law regulates: 1) the issuance of digital assets and secondary trading of digital assets in the Republic of Serbia... 2) the provision of services related to digital assets... 4) the competence of the Securities Commission... and the National Bank of Serbia; 5) supervision over the implementation of this law." Further, it defines "digital asset, i.e., virtual asset" as "a digital record of value that can be digitally bought, sold, exchanged or transferred and that can be used as a means of exchange or for investment purposes..." and "virtual currency" as "a type of digital asset that is not issued and whose value is not guaranteed by the central bank or other public authority... but is accepted by natural or legal persons as a means of exchange and can be bought, sold, exchanged, transferred and stored electronically."
*   **AInvest (June 2025):** "All trading, possession, and investment in cryptocurrencies are legal under the Law on Digital Assets, but these activities are tightly controlled. Both individuals and businesses can only conduct operations in the crypto space through licensed entities that comply with anti-money laundering and investor protection standards. The use of cryptocurrencies as payment for goods and services is prohibited, as the government considers digital assets to be investment products, not substitutes for the dinar."
*   **CoinStats (June 2025):** "In Serbia, the Law on Digital Assets regulates cryptocurrencies which was adopted in 2023 and amended in 2025... The law recognizes cryptocurrencies as digital assets rather than legal tender... Key Highlights: Legal Status: Its status is as digital property and not a legal tender. Regulatory Body: This is the Securities Commission (main regulator) and National Bank of Serbia (oversight). Licensing: Exchanges, wallets, and ICO organizers must be licensed." *(Note: While this source mentions 2023 adoption and 2025 amendment, other primary and legal sources point to the 2021 entry into force of the main law).*
*   **National Bank of Serbia (February 2025, regarding an unlicensed entity):** "The National Bank of Serbia (NBS) warned citizens about the unauthorized provision of services related to virtual currencies... That business company does not have a license to provide services related to virtual currencies in Serbia... Providing such services without an NBS license is considered... unauthorized and is not permitted by the Law on Digital Assets, and also constitutes a criminal offense in accordance with the criminal law."
*   **Securities Commission (Warning to Investors):** "The Securities Commission... issues this warning in order to alert the public and draw the attention of prospective investors to the risks associated with investing in cryptoassets, such as cryptocurrencies and digital tokens. Namely, a comprehensive system of regulation and oversight of issues and trading in cryptoassets has not been established yet, not just in the Republic of Serbia, but also globally. Therefore, investments in these instruments carry higher risk."
*   **STAV LAW (November 2024):** "The National Bank of Serbia is responsible for supervising virtual currencies, while the Securities Commission of Serbia is responsible for digital tokens... A provider of services related to digital assets in Serbia can offer these services only after obtaining the necessary permit from the competent authority..."
*   **Injac Attorneys (April 2025):** "Digital assets in Serbia are regulated by the Digital Assets Act, which was enacted in December 2020 and came into force on June 29, 2021. This area is also regulated by a series of secondary regulations issued by the National Bank of Serbia (NBS) and the Securities Commission."

**Direct URL Links to Sources:**

1.  **Ministarstvo finansija Republike Srbije (Ministry of Finance of the Republic of Serbia):** [https://www.mfin.gov.rs/sr/vesti/zakon-o-digitalnoj-imovini-danas-stupa-na-snagu](https://www.mfin.gov.rs/sr/vesti/zakon-o-digitalnoj-imovini-danas-stupa-na-snagu)
2.  **Paragraf Lex - Zakon o digitalnoj imovini (Law on Digital Assets):** [https://www.paragraf.rs/propisi/zakon_o_digitalnoj_imovini.html](https://www.paragraf.rs/propisi/zakon_o_digitalnoj_imovini.html)
3.  **AInvest - Serbia Legalizes Crypto Trading With 15% Capital Gains Tax:** [https://www.ainvest.com/news/serbia-legalizes-crypto-trading-with-15-capital-gains-tax-202506191015/](https://www.ainvest.com/news/serbia-legalizes-crypto-trading-with-15-capital-gains-tax-202506191015/)
4.  **CoinStats - Cryptocurrency Regulation in Serbia:** [https://coinstats.app/blog/cryptocurrency-regulation-in-serbia/](https://coinstats.app/blog/cryptocurrency-regulation-in-serbia/)
5.  **Coinfomania - Cryptocurrency Regulation in Serbia:** [https://coinfomania.com/cryptocurrency-regulation-in-serbia/](https://coinfomania.com/cryptocurrency-regulation-in-serbia/)
6.  **Motika & Partners - Zakon o digitalnoj imovini – opšte napomene (Law on Digital Assets - general notes):** [https://motika.rs/zakon-o-digitalnoj-imovini-opste-napomene/](https://motika.rs/zakon-o-digitalnoj-imovini-opste-napomene/)
7.  **Injac Attorneys - Crypto and Digital Assets: Detailed Guide to Legal Regulation (2025):** [https://injacattorneys.com/crypto-and-digital-assets-detailed-guide-to-legal-regulation-2025/](https://injacattorneys.com/crypto-and-digital-assets-detailed-guide-to-legal-regulation-2025/)
8.  **Telegraf Ubrzanje - Upozorenje Narodne banke Srbije u vezi s kriptovalutama (Warning of the National Bank of Serbia regarding cryptocurrencies):** [https://ubrzanje.telegraf.rs/vesti/digitalizacija/3990600-upozorenje-narodne-banke-srbije-u-vezi-s-kriptovalutama-izbegnite-prevaru-posredi-krivicno-delo](https://ubrzanje.telegraf.rs/vesti/digitalizacija/3990600-upozorenje-narodne-banke-srbije-u-vezi-s-kriptovalutama-izbegnite-prevaru-posredi-krivicno-delo)
9.  **Securities Commission - Caution urged for investing in cryptoassets:** [https://www.sec.gov.rs/index.php/en/warnings-en/caution-urged-for-investing-in-cryptoassets-en](https://www.sec.gov.rs/index.php/en/warnings-en/caution-urged-for-investing-in-cryptoassets-en)
10. **STAV LAW - Kripto u Srbiji: Najvažnije o zakonima i porezima (Crypto in Serbia: The most important things about laws and taxes):** [https://stav.law/blog/kripto-u-srbiji-zakoni-i-porezi/](https://stav.law/blog/kripto-u-srbiji-zakoni-i-porezi/)
11. **Nova Ekonomija - Narodna banka uvela šifru za kupovinu bitkoina (National Bank introduced a code for buying bitcoin):** [https://novaekonomija.rs/vesti-iz-zemlje/narodna-banka-uvela-sifru-za-kupovinu-bitkoina-od-sad-bolja-kontrola-transakcija-sa-digitalnom-imovinom](https://novaekonomija.rs/vesti-iz-zemlje/narodna-banka-uvela-sifru-za-kupovinu-bitkoina-od-sad-bolja-kontrola-transakcija-sa-digitalnom-imovinom)
12. **Freeman Law - Serbia & Cryptocurrency:** [https://freemanlaw.com/international-tax/serbia-cryptocurrency/](https://freemanlaw.com/international-tax/serbia-cryptocurrency/)
13. **Zunic Law - Dozvola za kriptovalute (License for cryptocurrencies):** [https://www.zuniclaw.com/sr/dozvola-za-kriptovalute/](https://www.zuniclaw.com/sr/dozvola-za-kriptovalute/)
14. **Pekic Law - Licenses to provide services related to digital assets in Serbia:** [https://pekic-law.com/licenses-to-provide-services-related-to-digital-assets-in-serbia/](https://pekic-law.com/licenses-to-provide-services-related-to-digital-assets-in-serbia/)
15. **Schoenherr Attorneys at Law - Blockchain & Cryptocurrency Regulation (Serbia Chapter):** [https://www.schoenherr.rs/insights/publications/blockchain-cryptocurrency-regulation-2022-serbia-chapter/](https://www.schoenherr.rs/insights/publications/blockchain-cryptocurrency-regulation-2022-serbia-chapter/) (While the main link is to a general page, the search results indicate specific content for Serbia within their publications, likely referencing the AML Act updates)
16. **AiPrise - Navigating KYC, AML, and Identity Verification in Serbia:** [https://www.aiprise.com/blog/navigating-kyc-aml-and-identity-verification-in-serbia](https://www.aiprise.com/blog/navigating-kyc-aml-and-identity-verification-in-serbia)
17. **Kapital RS - Porezi na kriptovalutne derivate u Srbiji (Taxes on cryptocurrency derivatives in Serbia):** [https://kapitalrs.com/blog/srb/porezi-na-kriptovalutne-derivate-u-srbiji-sta-su-i-kako-ih-platiti-2025/](https://kapitalrs.com/blog/srb/porezi-na-kriptovalutne-derivate-u-srbiji-sta-su-i-kako-ih-platiti-2025/)
18. **ECD - Kako platiti porez na kriptovalute u Srbiji (How to pay tax on cryptocurrencies in Serbia):** [https://ecd.rs/blog/kako-platiti-porez-na-kriptovalute-u-srbiji](https://ecd.rs/blog/kako-platiti-porez-na-kriptovalute-u-srbiji)
19. **Nova Ekonomija - Kako platiti porez na kriptovalute – Sve što treba da znate (How to pay tax on cryptocurrencies - Everything you need to know):** [https://novaekonomija.rs/finansijski-vodic/kako-platiti-porez-na-kriptovalute-sve-sto-treba-da-znate](https://novaekonomija.rs/finansijski-vodic/kako-platiti-porez-na-kriptovalute-sve-sto-treba-da-znate)
20. **B92 - NBS upozorava: Ova menjačnica radi neovlašćeno (NBS warns: This exchange office operates without authorization):** [https://www.b92.net/biz/vesti/srbija/nbs-upozorava-ova-menjacnica-radi-neovlasceno-2601002](https://www.b92.net/biz/vesti/srbija/nbs-upozorava-ova-menjacnica-radi-neovlasceno-2601002)
21. **N1 Info - NBS upozorava na neovlašćeno poslovanje bosanske menjačnice kriptovaluta u Srbiji (NBS warns of unauthorized operations of a Bosnian cryptocurrency exchange in Serbia):** [https://n1info.rs/biznis/nbs-upozorava-na-neovlasceno-poslovanje-bosanske-menjacnice-kriptovaluta-u-srbiji/](https://n1info.rs/biznis/nbs-upozorava-na-neovlasceno-poslovanje-bosanske-menjacnice-kriptovaluta-u-srbiji/)
22. **JPM & Partners - Serbia is Step Closer Towards Regulating Blockchain Technology and Cryptocurrencies:** [https://jpm.rs/news/serbia-is-step-closer-towards-regulating-blockchain-technology-and-cryptocurrencies/](https://jpm.rs/news/serbia-is-step-closer-towards-regulating-blockchain-technology-and-cryptocurrencies/)
23. **Pekic Law - Cryptocurrency Regulation, Ownership, and Trading in Serbia:** [https://pekic-law.com/cryptocurrency-regulation-ownership-and-trading-in-serbia/](https://pekic-law.com/cryptocurrency-regulation-ownership-and-trading-in-serbia/)