Law on Electronic Money adopted in Republika Srpska

On 04 January 2024, the Law on Electronic Money was published in the “Official Gazette of Republika Srpska”, no. 1/24 (hereinafter: the “Law”). The Law enters into force six months following the date of its publication, whilst the regulator (Banking Agency of Republika Srpska) shall render respective by-laws within six months following the day of entering into force.

An issuer of electronic money (e-money), under conditions stipulated in the Law, can be a bank, a microcredit organization, or a company for issuing e-money.

E-money can be accepted by any natural person or legal entity who is not an issuer of that e-money, whilst the e-money issuer can accept e-money issued by themselves, as well as e-money issued by another e-money issuer.

The Law has regulated conditions that a company must meet to obtain a permit/license for e-money issuing. Thus, e.g. the minimum share capital in funds amounts to 700,000 BAM and must be maintained during the course of business. E-money permits are issued for an indefinite period and cannot be transferred to other entities.

It is not necessary that a company that issues e-money conducts only such activity, since the Law also regulates the so-called hybrid companies, i.e. company which conducts other business activities, in addition to providing e-money issuing services. However, there are also special requirements for hybrid companies, e.g. to establish a special business unit for e-money issuance, to keep separate e-money issuing records, etc.

Provisions of the Law that apply to companies with registered office in Republika Srpska, also apply to operations of business units of companies with registered office in the Federation of Bosnia and Herzegovina and Brčko Distrikt, unless otherwise regulated.

The Banking Agency of Republika Srpska supervises the implementation of the Law and keeps the register on companies that issue e-money.
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