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FinTechs belonging to this area offer traditional banking services in a modern way, usually through online services or mobile applications as well as ancillary services – e.g. enabling customers to manage their giro- or custody-accounts online and in real time or offering e-wallet services. Keywords in this context are also API-Banking or Banking as a Service (BaaS)/ Bank as a Platform (BaaP).
API-Banking:
API stands for application programming interface and is offered to access data banks and to extract and insert information. API-Banking consequently means the access to data banks of banks to offer new and innovative banking applications.
Through these services FinTechs offer services with new functions, e.g. enabling customers to manage their accounts online and in real time.
BaaS – Bank as a Service/BaaP – Bank as a Platform:
The API-based Bank as a Service platform has a full banking licence, but merely serves as the back end for standalone independent FinTechs, which “use” the licence and the back end of the bank to offer new financial services, launch additional financial products or expand into additional markets.
Introduction
Attitude of the country towards online-banking services
Provision of online banking services is an increased trend by the Serbian banks. Banks are increasingly focusing on digitalization of payment services following a noticeable shift towards online payments during COVID-19 pandemic.
There is a noticeable trend in provision of new services to the banks which enable the banks to offer multiple functionalities to their customers, such as processing and payment gateway services. It is expected that the scope of account information services will expand following harmonization of the PS Law with the PSD2.
Legal affairs
Obligations and requirements to provide online-banking services described above
At the moment, banking services, including online banking services, in Serbia can be performed only by the locally licensed banks. Minimum capital requirements are EUR 10 million for a bank.
Besides banks, there is a possibility under the PS Law for a payment institution/e-money institution to grant a loan to a payment service user in connection with the payment services it regularly provides, but only if the following conditions are met: (i) a loan has been granted exclusively for the execution of a payment transaction; (ii) the loan repayment period does not exceed 12 months; (iii) a loan has not been granted from the funds of payment service users received by a payment institution for the execution of payment transactions of these users; (iv) own funds of a payment institution are at all times appropriate to the total amount of the loans granted. That type of loans also relate to an authorised overdraft facility and credit cards issuance.
Additional comments regarding the legal situation for online-banking services or what FinTech’s must be aware of in this business area
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Economic conditions
Market size for online-banking services and biggest companies in this business area
At the moment, banking services, including online banking services, in Serbia can be performed only by the locally licensed banks.
Besides banks, there is a limited possibility under the PS Law for a payment institution/e-money institution to grant a loan to a payment service user in connection with the payment services.
In February 2022, there are 23 banks, 13 payment institutions and 4 electronic money institutions and 18 factoring companies.
Additional comments regarding the economic situation for online-banking services or what FinTech’s must be awa