Serbia’s central bank has introduced stricter identification and compliance requirements for foreign individuals and non-resident companies holding bank accounts in the country, empowering commercial banks to impose temporary restrictions on accounts and transactions if clients fail to provide updated documentation within prescribed deadlines.
The amendments, adopted by the National Bank of Serbia (NBS), strengthen customer identification obligations for both dinar and foreign-currency accounts held by non-residents. Under the revised framework, banks must periodically update documentation for existing foreign clients, verify permanent identification data more thoroughly and, where necessary, suspend access to banking services until the required documents have been submitted and approved.
The measures do not authorize the confiscation of funds or automatic account closure. Instead, they introduce a reversible compliance restriction that may temporarily block access to banking products, services and payment transactions linked to an account. Once the required documentation is accepted, banks must restore access.
Six-Month Compliance Review for Existing Clients
The new rules primarily affect existing non-resident customers. Following the amendments’ entry into force, Serbian banks will have six months to collect the newly required documentation from foreign companies and individuals already maintaining accounts in the country.
Before applying any restriction, a bank must issue a written request specifying the required documents, provide an appropriate deadline for submission and notify the client of the consequences of non-compliance. If the client fails to respond within the allotted period, the bank may partially or completely restrict the use of account-related services.
Restrictions may apply not only to banking products but also to transactions initiated by or made in favor of the client. As a result, temporary compliance blocks could disrupt salary payments, supplier settlements, tax payments, dividend transfers, property transactions and other commercial obligations, even though deposited funds remain in the account. The revised framework has particular operational significance for foreign-owned businesses that rely on Serbian bank accounts for recurring payments or as part of broader regional treasury arrangements.
Additional Documentation Required for Foreign Companies
Foreign corporate account holders will be required to provide an official extract from the company register in their country of incorporation showing the business registration number or another permanent identification code. Where such a register does not exist or does not contain the required information, companies must submit alternative incorporation or constitutional documents enabling the bank to verify the entity’s legal form, incorporation date and permanent identification details.
The amendments increase compliance obligations for companies operating through cross-border ownership structures. Serbian subsidiaries owned by foreign holding companies, representative offices, project companies, international contractors and businesses maintaining Serbian accounts without establishing local operating subsidiaries may all need to ensure that documentation relating to foreign parent entities remains current and sufficiently detailed.
Depending on the issuing jurisdiction and a bank’s internal compliance procedures, foreign documents may also require translation, certification or other forms of authentication. Institutions may request additional evidence where submitted documentation does not clearly establish a client’s legal identity, corporate status or ownership chain.
The requirements are especially relevant for special-purpose vehicles (SPVs) involved in property, infrastructure, energy and investment projects, where Serbian bank accounts are frequently used for equity contributions, shareholder loans, construction payments, tax obligations and operating expenses. Even temporary payment interruptions could affect contractual deadlines or financing arrangements.
Expanded Identification Standards for Foreign Individuals
The amendments also introduce more detailed identification requirements for foreign citizens opening bank accounts. Serbian nationals must provide their name, residential or temporary address and Unique Master Citizen Number (JMBG). Foreign nationals must submit their name, address, foreigner registration number where available, passport number and an identification number issued by their home country when applicable.
When opening an account, foreign individuals must present a valid passport together with evidence of their residence or temporary residence during the previous 12 months, as well as their home-country identification number where one exists.
For individuals living across multiple jurisdictions, proving residential history may become the most demanding aspect of the process. Banks may request residence certificates, utility bills, tax residency documentation, tenancy agreements or other supporting evidence in accordance with their internal compliance procedures.
Banks Retain Discretion Over Verification Procedures
Implementation is expected to vary across Serbia’s banking sector because the National Bank of Serbia establishes minimum regulatory standards while individual commercial banks continue applying their own risk classifications, document verification procedures and compliance controls. Documentation accepted by one institution may require additional supporting evidence at another, particularly when dealing with jurisdictions that maintain different corporate registration systems or have limited access to public records.
The amendments also highlight the distinction between nationality, immigration status, tax residence and foreign-exchange residence. These classifications may result in different documentation requirements for foreign citizens residing and working in Serbia, non-residents who own property or businesses in the country, and Serbian nationals permanently living abroad.
According to the central bank’s revised approach, banks must be able to verify the identity of account holders, confirm that their legal status remains unchanged and ensure that transaction activity corresponds with the information held in compliance records. Permanent registry numbers and other identifiers are intended to improve the monitoring of ownership changes, legal status and jurisdiction. The changes also place greater responsibility on clients to maintain current documentation. Non-residents can no longer rely on documentation accepted when an account was originally opened, as banks may request updated information even where no visible changes in account activity have occurred.
Dormant or infrequently used accounts may face particular risks if clients overlook correspondence from their banks. An account may appear operational until a payment fails or access to online banking is suspended because required documentation has not been provided.
Digital Applications Permitted Under Revised Rules
The amendments additionally allow bank account applications to be submitted using a durable medium, rather than exclusively through paper documentation, expanding opportunities for electronic communication and remote processing. Banks remain responsible for verifying applicant identities and the authenticity of supporting documentation. Electronic submission does not prevent institutions from requesting original documents, certified copies or additional evidence where necessary.
The revised rules will enter into force on the eighth day following publication in Serbia’s Official Gazette. The subsequent six-month implementation period allows banks to update existing customer records, although many institutions are expected to begin contacting clients well before the deadline to distribute compliance reviews across their operations.
Foreign companies are expected to keep registry documentation current, maintain consistent ownership information and ensure authorized representatives are clearly identified. Individual account holders are expected to prepare valid identity and address documentation before receiving formal requests from their banks. Under the amended framework, non-residents remain eligible to maintain bank accounts in Serbia, but continued access to banking services will depend on maintaining complete, current and verifiable compliance documentation.
