Effective from 1 July 2025, the new Decision on the Procedure for Handling Complaints, Objections, and Mediation Proposals of Financial Services Consumers (“Official Gazette of RS”, No. 51/2025), adopted by the National Bank of Serbia (“NBS”), will come into force.
This Decision repeals the previous Decision on the Procedure for Handling Complaints and Objections of Financial Services Consumers (“Official Gazette of RS”, No. 1/19, 50/19, 87/21, and 77/23) and provides consumers with a more comprehensive and transparent framework to protect their rights in dealings with banks, leasing companies, payment institutions, electronic money issuers, and the public postal operator.
Key novelties compared to the previous decision:
- For the first time, the mediation procedure before the NBS is formalized as an alternative, out-of-court dispute resolution mechanism – applicable before, during, or after the objection process.
- The definitions of “complaint” and “means of communication” have been broadened: any written submission expressing dissatisfaction counts as a complaint regardless of its title, while means of communication now include those used during mediation.
- The deadline for the service provider’s response to an objection may be extended up to six months (instead of the previous three months) in more complex cases.
- Grounds for inadmissibility of objections have been clarified, including the obligation of the NBS to notify the consumer within 21 days of receipt if the objection will not be considered, stating the reasons.
- Complaint – the first step in protection
Consumers may submit a complaint within six months from the moment they become aware of the violation, but no later than three years from the date the violation occurred (a new provision compared to the previous regulation, which allowed only a six-month deadline).
Complaints must be submitted in written form – in person, by email, via the website, or through a mobile application. Electronic submission is permitted if the date, time of receipt, and content of the complaint can be verified.
Electronic submission is allowed if the date, time of receipt, and content of the complaint can be established.
All business premises of the financial service provider must clearly display information about the complaint submission procedure. On its digital platform, the provider must place a clearly marked link to the complaint section that directly leads consumers to the complaint form.
The deadline for a response is 15 days, with a possibility of a 15-day extension in justified cases.
- Objection to the National Bank of Serbia
If a consumer does not receive a response within the prescribed deadline or finds the response unsatisfactory, they may submit an objection to the NBS within six months from the date of receipt of the response or the expiry of the deadline.
The procedure is free of charge. The NBS examines whether there has been a violation of laws, regulations, general terms and conditions, or contracts. If deemed necessary, the NBS may order the service provider to rectify any irregularities within a specified deadline.
- Mediation – a peaceful and efficient solution
The new Decision introduces, for the first time, the possibility of conducting mediation before the NBS as an alternative to the objection procedure.
Mediation:
- is conducted with the consent of both parties,
- is free of charge,
- is conducted by a trained mediator from the NBS,
- can be conducted in person or electronically.
The procedure begins with a written proposal, followed by the conclusion of an agreement to participate in mediation.
The agreement reached may have the force of an enforceable document, if it contains a clause on enforcement.
Publication of information
Twice a year, the NBS will publish on its website a list of service providers for whom, in the course of the objection procedure or supervisory proceedings, it has been determined that they did not act in accordance with the law.
For further information or professional legal assistance, our team is at your disposal.