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Online Gaming in Serbia

Authored by - Joksović, Stojanović & Partners (Published Nov 2023)

Overview

Open

Serbia Online Gaming Overview

Regulated
The Games of Chance Administration was established by the Law on Games of Chance (“Official Gazette of RS”, Nos. 88/2011, 93/2012 – other law, 30/2018 and 95/2018), as an administrative body within the Ministry of Finance, for the purpose of performing state administration in the field of games of chance.

The Administration began operating on March 1st 2019. The funds required for the work and functioning of the Administration are provided from the budget of the Republic of Serbia.

The new Law on Games of Chance (“Official Gazette of RS”, No.18/20 of 03.03.2020) entered into force on 11.03.2020, and it is applied from 11.04.2020.

Pursuant to the provisions of this Law, the Games of Chance Administration independently performs state administration in the field of games of chance for the entire territory of the Republic of Serbia, in such a way as to provide functional unity in the implementation of regulations in the field of games of chance.

The seat of the Games of Chance Administration is in Belgrade, 1 Omladinskih brigada St.

For more information, please visit the Republic Of Serbia Ministry Of Finance website.

Market Size
The following table provides an overview of total budget revenues from the fees on games of chance, expressed in EUR by years, as well as the number of organisers of special games of chance on automatic equipment, special games of chance involving betting, and games of chance through means of electronic communication.

The following table provides a comparative overview of paid fees by type of games of chance for 2021 and 2022 from the jurisdiction of the Games of Chance Administration.

Competitive Landscape
The offline market is much more developed and competitive than the online market which did grow somewhat due to the COVID pandemic.

Organisers of special games of chance – through means of electronic communication.

Localisation
Payment is done mostly in cash at offline organisers and debit cards at online ones. Marketing is mainly done online, electronic media, sports events.

Top Key Attractions and Challenges
Attractions

  • Well regulated market
  • Gambling/betting widely popular
  • Use of hosting services is possible
  • Low taxes (10-15%)

Challenges

  • AML regulations strictly enforced by most banks
  • Basic capital must be in money only not in equipment
  • High fees

Licensing & Regulation

Well-regulated / Unregulated (Open)

Serbia Online Gaming Licensing & Regulation

Licence Triggers
Games of chance are games in which the participants, for a fee, are offered the opportunity to gain money, things, services or rights, where the gain or loss does not depend on the knowledge or skill of the participants in the game, but from chance or some uncertain event.

In accordance with the law, only games of...

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Enforcement

Irregular / Mixed impact

Serbia Online Gaming Enforcement

Regulating Bodies
Games of Chance Administration, AML administration, Commissioner for the protection of personal data.

Supervision By Regulator
Supervision is a procedure for checking and determining the legality and regularity of fulfilling conditions and obligations, i.e. compliance with prohibitions in accordance with the law and other regulations in the field of games of chance, as well as the...

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Marketing

Restricted

Serbia Online Gaming Marketing

In general, it is prohibited to advertise and promote games of chance without license for organisation and to advertise games of chance and organisers in printed and electronic media intended for minors.

Advertising of classic and special games of chance, including indirect references to them, is carried out with a notice prohibiting the participation of minors in games of chance...

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Fees

High

Serbia Online Gaming Fees

Application Fees
The application fee is approx. EUR 10 in total.

Ongoing Fees
EUR 2,500 monthly (the fee is paid to the appropriate public revenue payment account upon receipt of the approval decision by the fifth day of the following month for the month in which the approval decision was received, in proportion to the number of days...

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Taxes

Low

Serbia Online Gaming Taxes

Licence Taxes
The organiser pays a fee for organising games of chance – betting via means of electronic communication monthly in the amount of 15% of the base, and for other special games of chance via means of electronic communication in the amount of 10% of the base, which is the difference between the total in-payments made and the...

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Future Outlook

Positive

Serbia Online Gaming Future Outlook

Currently, no proposed changes to the law are in the Parliament. Online gambling is growing the fastest. The Law on Digital Assets has been in force since 2020 and it legalises use of crypto-currencies and introduces a licensing system for the providers of digital assets including crypto exchanges and ICOs/traders.

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Legal Expert

Joksović, Stojanović & Partners

Office locations Serbia

Joksović, Stojanović & Partners relies on highly experienced lawyers who provide high-end legal services in most complex and pioneering work in a wide range of industries.

Our principle field of practice is corporate and commercial law where we offer services in domestic and international corporate affairs. We are recognized for our expertise in work with an international element, which includes foreign investments in Serbia, mergers and acquisitions, investment through the privatization process, setting-up of business in Serbia and Montenegro, investments in domestic enterprises, joint-venture agreements and a wide range of commercial contract issues. Our office represents foreign clients in the resolution of disputes and litigation before courts in Serbia and Montenegro and international arbitrations. We are well known as advisors in major real estate and infrastructure projects in both Serbia and Montenegro. In addition, our office provides services in other fields related to day to day operations of our clients, including labor law, immigration, intellectual property and patent law, telecommunications, competition, capital markets, international private law and information technology (IT) law.

Our broad client base includes corporate, governmental and private entities. We provide continuous, long-term legal advice to a large number of international corporate clients in Serbia and Montenegro and we serve as counsel of choice for the German, Austrian and Swiss embassies in Belgrade, and we are listed as recommended attorneys by several other embassies in Serbia, including those of the United States, Australia, United Kingdom and Canada.

We have extensive cross-border transaction experience, where we collaborated with many international law firms and investment banks.

Joksović, Stojanović & Partners is a founding member of Adriatic Legal Network (ALN) (www.adriaticlegalnetwork.com ) and is collaborating with Andersen Global in Serbia and Montenegro (https://andersen.com/offices).

Our clients value our continuous resourcefulness, reliability and professional insight.

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