A new legal basis for compulsory liquidation was introduced through amendments to the Law on Payment Services in 2024. This provision mandates the compulsory liquidation and deletion from the business register for entities that have not had an open bank account for more than six months. The process is irremediable, meaning it cannot be avoided once initiated by the National Bank of Serbia or the Serbian Business Registers Agency.
While maintaining an account is a legal requirement, commercial banks are not obliged to open accounts for all businesses. Banks may refuse to establish a business relationship based on internal risk policies, sanctions lists, or reputational concerns. This poses a practical challenge as companies can only open regular accounts after registration, yet the law does not require an account for the initial registration itself.
The detailed review written by Senior Associate Mirjana Milošević from the JPM Belgrade office is available here.
