SERBIA Trends and Developments Contributed by: Željka Motika, Ivana Bulatović and Jovana Spasojević Gligorijević, Motika i partneri
– is the possibility to issue digital tokens with char - acteristics of financial instruments. This differs sig - nificantly from MiCA, which excludes security tokens and instead subjects them to general capital markets legislation. Serbian law allows the issuance of such securi - ty tokens provided that the total value issued by a single issuer does not exceed EUR3 million within a 12‑month period. Issuances below this threshold fall outside traditional capital markets rules, and the tokens are recorded on blockchain or other distributed ledger technology (DLT). These security tokens may be offered, purchased, and traded directly between issuers and investors, without licensed intermediaries. This model has become the most common form of digital token issuance in Ser - bia, especially among start‑ups, as it enables flexible fundraising while avoiding the complexity and cost of traditional capital markets regulation. Notably, the Serbian framework does not impose restrictions on issuers or on the categories of inves - tors. Both domestic and foreign investors may invest in digital tokens, contributing to the model’s attrac - tiveness for early‑stage companies. In practice, the Securities Commission has taken a supportive and pragmatic approach to supervising token issuances and has actively contributed to the growth of this seg - ment. Virtual currencies Serbia’s approach to virtual currencies differs consid - erably from the regime applicable to digital tokens. Currently, there are no virtual currencies issued in Ser - bia, and the National Bank of Serbia (NBS) has not expressed institutional support for this type of digital asset. Under Serbian law, virtual currencies are not recog - nised as legal tender or as means of payment. They are defined as digital assets not issued or guaranteed by the central bank or other public authorities, not necessarily linked to legal tender, and lacking the legal status of money. Nevertheless, they may be accepted as a means of exchange and can be bought, sold, transferred, and stored electronically.
Although the liberal issuance regime has been effec - tive for security tokens, it has not yielded similar results for virtual currencies. Unlike MiCA – which introduces a detailed regulatory regime for stablecoins, including EMTs and ARTs – Serbia lacks clear requirements for stablecoin issuers, hindering the development of this segment. The NBS has reinforced its conservative stance through public statements, most recently in 2025, advising citizens against investing in or transacting with virtual currencies, citing price volatility and the absence of central‑bank backing. As the issuance of electronic money in Serbia is a licensed activity reserved for entities established in Serbia and subject to strict requirements – and since fiat‑linked stablecoins are functionally comparable to electronic money – it is unlikely that the NBS would permit the issuance of stablecoins by unlicensed enti - ties. Additionally, because institutions supervised by the NBS are prohibited from engaging in activities related to digital assets, the issuance of e‑money‑type sta - blecoins is effectively blocked until regulatory reforms are introduced. Digital asset service providers Unlike issuers, digital asset service providers (DASPs) must be licensed. These services may be provided only by Serbian‑incorporated legal entities that obtain the appropriate licence from the relevant supervisory authority. The regulatory framework for DASPs largely mirrors the rules applicable to traditional financial institutions. Consequently, providers are subject to extensive organisational, compliance, and risk‑management obligations. One significant obstacle to market growth is the inability to conduct fully remote KYC procedures for non‑resident clients, which severely limits cross‑bor - der onboarding and scalability. Further, because the NBS maintains that digital assets do not constitute means of payment, no provider has
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