Serbia

Country score (EU Average*)

84(72) Political Financing
89(57) Financial Disclosure
92(49) Conflict of Interest
83(59) Freedom of Information
89(63) Public Procurement
71(66) Anti Money Laundering
67(71) Asset Recovery

Country Facts

Income	Upper middle
GNI per capita (2011 PPP $)	12908.01
Population, total	7057412.00
Urban population (% of total)	55.67
Internet users (per 100 people)	67.06
Life expectancy at birth (years)	75.49
Mean years of schooling (years)	10.8
Global Competitiveness Index	4.1

Sources: World Bank, UNDP, WEF.

Political Financing

The Law on Financing Political Parties Kosovo (2010, amended 2012 & 2013) and the Law on Financing Political Activities (2011, amended 2014) are the main laws regulating the financing of political parties in Serbia.

There are a number of limits on the private income of political parties. There are bans on donations from foreign interests, trade unions and anonymous donations. Corporate donations are only banned where the corporation is under partial government ownership. There are also limits on the amount that may be donated to political parties and candidates both during and outside of election period.

There is public funding available for political parties which is allocated according to the share of votes attained in the previous election, the representation in the elected body and the participation in the election. There is free and equal subsidized access to the media and there are provisions to encourage gender equality among candidates.

For regulations on spending, there are bans on vote buying and on the use of some state resources being used in favour or against a political party or candidate. There are no limits on what a party or candidate can spend.

Parties are required to keep annual accounts which must be made public. These must reveal finances in relation to election campaigns and must reveal the identity of donors. Accounts are overseen by the Anti-corruption Agency. There are sanctions for those breaching the provisions of the law. They include fines, the loss of public funding and imprisonment.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024
Bans and limits on private income	69	69	67	67	75	100
Public funding	88	88	88	88	88	88
Regulations on spending	100	100	100	100	100	50
Reporting, oversight and sanctions	92	100	100	100	100	100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Bans and limits on private income
Is there a ban on donations from foreign interests to political parties?	Yes. Foreign states, natural and leagal persons are banned from making contributions to political subjects (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on donations from foreign interests to candidates?	Yes. Foreign states, natural and leagal persons are banned from making contributions to political subjects (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on corporate donations to political parties?	Yes. All contributions must be channeled through the nominating political party Specifically, financing from the gaming industry; importers, exporters and manufacturers of excise goods, legal entities and entrepreneurs with due, and unsettled, public revenue obligations, is prohibited (Article 9 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on corporate donations to candidates?	Yes. All contributions must be channeled through the nominating political party It is prohibited to finance a political entity by foreign states; foreign natural persons and legal entities, except international political associations. Importantly, the term used in the legal text, "international political association," could refer to political foundations established by political parties (e.g., Konrad Adenauer Stiftung, Friedrich Ebert, etc.) Importantly, because the article specifies that this donation cannot be in money, it could refer to educational and consulting activities, such as international conferences, courses, etc. (Article 9 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on donations from corporations with government contracts to political parties?	Yes. Ban applies to donations from corporations with most types of public contracts (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on donations from corporations of partial government ownership to political parties?	Yes. Ban applies to donations from corporations with most types of public contracts (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on donations from corporations with government contracts to candidates?	Yes. Financing of political entity by a natural person or legal entity engaged in activities of general interest pursuant to contract with organs of the Republic of Serbia, autonomous province and local government and public services founded by them is prohibited throughout the validity of such contract and for a period of two years subsequent to termination of contractual relations. (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on donations from corporations of partial government ownership to candidates?	Yes. It is prohibited to finance political entity by companies and entrepreneurs engaged in services of general interest, institutions and companies with state capital share, other organizations discharging administrative authority; (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on donations from Trade Unions to political parties?	Yes. It is prohibited to finance political entity by trade unions (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on donations from Trade Unions to candidates?	Yes. It is prohibited to finance political entity by trade unions (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on anonymous donations to political parties?	Yes. It is prohibited to finance political entity by anonymous donors (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on anonymous donations to candidates?	Yes. It is prohibited to finance political entity by anonymous donors (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on state resources being given to or received by political parties or candidates (excluding regulated public funding)?	Yes. It is prohibited to finance political entity by companies and entrepreneurs engaged in services of general interest, institutions and companies with state capital share, other organizations discharging administrative authority; (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a ban on any other form of donation?	Yes. Financing of a political entity by an endowment and foundation is prohibited (Article 12 , Law on Financing Political Activities (2011, amended 2014) Article 12 Law on financing political activities, 2022)
Is there a limit on the amount a donor can contribute to a political party over a time period (not election specific)?	Yes. Maximum value of donation on at annual level that a natural person may give to political entities for regular work shall not exceed 20 average monthly salaries. Maximum value of donation at annual level that a legal entity may give to political entities for regular work shall not exceed 200 average monthly salaries (Article 10 , Law on Financing Political Activities (2011, amended 2014))
Is there a limit on the amount a donor can contribute to a political party in relation to an election?	Yes. The limit is 20 average monthly salaries per year by a physical person and 200 average montly salaries by a legal entity regardless of a number of elections held within a year. (Article 22 , Law on Financing Political Activities (2011, amended 2014))
Is there a limit on the amount a donor can contribute to a candidate?	Yes. The limit is 20 average monthly salaries per year by a physical person and 200 average montly salaries by a legal entity regardless of a number of elections held within a year. (Article 22 , Law on Financing Political Activities (2011, amended 2014))
Public funding
Eligibility criteria for direct public funding to political parties	Yes. See sub-indicators
Eligibility criteria for direct public funding to political parties: Share of votes in previous election	Yes. The number of votes of a political entity taken as basis for allocation of funds is calculated by multiplying the number of votes of all voters up to 5% of valid votes with a quotient of 1.5, and the number of votes over 5% of valid votes of all voters with a coefficient of 1. (Article 17, Law on Financing Political Activities (2011, amended 2014))
Eligibility criteria for direct public funding to political parties: Representation in elected body	Yes. Funds from public sources appropriated for financing of regular work of political entities whose candidates have been elected members of parliament, deputies and/or /councillors are set at the level of 0.105% of the budget of the Republic of Serbia, tax revenues of the budget of the autonomous province, or tax revenues of the budget of the local government. (Article 16, Law on Financing Political Activities (2011, amended 2014))
Eligibility criteria for direct public funding to political parties: Participation in election	Yes. Funds from public sources for covering election campaign costs are allocated in the year of regular elections in the amount of 0.07% of the Republic of Serbia budgetary expenditure, of the autonomous province budgetary expenditure and/or of the local government budgetary expenditure for the budget year (Articles 20 and 21, Law on Financing Political Activities (2011, amended 2014))
Eligibility criteria for direct public funding to political parties: Number of candidates	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of seats in previous election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of votes in next election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Registration as a political party	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of seats in next election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Number of members	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Other	No. Absent from legal framework
Allocation calculations for direct public funding to political parties	Yes. See sub-indicators
Allocation calculations for direct public funding to political parties: Proportional to votes received	Yes. Funds allocated as flat rate by votes received, though the number of votes up to 5% of valid votes is multiplied with a quotient of 1.5, and the number of votes over 5% of valid votes of all voters with a coefficient of 1. (Article 17, Law on Financing Political Activities (2011, amended 2014))
Allocation calculations for direct public funding to political parties: Equal	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Proportional to seats received	Yes. The funds referred to in Article 16 of this Law shall be distributed to political entities that won seats in representative bodies in proportion to the number of votes calculated in the manner provided for in paragraph 2 of this article. (Article 17, Law on Financing Political Activities (2011, amended 2014))
Allocation calculations for direct public funding to political parties: Flat rate by votes received	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Share of expenses reimbursed	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Proportional to candidates fielded	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Number of members	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Other	No. Absent from legal framework
Earmarking provisions for direct public funding to political parties	Yes. See sub-indicators
Earmarking provisions for direct public funding to political parties: Campaign spending	No. Absent from legal framework
Earmarking provisions for direct public funding to political parties: Ongoing party activities	Yes. The funds for financing regular operation of political entities are used for financing costs of election campaign, in accordance with this Law. (Article 19, Law on Financing Political Activities (2011, amended 2014))
Earmarking provisions for direct public funding to political parties: Intra-party institution	No. Absent from legal framework
Earmarking provisions for direct public funding to political parties: Other	Yes. The funds for financing regular operation of political entities are used for the operation and promotion the idea of a political entity and include: work with voters and members, the cost of transportation and maintenance meetings, the costs of promotion, advertising materials and publications, the cost of the public opinion polls, training, international cooperation, the cost of wages and salaries of employees, utility costs, as well as the cost for similar activities. (Article 19, Law on Financing Political Activities (2011, amended 2014))
Allocation criteria for free or subsidized access to media for political parties	Yes. See sub-indicators
Allocation criteria for free or subsidized access to media for political parties: Equal	Yes. Free and equal representation of political parties, coalitions, and candidates that have verified electoral registers for the republic, provincial, or local elections during campaigning; (Article 7.8, Law on Public Service Broadcasting (2014, amended 2016))
Allocation criteria for free or subsidized access to media for political parties: Number of candidates	No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Share of seats	No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Share of votes in preceding election	No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Other	No. Absent from legal framework
Are there provisions for free or subsidized access to media for candidates?	Yes. Free and equal representation of political parties, coalitions, and candidates that have verified electoral registers for the republic, provincial, or local elections during campaigning; (Article 7.8, Law on Public Service Broadcasting (2014, amended 2016))
Are there provisions for any other form of indirect public funding?	Yes. See sub-indicators
Provisions for any other form of indirect public funding: Premises for campaign meetings	No. Absent from legal framework
Provisions for any other form of indirect public funding: Space for campaign materials	No. Absent from legal framework
Provisions for any other form of indirect public funding: Tax relief	No. Absent from legal framework
Provisions for any other form of indirect public funding: Free or subsidised transport	No. Absent from legal framework
Provisions for any other form of indirect public funding: Free or subsidised postage cost	No. Absent from legal framework
Provisions for any other form of indirect public funding: Other	Yes. Organs of the Republic of Serbia, autonomous province and local government, as well as other organizations founded by them shall more specifically regulate granting of services and goods referred in paragraph 1 of this article (art. 6). (Article 6, Law on Financing Political Activities (2011, amended 2014))
Is the provision of direct public funding to political parties related to gender equality among candidates?	Yes. Indirect provision - The election Law demands that parties have at least one third of candidates of each gender. Parties not complying could not participate election processes at all and consequently cannot obtain state funding. ( Article 40a, Law on the Elections of Deputies (2000, last amended 2011))
Are there provisions for other financial advantages to encourage gender equality in political parties?	No. Absent from legal framework
Regulations on spending
Is there a ban on vote buying?	Yes. Punishment is 3 years in prison, or 5 in case of elections committee member (Article 156, Criminal Code (2005, amended 2014); Articles 104 and 106, Law on the Elections of Deputies (2000, last amended 2011))
Are there bans on state resources being used in favour or against a political party or candidate?	Yes. It is obligatory to grant services and goods from public entities under equal terms. State media also has to provide free and equal representation of political parties. (Article 7.8, Law on Public Service Broadcasting (2014, amended 2016); Article 6 , Law on Financing Political Activities (2011, amended 2014))
Are there limits on the amount a political party can spend?	No. Absent from legal framework
Are there limits on the amount a candidate can spend?	No. Absent from legal framework
Reporting, oversight and sanctions
Do political parties have to report regularly on their finances?	Yes. Political entities which have representatives in elected bodies and registered political parties are required to submit to the Agency an annual financial report and the report on contributions and assets, with prior obtained the opinion of an authorized auditor licensed in accordance with the regulations on accounting and auditing, to 15 April of the current year for the previous year. (Article 28, Law on Financing Political Activities (2011, amended 2014))
Do political parties have to report on their finances in relation to election campaigns?	Yes. Political party participating in the election campaign, he shall submit a report on the costs election campaign, within 30 days of the announcement of final election results. to submit to the Agency an annual financial report and the report on contributions and assets, with prior obtained the opinion of an authorized auditor licensed in accordance with the regulations on accounting and auditing, to 15 April of the current year for the previous year. (Article 29, Law on Financing Political Activities (2011, amended 2014))
Do candidates have to report on their campaign finances?	Yes. Political entities which have representatives in elected bodies and registered political parties are required to submit to the Agency an annual financial report and the report on contributions and assets, with prior obtained the opinion of an authorized auditor licensed in accordance with the regulations on accounting and auditing, to 15 April of the current year for the previous year. (Article 29, Law on Financing Political Activities (2011, amended 2014))
Is information in reports from political parties and/or candidates to be made public?	Yes. The annual financial report is published on the website of the Agency. (Article 29, Law on Financing Political Activities (2011, amended 2014))
Must reports from political parties and/or candidates reveal the identity of donors?	Yes. The report on election campaign costs contains information on origin, amount and structure of raised and spent funds from public and private sources. (Article 29, Law on Financing Political Activities (2011, amended 2014))
Institutions receiving financial reports from political parties and/or candidates
Institutions receiving financial reports from political parties and/or candidates: Electoral Management Board	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Auditing agency	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Ministry	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Special institution	Yes. Anti-corruption Agency (Article 27, Law on Financing Political Activities (2011, amended 2014))
Institutions receiving financial reports from political parties and/or candidates: Court	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Other	No. Absent from legal framework
Is it specified that a particular institution(s) is responsible for examining financial reports and/or investigating violations?
Institution responsible for examining financial reports and/or investigating violations: Court	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Ministry	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Auditing agency	Yes. After examination of the financial reports of the political subject, the Anti-corruption Agency can request State Audit Institution to audit the financial reports. (Article 34, Law on Financing Political Activities (2011, amended 2014))
Institution responsible for examining financial reports and/or investigating violations: Electoral Management Body	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Institution for this purpose	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Other	Yes. After examination of the financial reports of the political subject, the Anti-corruption Agency can request State Audit Institution to audit the financial reports. (Article 34, Law on Financing Political Activities (2011, amended 2014))
Other institutions with a formal role in political finance oversight
Institutions with a formal role in political finance oversight: Court	No. Absent from legal framework (Chapter V (Articles 27-34, )Law on Financing Political Activities (2011, amended 2014))
Institutions with a formal role in political finance oversight: Ministry	No. Absent from legal framework (Chapter V (Articles 27-34, )Law on Financing Political Activities (2011, amended 2014))
Institutions with a formal role in political finance oversight: Auditing agency	Yes. The Agency may, after conducting control of financial reports of a political entity, forward a request to the State Audit Institution to audit these reports, in accordance with the law governing competencies of the State Audit Institution (Article 34, Law on Financing Political Activities (2011, amended 2014))
Institutions with a formal role in political finance oversight: EMB	No. Absent from legal framework
Institutions with a formal role in political finance oversight: Institution for this purpose	No. Absent from legal framework
Institutions with a formal role in political finance oversight: Other	No. Absent from legal framework
Sanctions for political finance infractions
Sanctions for political finance infractions: Fines	Yes. 200,000 to 2,000,000 RSD depending on misdemeanor (Articles 39 and 40, Law on Financing Political Activities (2011, amended 2014))
Sanctions for political finance infractions: Loss of public funding	Yes. In case of conviction for a criminal offence specified in article 38 hereof or if a political party or responsible person of a political entity is fined for misdemeanour specified in article 39 hereof, the political entity shall lose the right to funds from public sources dedicated for financing of the political entity (Article 42, Law on Financing Political Activities (2011, amended 2014) )
Sanctions for political finance infractions: Penal/Criminal	Yes. Whoever gives, and/or provides for and on behalf of the political entity, funds for financing of the political entity contrary to the provisions of this Law with intent to conceal the source of financing or amount of collected funds of the political entity, shall be punished with imprisonment from three months to three years. (Article 38, Law on Financing Political Activities (2011, amended 2014) )
Sanctions for political finance infractions: Forfeiture	No. Absent from legal framework
Sanctions for political finance infractions: Deregistration of party	No. Absent from legal framework
Sanctions for political finance infractions: Loss of elected office	No. Absent from legal framework
Sanctions for political finance infractions: Suspension of political party	No. Absent from legal framework
Sanctions for political finance infractions: Loss of nomination of candidate	No. Absent from legal framework
Sanctions for political finance infractions: Loss of political rights	No. Absent from legal framework
Sanctions for political finance infractions: Other	Yes. The suspension of the transfer of funds from public source (Articles 42 and 43, Law on Financing Political Activities (2011, amended 2014))

Legislation

Law on Financing Political Activities, 2011, amended 2014 (Serbian)	pdf
Law on Public Service Broadcasting, 2014, amended 2016 (Serbian)	pdf
Law on the Elections of Members of Parliament, 2000, amended 2011 (English)	pdf
Criminal Code, 2005, amended 2014 (English)	pdf

*Last update: 2017

Financial Disclosure

The Serbian Anti-Corruption Agency Act (2008, last amended 2010) sets down all of the regulations governing financial disclosure, which apply to all public officials. Thus, the Head of State, Ministers, Members of Parliament and Civil Servants must disclose real estate, movable assets, cash, debts, and gifts they receive. Additionally, the source and amount of outside income, and shares in private or public companies must be disclosed. Government contracts are to be disclosed only if the public official holds over 20% of shares in the enterprise. Any private interests which may affect decision-making must be included in disclosure statements. All public officials continue to submit financial interest declarations for two years after ending tenure. Spouses and underage children are to be included in the disclosure.

All public officials submit their statements upon first taking and leaving office, and make annual updates given any changes have occurred. Submitting late declarations is punishable with a fine, while failing to make a declaration or making false disclosure statements may lead to imprisonment from six months to five years. All public officials make their declarations with the Anti-Corruption Agency. This agency is also responsible for verifying the accuracy of submissions, and enforcing possible sanctions. In addition, the Anti-Corruption Agency publishes all disclosure statements on its homepage. Only car registration number, bank and bank account number and the address of physical property are not included in this publication.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Disclosure items	81	85	85	85	85	96
Filing frequency	100	75	75	75	75	75
Sanctions	33	100	100	100	100	100
Monitoring and Oversight	50	100	100	100	100	100
Public access to declarations	25	75	75	75	75	75
Alternative Metric	2012	2015	2016	2017	2020	2024	Trend
Head of State	58	87	87	87	87	89
Ministers	58	87	87	87	87	89
Members of Parliament	57	87	87	87	87	89
Civil servants	58	87	87	87	87	89

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Head of State
Disclosure items
Spouses and children included in disclosure	Yes. Declaration report shall contain information on assets and income of his/her spouse or common law partner, as well as those of his/her underaged children if they live in the same family household, as at the day of election, appointment or nominationt. (Article 68, Law on Corruption Prevention (2019))
Income and Assets
Real estate	Yes. Declaration report shall contain information on permanent and temporary residence, the right to use an apartment for official purposes and the right of ownership or the right of lease on real property (Article 71, Law on Corruption Prevention (2019))
Movable assets	Yes. Disclosure report shall contain information concerning movable property subject to registration with the relevant authorities in the Republic of Serbia and abroad (motor vehicles, vessels, aircraft, weapons et al),; property rights on and movables of high value (valuables, art collections et al); rights deriving from copyright, patent and similar intellectual property rights. (Article 71, Law on Corruption Prevention (2019))
Cash	Yes. Disclosure report shall contain concerning property and income, including deposits in banks and other financial organisations, at home and abroad (Article 71, Law on Corruption Prevention (2019))
Loans and Debts	Yes. Disclosure report shall contain information that includes receivables and payables (principal, interest and period of repayment and maturity); (Article 71, Law on Corruption Prevention (2019))
Income from outside employment/assets	Yes. Disclosure report sahall contain information that includes source and amount of income from source and amount of net income the public official receives because s/he is discharging a public office and the source and amount of other net income s/he receives from the Budget and other public sources; source and amount of net income from other work or business activity; net income from scientific research, teaching, cultural, artistic, humanitarian or sports activities; income from copyright, patent and other intellectual property rights; source and amount of other net income; (Article 71, Law on Corruption Prevention (2019))
Incompatibilities
Gifts received as a public official	Yes. Received occasional and protocol gifts shall become public property, in accordance with the law governing public property. Within eight days from the day of receiving an occasional or protocol gift and/or returning to the country, the public official shall hand over the gift to the public authority in which s/he discharges public office, and the public authority shall hand over the gift to the authority in charge of dealing with items that constitute public property. Exceptionally, a public official and his/her family member shall be entitled to retain a protocol or occasional gift whose value does not exceed 10% of the average monthly salary without taxes and contributions in the Republic of Serbia; the total value of gifts retained in the course of one calendar year cannot exceed the amount of one average monthly salary without taxes and contributions in the Republic of Serbia. Gifts retained by family members shall be included in the total value of the gifts a public official has retained within one calendar year. (Articles 59 and 60, Law on Corruption Prevention (2019))
Ownership of state-owned enterprises (SOEs)	Yes. Disclosure report shall contain information that includes shares and stakes in legal persons; data on legal persons if the public official holds there more than 3% of stakes or shares (Article 71, Law on Corruption Prevention (2019))
Holding government contracts	Yes. Public officials have to disclose within 3 days if a company of which they or their family members own a share greater than 20% participates in a procedure that would end with the signing of a government contract. (Article 53, Law on Corruption Prevention (2019))
Board member, advisor, or company officer of private firm	Yes. At the request of a public official the Agency may give consent to a public official to perform other work and/or business activity. Along with the request, the public official shall submit a positive opinion of the authority that had elected, appointed or nominated him/her to the public office. An appointed civil servant is obliged to submit, along with the request, the consent of his/her immediate superior. The Agency shall decide on a complete and properly filed request within 15 days from the day of its receipt. (Article 46, Law on Corruption Prevention (2019))
Post-employment	Yes. Prior to establishing an employment relationship and/or business cooperation referred to in paragraph 1 of this Article, a person whose public office has ceased shall request the consent of the Agency, which is obliged to decide on the request within 30 days. (Article 55, Law on Corruption Prevention (2019))
Simultaneously holding policy-making position and policy-executing position	Yes. Public officials are obliged to submit a disclosure report that includes other public functions, jobs or activities discharged in accordance with law and special regulations; (Article 71, Law on Corruption Prevention (2019))
Participating in official decision-making processes that affect private interests	Yes. On taking office and in the course of discharging public office, a public official shall notify in writing, without delay and no later than within a period of five days, his/her immediate superior and the Agency regarding any doubts concerning the existence of a conflict of interest, or his/her conflict of interest, or that of an associated person. (Article 42, Law on Corruption Prevention (2019))
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	Yes. Report must be filed within 30 days of taking the office (Article 68, Law on Corruption Prevention (2019))
Filing required upon leaving office	Yes. Report must be filed within 30 days of leaving the office (Article 68, Law on Corruption Prevention (2019))
Filing required annually	No. Only when significant changes of the property reported in the previous report occur. Changes are considered significant if their value exceeds average annual net income in the Republic of Serbia when there is a change to the structure of said assets. (Articles 69, Law on Corruption Prevention (2019))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. On taking office and in the course of discharging public office, a public official shall notify in writing, without delay and no later than within a period of five days, his/her immediate superior and the Agency regarding any doubts concerning the existence of a conflict of interest, or his/her conflict of interest, or that of an associated person. (Article 42, Law on Corruption Prevention (2019))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. For the late report filing an official can be fined with 50,000 to 150,000 RSD (Article 103, Law on Corruption Prevention (2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	Yes. Non-filing report of property is punishable with imprisonment from six month to five years. (Article 101, Law on Corruption Prevention (2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Providing false information on property is punishable with imprisonment from six month to five years. (Article 101, Law on Corruption Prevention (2019))
Monitoring and Oversight
Depository body explicitly identified	Yes. The Agency shall maintain the following records: 1) Register of Public Officials; 2) Register of Assets and Income of Public Officials; 3) Record of legal persons in which public officials or their family members have stakes or shares of more than 20%, that are participating in public procurement, privatisation or other procedures whose outcome is the conclusion of a contract with a public authority-budget user or another legal person in which more than 20% of the capital is owned by the Republic of Serbia, the autonomous province, a local self-government unit and a city municipality; 4) Catalog of Gifts. (Articles 100, Law on Corruption Prevention (2019))
Enforcement body explicitly identified	Yes. The Anti-Corruption Agency institutes proceedings and pronounces measures for violation of the Law, and rules on conflict of interest (Article 6, Law on Corruption Prevention (2019))
Some agency assigned responsibility for verifying submission	Yes. The Anti-Corruption Agency verifies the submissions of officials in cooperation with the state bodies where they serve. (Article 75, Law on Corruption Prevention (2019))
Some agency assigned responsibility for verifying accuracy	Yes. The Anti-Corruption Agency checks due filing of Report and accuracy and completeness of information. (Article 75, Law on Corruption Prevention (2019))
Public access to declarations
Public availability	Yes. The catalogue of gifts and information on the salary and the public functions of officials is public. (Articles 66 and 67, Law on Corruption Prevention (2019))
Timing of information release specified	Yes. The catalogue of gifts will be published by 1 June for the previous year. (Article 66, Law on Corruption Prevention (2019))
Location(s) of access specified	Yes. Public information will be posted on the Anti-Corruption Agency's web site. Once three years have elapsed from the termination of public office, data from the records, with the exception of those from the Catalog of Gifts, shall no longer be published on the website of the Agency. (Article 100, Law on Corruption Prevention (2019))
Cost of access specified	No. ů
Ministers
Disclosure items
Spouses and children included in disclosure	Yes. Declaration report shall contain information on assets and income of his/her spouse or common law partner, as well as those of his/her underaged children if they live in the same family household, as at the day of election, appointment or nominationt. (Article 68, Law on Corruption Prevention (2019))
Income and Assets
Real estate	Yes. Declaration report shall contain information on permanent and temporary residence, the right to use an apartment for official purposes and the right of ownership or the right of lease on real property (Article 71, Law on Corruption Prevention (2019))
Movable assets	Yes. Disclosure report shall contain information concerning movable property subject to registration with the relevant authorities in the Republic of Serbia and abroad (motor vehicles, vessels, aircraft, weapons et al),; property rights on and movables of high value (valuables, art collections et al); rights deriving from copyright, patent and similar intellectual property rights. (Article 71, Law on Corruption Prevention (2019))
Cash	Yes. Disclosure report shall contain concerning property and income, including deposits in banks and other financial organisations, at home and abroad (Article 71, Law on Corruption Prevention (2019))
Loans and Debts	Yes. Disclosure report shall contain information that includes receivables and payables (principal, interest and period of repayment and maturity); (Article 71, Law on Corruption Prevention (2019))
Income from outside employment/assets	Yes. Disclosure report sahall contain information that includes source and amount of income from source and amount of net income the public official receives because s/he is discharging a public office and the source and amount of other net income s/he receives from the Budget and other public sources; source and amount of net income from other work or business activity; net income from scientific research, teaching, cultural, artistic, humanitarian or sports activities; income from copyright, patent and other intellectual property rights; source and amount of other net income; (Article 71, Law on Corruption Prevention (2019))
Incompatibilities
Gifts received as a public official	Yes. Received occasional and protocol gifts shall become public property, in accordance with the law governing public property. Within eight days from the day of receiving an occasional or protocol gift and/or returning to the country, the public official shall hand over the gift to the public authority in which s/he discharges public office, and the public authority shall hand over the gift to the authority in charge of dealing with items that constitute public property. Exceptionally, a public official and his/her family member shall be entitled to retain a protocol or occasional gift whose value does not exceed 10% of the average monthly salary without taxes and contributions in the Republic of Serbia; the total value of gifts retained in the course of one calendar year cannot exceed the amount of one average monthly salary without taxes and contributions in the Republic of Serbia. Gifts retained by family members shall be included in the total value of the gifts a public official has retained within one calendar year. (Articles 59 and 60, Law on Corruption Prevention (2019))
Ownership of state-owned enterprises (SOEs)	Yes. Disclosure report shall contain information that includes shares and stakes in legal persons; data on legal persons if the public official holds there more than 3% of stakes or shares (Article 71, Law on Corruption Prevention (2019))
Holding government contracts	Yes. Public officials have to disclose within 3 days if a company of which they or their family members own a share greater than 20% participates in a procedure that would end with the signing of a government contract. (Article 53, Law on Corruption Prevention (2019))
Board member, advisor, or company officer of private firm	Yes. At the request of a public official the Agency may give consent to a public official to perform other work and/or business activity. Along with the request, the public official shall submit a positive opinion of the authority that had elected, appointed or nominated him/her to the public office. An appointed civil servant is obliged to submit, along with the request, the consent of his/her immediate superior. The Agency shall decide on a complete and properly filed request within 15 days from the day of its receipt. (Article 46, Law on Corruption Prevention (2019))
Post-employment	Yes. Prior to establishing an employment relationship and/or business cooperation referred to in paragraph 1 of this Article, a person whose public office has ceased shall request the consent of the Agency, which is obliged to decide on the request within 30 days. (Article 55, Law on Corruption Prevention (2019))
Simultaneously holding policy-making position and policy-executing position	Yes. Public officials are obliged to submit a disclosure report that includes other public functions, jobs or activities discharged in accordance with law and special regulations; (Article 71, Law on Corruption Prevention (2019))
Participating in official decision-making processes that affect private interests	Yes. On taking office and in the course of discharging public office, a public official shall notify in writing, without delay and no later than within a period of five days, his/her immediate superior and the Agency regarding any doubts concerning the existence of a conflict of interest, or his/her conflict of interest, or that of an associated person. (Article 42, Law on Corruption Prevention (2019))
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	Yes. Report must be filed within 30 days of taking the office (Article 68, Law on Corruption Prevention (2019))
Filing required upon leaving office	Yes. Report must be filed within 30 days of leaving the office (Article 68, Law on Corruption Prevention (2019))
Filing required annually	No. Only when significant changes of the property reported in the previous report occur. Changes are considered significant if their value exceeds average annual net income in the Republic of Serbia when there is a change to the structure of said assets. (Articles 69, Law on Corruption Prevention (2019))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. On taking office and in the course of discharging public office, a public official shall notify in writing, without delay and no later than within a period of five days, his/her immediate superior and the Agency regarding any doubts concerning the existence of a conflict of interest, or his/her conflict of interest, or that of an associated person. (Article 42, Law on Corruption Prevention (2019))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. For the late report filing an official can be fined with 50,000 to 150,000 RSD (Article 103, Law on Corruption Prevention (2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	Yes. Non-filing report of property is punishable with imprisonment from six month to five years. (Article 101, Law on Corruption Prevention (2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Providing false information on property is punishable with imprisonment from six month to five years. (Article 101, Law on Corruption Prevention (2019))
Monitoring and Oversight
Depository body explicitly identified	Yes. The Agency shall maintain the following records: 1) Register of Public Officials; 2) Register of Assets and Income of Public Officials; 3) Record of legal persons in which public officials or their family members have stakes or shares of more than 20%, that are participating in public procurement, privatisation or other procedures whose outcome is the conclusion of a contract with a public authority-budget user or another legal person in which more than 20% of the capital is owned by the Republic of Serbia, the autonomous province, a local self-government unit and a city municipality; 4) Catalog of Gifts. (Articles 100, Law on Corruption Prevention (2019))
Enforcement body explicitly identified	Yes. The Anti-Corruption Agency institutes proceedings and pronounces measures for violation of the Law, and rules on conflict of interest (Article 6, Law on Corruption Prevention (2019))
Some agency assigned responsibility for verifying submission	Yes. The Anti-Corruption Agency verifies the submissions of officials in cooperation with the state bodies where they serve. (Article 75, Law on Corruption Prevention (2019))
Some agency assigned responsibility for verifying accuracy	Yes. The Anti-Corruption Agency checks due filing of Report and accuracy and completeness of information. (Article 75, Law on Corruption Prevention (2019))
Public access to declarations
Public availability	Yes. The catalogue of gifts and information on the salary and the public functions of officials is public. (Articles 66 and 67, Law on Corruption Prevention (2019))
Timing of information release specified	Yes. The catalogue of gifts will be published by 1 June for the previous year. (Article 66, Law on Corruption Prevention (2019))
Location(s) of access specified	Yes. Public information will be posted on the Anti-Corruption Agency's web site. Once three years have elapsed from the termination of public office, data from the records, with the exception of those from the Catalog of Gifts, shall no longer be published on the website of the Agency. (Article 100, Law on Corruption Prevention (2019))
Cost of access specified	No. ů
Members of Parliament
Disclosure items
Spouses and children included in disclosure	Yes. Declaration report shall contain information on assets and income of his/her spouse or common law partner, as well as those of his/her underaged children if they live in the same family household, as at the day of election, appointment or nominationt. (Article 68, Law on Corruption Prevention (2019))
Income and Assets
Real estate	Yes. Declaration report shall contain information on permanent and temporary residence, the right to use an apartment for official purposes and the right of ownership or the right of lease on real property (Article 71, Law on Corruption Prevention (2019))
Movable assets	Yes. Disclosure report shall contain information concerning movable property subject to registration with the relevant authorities in the Republic of Serbia and abroad (motor vehicles, vessels, aircraft, weapons et al),; property rights on and movables of high value (valuables, art collections et al); rights deriving from copyright, patent and similar intellectual property rights. (Article 71, Law on Corruption Prevention (2019))
Cash	Yes. Disclosure report shall contain concerning property and income, including deposits in banks and other financial organisations, at home and abroad (Article 71, Law on Corruption Prevention (2019))
Loans and Debts	Yes. Disclosure report shall contain information that includes receivables and payables (principal, interest and period of repayment and maturity); (Article 71, Law on Corruption Prevention (2019))
Income from outside employment/assets	Yes. Disclosure report sahall contain information that includes source and amount of income from source and amount of net income the public official receives because s/he is discharging a public office and the source and amount of other net income s/he receives from the Budget and other public sources; source and amount of net income from other work or business activity; net income from scientific research, teaching, cultural, artistic, humanitarian or sports activities; income from copyright, patent and other intellectual property rights; source and amount of other net income; (Article 71, Law on Corruption Prevention (2019))
Incompatibilities
Gifts received as a public official	Yes. Received occasional and protocol gifts shall become public property, in accordance with the law governing public property. Within eight days from the day of receiving an occasional or protocol gift and/or returning to the country, the public official shall hand over the gift to the public authority in which s/he discharges public office, and the public authority shall hand over the gift to the authority in charge of dealing with items that constitute public property. Exceptionally, a public official and his/her family member shall be entitled to retain a protocol or occasional gift whose value does not exceed 10% of the average monthly salary without taxes and contributions in the Republic of Serbia; the total value of gifts retained in the course of one calendar year cannot exceed the amount of one average monthly salary without taxes and contributions in the Republic of Serbia. Gifts retained by family members shall be included in the total value of the gifts a public official has retained within one calendar year. (Articles 59 and 60, Law on Corruption Prevention (2019))
Ownership of state-owned enterprises (SOEs)	Yes. Disclosure report shall contain information that includes shares and stakes in legal persons; data on legal persons if the public official holds there more than 3% of stakes or shares (Article 71, Law on Corruption Prevention (2019))
Holding government contracts	Yes. Public officials have to disclose within 3 days if a company of which they or their family members own a share greater than 20% participates in a procedure that would end with the signing of a government contract. (Article 53, Law on Corruption Prevention (2019))
Board member, advisor, or company officer of private firm	Yes. At the request of a public official the Agency may give consent to a public official to perform other work and/or business activity. Along with the request, the public official shall submit a positive opinion of the authority that had elected, appointed or nominated him/her to the public office. An appointed civil servant is obliged to submit, along with the request, the consent of his/her immediate superior. The Agency shall decide on a complete and properly filed request within 15 days from the day of its receipt. (Article 46, Law on Corruption Prevention (2019))
Post-employment	Yes. Prior to establishing an employment relationship and/or business cooperation referred to in paragraph 1 of this Article, a person whose public office has ceased shall request the consent of the Agency, which is obliged to decide on the request within 30 days. (Article 55, Law on Corruption Prevention (2019))
Simultaneously holding policy-making position and policy-executing position	Yes. Public officials are obliged to submit a disclosure report that includes other public functions, jobs or activities discharged in accordance with law and special regulations; (Article 71, Law on Corruption Prevention (2019))
Participating in official decision-making processes that affect private interests	Yes. On taking office and in the course of discharging public office, a public official shall notify in writing, without delay and no later than within a period of five days, his/her immediate superior and the Agency regarding any doubts concerning the existence of a conflict of interest, or his/her conflict of interest, or that of an associated person. (Article 42, Law on Corruption Prevention (2019))
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	Yes. Report must be filed within 30 days of taking the office (Article 68, Law on Corruption Prevention (2019))
Filing required upon leaving office	Yes. Report must be filed within 30 days of leaving the office (Article 68, Law on Corruption Prevention (2019))
Filing required annually	No. Only when significant changes of the property reported in the previous report occur. Changes are considered significant if their value exceeds average annual net income in the Republic of Serbia when there is a change to the structure of said assets. (Articles 69, Law on Corruption Prevention (2019))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. On taking office and in the course of discharging public office, a public official shall notify in writing, without delay and no later than within a period of five days, his/her immediate superior and the Agency regarding any doubts concerning the existence of a conflict of interest, or his/her conflict of interest, or that of an associated person. (Article 42, Law on Corruption Prevention (2019))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. For the late report filing an official can be fined with 50,000 to 150,000 RSD (Article 103, Law on Corruption Prevention (2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	Yes. Non-filing report of property is punishable with imprisonment from six month to five years. (Article 101, Law on Corruption Prevention (2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Providing false information on property is punishable with imprisonment from six month to five years. (Article 101, Law on Corruption Prevention (2019))
Monitoring and Oversight
Depository body explicitly identified	Yes. The Agency shall maintain the following records: 1) Register of Public Officials; 2) Register of Assets and Income of Public Officials; 3) Record of legal persons in which public officials or their family members have stakes or shares of more than 20%, that are participating in public procurement, privatisation or other procedures whose outcome is the conclusion of a contract with a public authority-budget user or another legal person in which more than 20% of the capital is owned by the Republic of Serbia, the autonomous province, a local self-government unit and a city municipality; 4) Catalog of Gifts. (Articles 100, Law on Corruption Prevention (2019))
Enforcement body explicitly identified	Yes. The Anti-Corruption Agency institutes proceedings and pronounces measures for violation of the Law, and rules on conflict of interest (Article 6, Law on Corruption Prevention (2019))
Some agency assigned responsibility for verifying submission	Yes. The Anti-Corruption Agency verifies the submissions of officials in cooperation with the state bodies where they serve. (Article 75, Law on Corruption Prevention (2019))
Some agency assigned responsibility for verifying accuracy	Yes. The Anti-Corruption Agency checks due filing of Report and accuracy and completeness of information. (Article 75, Law on Corruption Prevention (2019))
Public access to declarations
Public availability	Yes. The catalogue of gifts and information on the salary and the public functions of officials is public. (Articles 66 and 67, Law on Corruption Prevention (2019))
Timing of information release specified	Yes. The catalogue of gifts will be published by 1 June for the previous year. (Article 66, Law on Corruption Prevention (2019))
Location(s) of access specified	Yes. Public information will be posted on the Anti-Corruption Agency's web site. Once three years have elapsed from the termination of public office, data from the records, with the exception of those from the Catalog of Gifts, shall no longer be published on the website of the Agency. (Article 100, Law on Corruption Prevention (2019))
Cost of access specified	No. ů
Civil servants
Disclosure items
Spouses and children included in disclosure	Yes. Declaration report shall contain information on assets and income of his/her spouse or common law partner, as well as those of his/her underaged children if they live in the same family household, as at the day of election, appointment or nominationt. (Article 68, Law on Corruption Prevention (2019))
Income and Assets
Real estate	Yes. Declaration report shall contain information on permanent and temporary residence, the right to use an apartment for official purposes and the right of ownership or the right of lease on real property (Article 71, Law on Corruption Prevention (2019))
Movable assets	Yes. Disclosure report shall contain information concerning movable property subject to registration with the relevant authorities in the Republic of Serbia and abroad (motor vehicles, vessels, aircraft, weapons et al),; property rights on and movables of high value (valuables, art collections et al); rights deriving from copyright, patent and similar intellectual property rights. (Article 71, Law on Corruption Prevention (2019))
Cash	Yes. Disclosure report shall contain concerning property and income, including deposits in banks and other financial organisations, at home and abroad (Article 71, Law on Corruption Prevention (2019))
Loans and Debts	Yes. Disclosure report shall contain information that includes receivables and payables (principal, interest and period of repayment and maturity); (Article 71, Law on Corruption Prevention (2019))
Income from outside employment/assets	Yes. Disclosure report sahall contain information that includes source and amount of income from source and amount of net income the public official receives because s/he is discharging a public office and the source and amount of other net income s/he receives from the Budget and other public sources; source and amount of net income from other work or business activity; net income from scientific research, teaching, cultural, artistic, humanitarian or sports activities; income from copyright, patent and other intellectual property rights; source and amount of other net income; (Article 71, Law on Corruption Prevention (2019))
Incompatibilities
Gifts received as a public official	Yes. Received occasional and protocol gifts shall become public property, in accordance with the law governing public property. Within eight days from the day of receiving an occasional or protocol gift and/or returning to the country, the public official shall hand over the gift to the public authority in which s/he discharges public office, and the public authority shall hand over the gift to the authority in charge of dealing with items that constitute public property. Exceptionally, a public official and his/her family member shall be entitled to retain a protocol or occasional gift whose value does not exceed 10% of the average monthly salary without taxes and contributions in the Republic of Serbia; the total value of gifts retained in the course of one calendar year cannot exceed the amount of one average monthly salary without taxes and contributions in the Republic of Serbia. Gifts retained by family members shall be included in the total value of the gifts a public official has retained within one calendar year. (Articles 59 and 60, Law on Corruption Prevention (2019))
Ownership of state-owned enterprises (SOEs)	Yes. Disclosure report shall contain information that includes shares and stakes in legal persons; data on legal persons if the public official holds there more than 3% of stakes or shares (Article 71, Law on Corruption Prevention (2019))
Holding government contracts	Yes. Public officials have to disclose within 3 days if a company of which they or their family members own a share greater than 20% participates in a procedure that would end with the signing of a government contract. (Article 53, Law on Corruption Prevention (2019))
Board member, advisor, or company officer of private firm	Yes. At the request of a public official the Agency may give consent to a public official to perform other work and/or business activity. Along with the request, the public official shall submit a positive opinion of the authority that had elected, appointed or nominated him/her to the public office. An appointed civil servant is obliged to submit, along with the request, the consent of his/her immediate superior. The Agency shall decide on a complete and properly filed request within 15 days from the day of its receipt. (Article 46, Law on Corruption Prevention (2019))
Post-employment	Yes. Prior to establishing an employment relationship and/or business cooperation referred to in paragraph 1 of this Article, a person whose public office has ceased shall request the consent of the Agency, which is obliged to decide on the request within 30 days. (Article 55, Law on Corruption Prevention (2019))
Simultaneously holding policy-making position and policy-executing position	Yes. Public officials are obliged to submit a disclosure report that includes other public functions, jobs or activities discharged in accordance with law and special regulations; (Article 71, Law on Corruption Prevention (2019))
Participating in official decision-making processes that affect private interests	Yes. On taking office and in the course of discharging public office, a public official shall notify in writing, without delay and no later than within a period of five days, his/her immediate superior and the Agency regarding any doubts concerning the existence of a conflict of interest, or his/her conflict of interest, or that of an associated person. (Article 42, Law on Corruption Prevention (2019))
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	Yes. Report must be filed within 30 days of taking the office (Article 68, Law on Corruption Prevention (2019))
Filing required upon leaving office	Yes. Report must be filed within 30 days of leaving the office (Article 68, Law on Corruption Prevention (2019))
Filing required annually	No. Only when significant changes of the property reported in the previous report occur. Changes are considered significant if their value exceeds average annual net income in the Republic of Serbia when there is a change to the structure of said assets. (Articles 69, Law on Corruption Prevention (2019))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. On taking office and in the course of discharging public office, a public official shall notify in writing, without delay and no later than within a period of five days, his/her immediate superior and the Agency regarding any doubts concerning the existence of a conflict of interest, or his/her conflict of interest, or that of an associated person. (Article 42, Law on Corruption Prevention (2019))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. For the late report filing an official can be fined with 50,000 to 150,000 RSD (Article 103, Law on Corruption Prevention (2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	Yes. Non-filing report of property is punishable with imprisonment from six month to five years. (Article 101, Law on Corruption Prevention (2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Providing false information on property is punishable with imprisonment from six month to five years. (Article 101, Law on Corruption Prevention (2019))
Monitoring and Oversight
Depository body explicitly identified	Yes. The Agency shall maintain the following records: 1) Register of Public Officials; 2) Register of Assets and Income of Public Officials; 3) Record of legal persons in which public officials or their family members have stakes or shares of more than 20%, that are participating in public procurement, privatisation or other procedures whose outcome is the conclusion of a contract with a public authority-budget user or another legal person in which more than 20% of the capital is owned by the Republic of Serbia, the autonomous province, a local self-government unit and a city municipality; 4) Catalog of Gifts. (Articles 100, Law on Corruption Prevention (2019))
Enforcement body explicitly identified	Yes. The Anti-Corruption Agency institutes proceedings and pronounces measures for violation of the Law, and rules on conflict of interest (Article 6, Law on Corruption Prevention (2019))
Some agency assigned responsibility for verifying submission	Yes. The Anti-Corruption Agency verifies the submissions of officials in cooperation with the state bodies where they serve. (Article 75, Law on Corruption Prevention (2019))
Some agency assigned responsibility for verifying accuracy	Yes. The Anti-Corruption Agency checks due filing of Report and accuracy and completeness of information. (Article 75, Law on Corruption Prevention (2019))
Public access to declarations
Public availability	Yes. The catalogue of gifts and information on the salary and the public functions of officials is public. (Articles 66 and 67, Law on Corruption Prevention (2019))
Timing of information release specified	Yes. The catalogue of gifts will be published by 1 June for the previous year. (Article 66, Law on Corruption Prevention (2019))
Location(s) of access specified	Yes. Public information will be posted on the Anti-Corruption Agency's web site. Once three years have elapsed from the termination of public office, data from the records, with the exception of those from the Catalog of Gifts, shall no longer be published on the website of the Agency. (Article 100, Law on Corruption Prevention (2019))
Cost of access specified	No. ů

Legislation

Law on Prevention of Corruption of 2019_SER (Serbian)

*Last update: 2017

Conflict of Interest

For all Serbian public officials, the Anti-Corruption Agency Act (2008, amended in 2010) lays down that conflicts of interests must generally be avoided. Additionally, the Constitution (2006) prevents the Head of State from performing any other professional duty. For Ministers, Members of Parliament and Civil Servants accepting gifts or following additional employment in the private sector is not allowed. This would include the ownership of private and public enterprises, board membership, or privately playing part in performing government contracts. All public officials are prevented from pursuing employment with an organization they cooperated with in their functions in the two years after ending tenure. Only for the Head of State and Ministers is it specified that they may not use public office to bring about personal benefits for themselves or associated persons.

Violation of the laws governing conflicts of interests can lead to a fine from RSD 50,000 to 150,000, as well as possible expulsion from office. These sanctions apply to all public officials. All the while, no monitoring or enforcement body is specified for the Head of State. Meanwhile, the Anti-Corruption Agency is charged with providing guidance and enforcing sanctions for Ministers, MPs, and Civil Servants.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Restrictions	73	40	40	40	68	75
Sanctions	33	33	33	0	33	100
Monitoring and Oversight	25	88	88	62	100	100
Alternative Metric	2012	2015	2016	2017	2020	2024	Trend
Head of State	27	44	44	0	68	90
Ministers	46	61	61	50	64	93
Members of Parliament	40	41	41	30	68	90
Civil servants	62	68	68	57	68	93

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Head of State
Restrictions
General restriction on conflict of interest	Yes. No person may perform a state or public function in conflict with their other functions, occupation or private interests. The President of the Republic is obliged to comply in all respects with the regulations governing conflicts of interest in the performance of public functions. A public official (here included the President) is obliged not to subordinate the public interest to the private one, to adhere to the regulations that regulate his rights and obligations, and to create and maintain the trust of citizens in the conscientious and responsible performance of the public function. A public official must not be dependent on persons who could affect his or her impartiality, nor use a public office for the purpose of gaining any benefit or convenience for himself or a related person. A public official is prohibited from using, for the purpose of gaining benefits or benefits to himself or others or harming others, information obtained in a public office, if they are not available to the public. (Constitution of the Republic of Serbia of 2006 (as of 2020), Art. 6 Presidential Act (as of 2020), Art. 9 Law on Prevention of Corruption of 2019 (as of 2020), Arts. 2 (3) and 40)
Accepting gifts	Yes. A gift is a thing, right or service, given or done without appropriate compensation, or a benefit or convenience done to a public official or family member. A public official and a family member may not receive a gift in connection with the performance of a public function, except for a protocol and occasional gift. A public official is obliged to inform the public authority in which s/he is in public office in writing about every gift received in connection with the performance of a public function, within ten days from the day of receiving the gift, ie from returning to the country. (Law on Prevention of Corruption of 2019 (as of 2020), Arts. 58-66)
Private firm ownership and/or stock holdings	Yes. A public official who at the time of election or appointment to public office has, or who during the time in public office acquires shares in a company, on the basis of which he has management rights, is obliged to within 30 days from the day of election or appointment, ie the acquisition of shares or stocks, transfer his/her management rights in the company to a legal or natural person, so that that person, in his own name and on behalf of a public official, exercises them until the termination of public office. The public official is obliged to submit to the company and the Agency data on the person to whom he transferred management rights and evidence on the transfer of management rights which he registered in accordance with the law governing the registration of business entities, within 15 days from the day of transfer. A public official who has or acquires up to 3% of shares in a company is not obliged to transfer management rights. However, this provision does not apply to a public official who is prohibited by a special law from owning shares, stocks and other securities in certain companies. (Law on Prevention of Corruption of 2019 (as of 2020), Arts. 51, 52, 71 (18) (19) and 73 (8) (9))
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	Yes. A legal entity in which a public official or a family member owns shares of more than 20%, during their time in public office and two years after its termination, and which participates in a public procurement or privatization procedure, or other procedure resulting in concluding a contract with a public authority, another budget user or other legal entity in which more than 20% of the capital is owned by the Republic of Serbia, autonomous province, local self-government unit or city municipality, is obliged to submit to the Agency information on the contract, within 15 days of the end of the procedure. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 53)
Board member, advisor, or company officer of private firm	Yes. The President of the Republic may not perform another public function or professional duty. (Constitution of the Republic of Serbia of 2006 (as of 2020), Art. 115)
Post-employment	No. Generally, a person whose public office has ceased may not establish, for two years after the termination of public office, an employment relationship, ie business cooperation with a legal entity, entrepreneur or international organization performing activities related to the public office performed by a public official, except with the obtained consent from the Agency. However, this restriction does not apply to a public official elected directly by the citizen, which is the case of the President. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 55 Constitution of the Republic of Serbia of 2006 (as of 2020), Art. 114)
Simultaneously holding policy-making position and policy-executing position	Yes. The President of the Republic may not perform another public function or professional duty. (Constitution of the Republic of Serbia of 2006 (as of 2020), Art. 115)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Assisting family or friends in obtaining employment in public sector	Yes. A public official must not be dependent on persons who could affect his or her impartiality, nor use a public office for the purpose of gaining any benefit or convenience for himself or a related person. A public official is prohibited from using, for the purpose of gaining benefits or benefits to himself or others or harming others, information obtained in a public office, if they are not available to the public. (Law on Prevention of Corruption of 2019 (as of 2020), Arts. 2 (3) and 40)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. A fine in the amount of 50,000 to 150,000 dinars shall be imposed on a public official for a misdemeanor if s/he: 1) does not respond to the invitation of the Agency (Article 37); 2) fails to notify the Agency within the prescribed time limit of suspicion of the existence of a conflict of interest that he or a person related to him has (Article 42, paragraph 1); 3) fails to notify the Agency within the prescribed time limit on the performance of another job or activity (Article 45, paragraph 1); 4)performs another job or activity contrary to Article 46; 5) advises legal and natural persons contrary to Article 47 of this Law; 6) during the performance of a public function, establishes a company, ie a public service or starts performing independent activity (Article 48, paragraph 1); 7) during the performance of a public function, becomes a representative or a member of the body of a legal entity in private ownership or exercises management rights (Article 48, paragraph 2); 8) becomes a member or representative of an association contrary to Article 49; 9) fails to transfer management rights within the prescribed time limit (Article 51, paragraph 1); 10) fails to submit data to the Agency within the prescribed time limit (Article 51, paragraph 2); 11) performs another public function contrary to Article 56; 12) receives a gift contrary to Article 58; 13) fails to submit an appropriate or protocol gift within the prescribed time limit (Article 59, paragraph 4); 15) retains ownership of a protocol or occasional gift contrary to Article 60; 16) fails to notify the public authority of the received gift in the prescribed manner and within the prescribed time limit (Article 62); 17) fails to report property and income within the prescribed time limit (Articles 68 and 69). A fine of 100,000 to 150,000 dinars shall be imposed on a public official for a misdemeanor if he performs a function in a political party. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 103)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	Yes. A measure of reprimand or a measure of public announcement of a recommendation for dismissal from public office may be imposed on a public official who has breached conflict of interest regulations. However, a public official elected directly by citizens, which is the President's case, may only be issued a warning or a measure of public announcement of the decision on violation of this Law. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 82)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	Yes. A public official who, contrary to the provisions of the Law, does not report property to the Agency or provides false information about property, in order to conceal information about property, shall be punished by imprisonment for a term between six months and five years. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 101)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	Yes. Agency for the Prevention of Corruption. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 6 (9) (14) (15))
Enforcement body specified (sanctions, hearings)	Yes. Agency for the Prevention of Corruption. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 6 (4) (6))
Ministers
Restrictions
General restriction on conflict of interest	Yes. A public official (here included Members of Government, i.e. Ministers) is obliged not to subordinate the public interest to the private one, to adhere to the regulations that regulate his rights and obligations, and to create and maintain the trust of citizens in the conscientious and responsible performance of the public function. A public official must not be dependent on persons who could affect his or her impartiality, nor use a public office for the purpose of gaining any benefit or convenience for himself or a related person. A public official is prohibited from using, for the purpose of gaining benefits or benefits to himself or others or harming others, information obtained in a public office, if they are not available to the public. (Law on Prevention of Corruption of 2019 (as of 2020), Arts. 2 (3) and 40)
Accepting gifts	Yes. A gift is a thing, right or service, given or done without appropriate compensation, or a benefit or convenience done to a public official or family member. A public official and a family member may not receive a gift in connection with the performance of a public function, except for a protocol and occasional gift. A public official is obliged to inform the public authority in which s/he is in public office in writing about every gift received in connection with the performance of a public function, within ten days from the day of receiving the gift, ie from returning to the country. (Law on Prevention of Corruption of 2019 (as of 2020), Arts. 58-66)
Private firm ownership and/or stock holdings	Yes. A public official who at the time of election or appointment to public office has, or who during the time in public office acquires shares in a company, on the basis of which he has management rights, is obliged to within 30 days from the day of election or appointment, ie the acquisition of shares or stocks, transfer his/her management rights in the company to a legal or natural person, so that that person, in his own name and on behalf of a public official, exercises them until the termination of public office. The public official is obliged to submit to the company and the Agency data on the person to whom he transferred management rights and evidence on the transfer of management rights which he registered in accordance with the law governing the registration of business entities, within 15 days from the day of transfer. A public official who has or acquires up to 3% of shares in a company is not obliged to transfer management rights. However, this provision does not apply to a public official who is prohibited by a special law from owning shares, stocks and other securities in certain companies. (Law on Prevention of Corruption of 2019 (as of 2020), Arts. 51, 52, 71 (18) (19) and 73 (8) (9))
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	Yes. A legal entity in which a public official or a family member owns shares of more than 20%, during their time in public office and two years after its termination, and which participates in a public procurement or privatization procedure, or other procedure resulting in concluding a contract with a public authority, another budget user or other legal entity in which more than 20% of the capital is owned by the Republic of Serbia, autonomous province, local self-government unit or city municipality, is obliged to submit to the Agency information on the contract, within 15 days of the end of the procedure. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 53)
Board member, advisor, or company officer of private firm	Yes. A public official may not be a member of the body of an association, nor its representative, if there is a relationship of dependence or other relationship between the public office and membership in the body of the association or representation of the association or endangers or could endanger its impartiality or reputation of public office. Additionally, a public official may not perform other work or activity during the performance of a public function that requires full-time or permanent work. If it determines that the performance of work previously allowed (in scientific research, teaching, cultural, artistic, humanitarian and sports activities), endangers the impartial performance or reputation of a public function, ie that it represents a conflict of interest, the Agency shall set a deadline within which the public official is obliged to cease performing that work or activity. (Law on Prevention of Corruption of 2019 (as of 2020), Arts. 46 and 49)
Post-employment	Yes. A person whose public office has ceased may not establish, for two years after the termination of public office, an employment relationship, ie business cooperation with a legal entity, entrepreneur or international organization performing activities related to the public office performed by a public official, except with the obtained consent from the Agency. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 55)
Simultaneously holding policy-making position and policy-executing position	Yes. A Member of the Government may not be a deputy in the National Assembly, deputy in the Assembly of the autonomous province and representative in the Assembly of the local self-government units, nor may he or she be a member of the executive council of the autonomous province or executive body of the local self-government unit. (Constitution of the Republic of Serbia of 2006 (as of 2020), Art. 126)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Assisting family or friends in obtaining employment in public sector	Yes. A public official must not be dependent on persons who could affect his or her impartiality, nor use a public office for the purpose of gaining any benefit or convenience for himself or a related person. A public official is prohibited from using, for the purpose of gaining benefits or benefits to himself or others or harming others, information obtained in a public office, if they are not available to the public. (Law on Prevention of Corruption of 2019 (as of 2020), Arts. 2 (3) and 40)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. A fine in the amount of 50,000 to 150,000 dinars shall be imposed on a public official for a misdemeanor if s/he: 1) does not respond to the invitation of the Agency (Article 37); 2) fails to notify the Agency within the prescribed time limit of suspicion of the existence of a conflict of interest that he or a person related to him has (Article 42, paragraph 1); 3) fails to notify the Agency within the prescribed time limit on the performance of another job or activity (Article 45, paragraph 1); 4)performs another job or activity contrary to Article 46; 5) advises legal and natural persons contrary to Article 47 of this Law; 6) during the performance of a public function, establishes a company, ie a public service or starts performing independent activity (Article 48, paragraph 1); 7) during the performance of a public function, becomes a representative or a member of the body of a legal entity in private ownership or exercises management rights (Article 48, paragraph 2); 8) becomes a member or representative of an association contrary to Article 49; 9) fails to transfer management rights within the prescribed time limit (Article 51, paragraph 1); 10) fails to submit data to the Agency within the prescribed time limit (Article 51, paragraph 2); 11) performs another public function contrary to Article 56; 12) receives a gift contrary to Article 58; 13) fails to submit an appropriate or protocol gift within the prescribed time limit (Article 59, paragraph 4); 15) retains ownership of a protocol or occasional gift contrary to Article 60; 16) fails to notify the public authority of the received gift in the prescribed manner and within the prescribed time limit (Article 62); 17) fails to report property and income within the prescribed time limit (Articles 68 and 69). A fine of 100,000 to 150,000 dinars shall be imposed on a public official for a misdemeanor if he performs a function in a political party. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 103)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	Yes. A measure of reprimand or a measure of public announcement of a recommendation for dismissal from public office may be imposed on a public official who has breached conflict of interest regulations. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 82)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	Yes. A public official who, contrary to the provisions of the Law, does not report property to the Agency or provides false information about property, in order to conceal information about property, shall be punished by imprisonment for a term between six months and five years. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 101)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	Yes. Agency for the Prevention of Corruption. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 6 (9) (14) (15))
Enforcement body specified (sanctions, hearings)	Yes. Agency for the Prevention of Corruption. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 6 (4) (6))
Members of Parliament
Restrictions
General restriction on conflict of interest	Yes. A Member of Parliament may not perform the function of a deputy or use the advantages of the function in order to achieve benefits or advantages for himself or a related person. (Code of Conduct for Members of Parliament of 2020, Art. 10 Law on Prevention of Corruption of 2019 (as of 2020), Arts. 2 (3) and 40)
Accepting gifts	Yes. A Member of Parliament shall not request or receive, ie allow another person to receive a gift in his/her name or in his/her favor in connection with the performance of the parliamentary function, except for appropriate and protocol gifts of a certain value, given in accordance with usual protocol courtesy. The Member of Parliament is obliged to inform the Speaker of the National Assembly of any gift received in connection with the performance of the parliamentary function, as well as to hand over the gift, which exceeds the value determined by law, to the Speaker of the National Assembly. (Code of Conduct for Members of Parliament of 2020, Art. 16 Law on Prevention of Corruption of 2019 (as of 2020), Arts. 58-66)
Private firm ownership and/or stock holdings	Yes. A public official who at the time of election or appointment to public office has, or who during the time in public office acquires shares in a company, on the basis of which he has management rights, is obliged to within 30 days from the day of election or appointment, ie the acquisition of shares or stocks, transfer his/her management rights in the company to a legal or natural person, so that that person, in his own name and on behalf of a public official, exercises them until the termination of public office. The public official is obliged to submit to the company and the Agency data on the person to whom he transferred management rights and evidence on the transfer of management rights which he registered in accordance with the law governing the registration of business entities, within 15 days from the day of transfer. A public official who has or acquires up to 3% of shares in a company is not obliged to transfer management rights. However, this provision does not apply to a public official who is prohibited by a special law from owning shares, stocks and other securities in certain companies. (Law on Prevention of Corruption of 2019 (as of 2020), Arts. 51, 52, 71 (18) (19) and 73 (8) (9))
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	Yes. A legal entity in which a public official or a family member owns shares of more than 20%, during their time in public office and two years after its termination, and which participates in a public procurement or privatization procedure, or other procedure resulting in concluding a contract with a public authority, another budget user or other legal entity in which more than 20% of the capital is owned by the Republic of Serbia, autonomous province, local self-government unit or city municipality, is obliged to submit to the Agency information on the contract, within 15 days of the end of the procedure. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 53)
Board member, advisor, or company officer of private firm	Yes. A Member of Parliament may not simultaneously perform another public function or professional activity incompatible with the parliamentary function, in accordance with the Constitution and the law. A function that is incompatible with the function of a deputy on the day of confirmation of the deputy mandate shall cease. Additionally, aa public official may not be a member of the body of an association, nor its representative, if there is a relationship of dependence or other relationship between the public office and membership in the body of the association or representation of the association or endangers or could endanger its impartiality or reputation of public office. (Constitution of the Republic of Serbia of 2006 (as of 2020), Art. 110 Law on the National Assembly of 2010 (as of 2020), Art. 39 Law on Prevention of Corruption of 2019 (as of 2020), Arts. 46 and 49)
Post-employment	No. Generally, a person whose public office has ceased may not establish, for two years after the termination of public office, an employment relationship, ie business cooperation with a legal entity, entrepreneur or international organization performing activities related to the public office performed by a public official, except with the obtained consent from the Agency. However, this restriction does not apply to a public official elected directly by the citizen, which is the case of Members of Parliament. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 55 Constitution of the Republic of Serbia of 2006 (as of 2020), Art. 100)
Simultaneously holding policy-making position and policy-executing position	Yes. A Deputy may not be a deputy in the Assembly of the autonomous province, nor an official in bodies of executive government and judiciary, nor may he or she perform other functions, affairs and duties, which represent a conflict of interest, according to the Law. (Constitution of the Republic of Serbia of 2006 (as of 2020), Art. 102)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Assisting family or friends in obtaining employment in public sector	Yes. A public official must not be dependent on persons who could affect his or her impartiality, nor use a public office for the purpose of gaining any benefit or convenience for himself or a related person. A public official is prohibited from using, for the purpose of gaining benefits or benefits to himself or others or harming others, information obtained in a public office, if they are not available to the public. (Law on Prevention of Corruption of 2019 (as of 2020), Arts. 2 (3) and 40)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. A fine in the amount of 50,000 to 150,000 dinars shall be imposed on a public official for a misdemeanor if s/he: 1) does not respond to the invitation of the Agency (Article 37); 2) fails to notify the Agency within the prescribed time limit of suspicion of the existence of a conflict of interest that he or a person related to him has (Article 42, paragraph 1); 3) fails to notify the Agency within the prescribed time limit on the performance of another job or activity (Article 45, paragraph 1); 4)performs another job or activity contrary to Article 46; 5) advises legal and natural persons contrary to Article 47 of this Law; 6) during the performance of a public function, establishes a company, ie a public service or starts performing independent activity (Article 48, paragraph 1); 7) during the performance of a public function, becomes a representative or a member of the body of a legal entity in private ownership or exercises management rights (Article 48, paragraph 2); 8) becomes a member or representative of an association contrary to Article 49; 9) fails to transfer management rights within the prescribed time limit (Article 51, paragraph 1); 10) fails to submit data to the Agency within the prescribed time limit (Article 51, paragraph 2); 11) performs another public function contrary to Article 56; 12) receives a gift contrary to Article 58; 13) fails to submit an appropriate or protocol gift within the prescribed time limit (Article 59, paragraph 4); 15) retains ownership of a protocol or occasional gift contrary to Article 60; 16) fails to notify the public authority of the received gift in the prescribed manner and within the prescribed time limit (Article 62); 17) fails to report property and income within the prescribed time limit (Articles 68 and 69). A fine of 100,000 to 150,000 dinars shall be imposed on a public official for a misdemeanor if he performs a function in a political party. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 103)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	Yes. The following measures may be imposed for non-compliance with the Code of Conduct for Members of Parliament: reprimand and public reprimand. The public reprimand is published on the website of the National Assembly, for a period of 30 days. (Code of Conduct for Members of Parliament of 2020, Art. 31 Law on Prevention of Corruption of 2019 (as of 2020), Art. 82)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	Yes. A public official who, contrary to the provisions of the Law, does not report property to the Agency or provides false information about property, in order to conceal information about property, shall be punished by imprisonment for a term between six months and five years. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 101)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	Yes. Agency for the Prevention of Corruption. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 6 (9) (14) (15))
Enforcement body specified (sanctions, hearings)	Yes. The Committee on Administrative-Budgetary and Mandate-Immunity Issues supervises the application of the Code, except for the provisions relating to the obligation to declare the private interests of deputies, compliance with regulations restricting the simultaneous performance of two or more functions, prohibition of gifts and prohibiting the use of the function for the purpose of obtaining benefits or conveniences for oneself or a related party. The Committee makes a decision on the violation of the Code, if it is determined that there is a violation of its provisions, and imposes the prescribed measure. The Committee is obliged to decide within 30 days from the day of submitting the application, and the decision is final. (Code of Conduct for Members of Parliament of 2020, Arts. 27 and 30)
Civil servants
Restrictions
General restriction on conflict of interest	Yes. Conflict of interest is a situation in which a civil servant has a private interest that affects, may affect or appears to affect his/her conduct in the performance of his/her duties, in a manner that endangers the public interest. The private interest of a civil servant is any benefit or convenience for the civil servant or a person related to him/her. A civil servant is obliged to do everything in his power to avoid any situation of conflict of interest, and if such a situation could not be avoided, the provisions of the law on conflict of interest management shall apply. In the performance of his/her duties, a civil servant must not allow his/her private interest to come into conflict with the public interest. S/he is obliged to take into account the actual or possible conflicts of interest and to take measures provided by law in order to avoid it. (Code of Conduct for Civil Servants of 2008 (as of 2020), Art. 7 Law on Civil Servants of 2005 (as of 2020), Art. 25 Law on Prevention of Corruption of 2019 (as of 2020), Arts. 2 (3) and 40 )
Accepting gifts	Yes. A civil servant may not receive a gift, or any service or other benefit for himself or other persons in the performance of his duties, except for a protocol or occasional gift of lesser value in accordance with the regulations governing the prevention of conflicts of interest in the performance of public functions. If a civil servant is offered a gift or some other benefit, s/he is obliged to refuse the gift or other benefit, ie return the handed gift, to take actions to identify the person and, if possible, find witnesses and immediately, and no later than within 24 hours, make an official note and inform the immediate superior. For each gift, the public official is obliged to submit a notification on the received gift to the public authority in which he is in public office, within ten days from the day of receiving the gift, ie from returning to the country. The public official submits a notification about the received gift and when the gift was received by a family member. (Code of Conduct for Civil Servants of 2008 (as of 2020), Art. 9 Law on Civil Servants of 2005 (as of 2020), Art. 25a Ordinance on Gifts of Public Officials of 2020 Law on Prevention of Corruption of 2019 (as of 2020), Arts. 58-66)
Private firm ownership and/or stock holdings	Yes. A civil servant may not establish a company, public service, or engage in entrepreneurship. The regulations governing the prevention of conflicts of interest in the performance of public functions shall apply to the transfer of management rights in an economic entity to another person. A civil servant is obliged to submit data on the person to whom management rights were transferred, and evidence of their transfer to the manager, and the Anti-Corruption Agency is obliged to publish the data on its website. (Law on Civil Servants of 2005 (as of 2020), Art. 28 Law on Employees in the Public Service of 2017 (as of 2020), Arts. 29 and 143 (9) Law on Prevention of Corruption of 2019 (as of 2020), Arts. 51, 52, 71 (18) (19) and 73 (8) (9))
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	Yes. A legal entity in which a public official or a family member owns shares of more than 20%, during their time in public office and two years after its termination, and which participates in a public procurement or privatization procedure, or other procedure resulting in concluding a contract with a public authority, another budget user or other legal entity in which more than 20% of the capital is owned by the Republic of Serbia, autonomous province, local self-government unit or city municipality, is obliged to submit to the Agency information on the contract, within 15 days of the end of the procedure. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 53)
Board member, advisor, or company officer of private firm	Yes. A civil servant may not be a director, deputy or assistant director of a legal entity, and a member of the management board, supervisory board or other management body of a legal entity, unless appointed as such by the Government or another state body. A civil servant may be a member of the association's body. The civil servant is obliged to inform the head of unit about membership in bodies of legal entities, ie associations, within five days from the day of appointment to the body. The state body shall keep records on the membership of civil servants in these bodies. (Law on Civil Servants of 2005 (as of 2020), Art. 29 Law on Prevention of Corruption of 2019 (as of 2020), Arts. 46 and 49 )
Post-employment	Yes. A person whose public office has ceased may not establish, for two years after the termination of public office, an employment relationship, ie business cooperation with a legal entity, entrepreneur or international organization performing activities related to the public office performed by a public official, except with the obtained consent from the Agency. (Law on Prevention of Corruption of 2019 (as of 2020), Art. 55)
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework.
Participating in official decision-making processes that affect private interests	Yes. The civil servant is obliged to, immediately upon learning, and no later than the first following working day, report in writing to the immediate supervisor the existence of a private interest in connection with the performance of certain tasks, ie the relationship of dependence in connection with the performance of certain tasks with the association of which he is a member, and to refrain from further activities that may jeopardize the public interest, until the manager appoints another civil servant to perform those tasks. (Law on Civil Servants of 2005 (as of 2020), Art. 30)
Assisting family or friends in obtaining employment in public sector	Yes. A public official must not be dependent on persons who could affect his or her impartiality, nor use a public office for the purpose of gaining any benefit or convenience for himself or a related person. A public official is prohibited from using, for the purpose of gaining benefits or benefits to himself or others or harming others, information obtained in a public office, if they are not available to the public. (Law on Prevention of Corruption of 2019 (as of 2020), Arts. 2 (3) and 40)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. For minor violations of duties from employment, a reprimand or a fine of up to 20% of the full-time salary for the month in which the fine was imposed, may be imposed. For serious violations of duties from employment, the following may be imposed: 1) a fine of 20% to 30% of the civil servant's basic salary, for the month in which the fine was imposed, for a period of up to six months; 2) determination of the immediately lower salary grade; 3) ban on promotion for four years; 4) transfer to a job in the immediately lower title with the determination of the coefficient in accordance with the law governing salaries in state bodies; 5) termination of employment. A fine is always enforced administratively. (Law on Civil Servants of 2005 (as of 2020), Arts. 31 and 110)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	Yes. A measure of reprimand or a measure of public announcement of a recommendation for dismissal from public office may be imposed on a public official who has breached conflict of interest regulations. (Law on Civil Servants of 2005 (as of 2020), Arts. 31, 107-109 and 110 Law on Prevention of Corruption of 2019 (as of 2020), Art. 82)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	Yes. A public official who, contrary to the provisions of the Law, does not report property to the Agency or provides false information about property, in order to conceal information about property, shall be punished by imprisonment for a term between six months and five years. (Law on Civil Servants of 2005 (as of 2020), Art. 31 Law on Prevention of Corruption of 2019 (as of 2020), Art. 101)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	Yes. High Civil Service Council and Agency for the Prevention of Corruption. (Code of Conduct for Civil Servants of 2008 (as of 2020), Art. 18a, 18b and 18c Law on Prevention of Corruption of 2019 (as of 2020), Art. 6 (9) (14) (15))
Enforcement body specified (sanctions, hearings)	Yes. Disciplinary proceedings are initiated by the manager, on his/her own initiative or at the suggestion of a person who is superior to a civil servant. Additionally, the Agency for the Prevention of Corruption may be competent to enforce specific measures. (Law on Civil Servants of 2005 (as of 2020), Art. 112 Law on Prevention of Corruption of 2019 (as of 2020), Art. 6 (4) (6))

Legislation

Constitution of the Republic of Serbia of 2006 (Serbian)	pdf
Presidential Act (Serbian)	pdf
Law on Prevention of Corruption of 2019 (Serbian)	pdf
Code of Conduct for Members of Parliament of 2020 (Serbian)	pdf
Law on the National Assembly of 2010 (Serbian)	pdf
Law on Civil Servants of 2005 (Serbian)	pdf
Code of Conduct for Civil Servants of 2008 (Serbian)	pdf
Ordinance on Gifts of Public Officials of 2020 (Serbian)	pdf
Law on Employees in the Public Service of 2017 (Serbian)	pdf

*Last update: 2017

Freedom of Information

Serbia's FOI framework derives from both its Constitution (2006) and from the Law on Free Access to Information of Public Importance (2004, amended 2010). The FOI law applies to central government bodies, territorial autonomy bodies, local self-government bodies or organizations vested with public powers, and a legal entity founded by or funded by a government body.

Specific exemptions to disclosure are outlined in the aforementioned FOI law, Law on Secrecy of Data (2009), and Law on the Protection of Personal Data (2008). However, there is a public interest test whereby exemptions to disclosure may be overridden in cases where the public interest outweighs the prohibition on disclosure.

Appeals may be filed with public authorities and with the courts. An applicant may also lodge a complaint with the Commissioner for Information of Public Importance.

Monetary fines may be imposed on individuals for the failure to provide information. While the implementation process is supervised by the Ministry responsible for administrative affairs, the Commissioner monitors compliance, reports to the public and the National Assembly, makes motions to draft or amend regulations, proposes measures to improve operations, and trains employees of government bodies.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024
Scope and Coverage	100	100	100	100	100	100
Information access and release	88	88	88	88	88	100
Exceptions and Overrides	67	67	67	67	67	100
Sanctions for non-compliance	33	33	33	33	33	33
Monitoring and Oversight	33	33	33	33	33	83

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Scope and Coverage
Scope of disclosure
Existence of legal right to access	Yes. Everyone shall have the right to access information kept by state bodies and organizations with delegated public powers, in accordance with the law. (Article 51 Constitution of the Republic of Serbia, 2006)
"Information" or "Documents" is defined	Yes. Information of public importance, within the meaning of this Law, is information held by a public authority body, created during or relating to the operation of a public authority body, which is contained in a document and concerns anything the public has a justified interest to know. For information to be considered information of public importance, it shall be irrelevant whether the source of information is a public authority or another person, which medium carries the document containing the information (paper, tape, film, electronic media, etc.), on which date the information was created or in which way the information was obtained, nor shall any other similar properties of such information bear any relevance for this purpose. (Article 2 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Proactive disclosure is specified	Yes. Article 39 The authority referred to in Article 3, item 1) to 7) of this law prepares an informant about his work, which contains in particular: 1) basic data about the authority and the informant (including working hours and information on the accessibility of facilities used by the authority to persons with disabilities); 2) organizational structure (organization chart); 3) names, contact information and description of functions of organizational unit managers; 4) description of the rules regarding the publicity of the work; 5) description of competences, authorizations and obligations; 6) description of actions within the scope of competence, authority and obligations; 7) for collegial bodies, data on held sessions and description of decision-making methods; 8) listing the regulations that the body applies in its work and the regulations for the adoption of which it is competent; 9) specifying strategies, programs, plans and reports adopted by the authority; 10) listing the acts from point. 8) and 9) of this paragraph which are in the process of preparation by the authorities; 11) list of services that the authority provides to interested persons; 12) procedure for the provision of services from item 11) of this paragraph; 13) review of data on the services provided from point 11) of this paragraph; 14) financial data (data on the budget, ie financial plan and sources of income); 15) data on public procurement, including the plan of public procurement and the list of concluded contracts on the procurement of goods, services, works and real estate, with the value of the concluded contracts, the date of conclusion and the term of validity; 16) data on state aid (with data on subjects of subsidies and donations and their amounts); 17) data on performed inspections and audits of the organization's operations; 18) data on paid salaries, wages and other income, including data on salaries of management bodies, i.e. management and heads of organizational units; 19) data on means of work and facilities that the body owns or uses; 20) storage of information carriers; 21) types of information in possession, including the contents of databases and registers handled by the authority; 22) types of information to which the authority provides access; 23) list of the most frequently requested information of public importance; 24) information on submitting a request, with addresses for receiving mail and electronic mail and data on deadlines for processing the request, the right to a legal remedy and the person responsible for processing the request. (Article 39 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Coverage of public and private sectors
Executive branch	Yes. A public authority body within the meaning of this Law (hereinafter referred to as public authority) shall mean: 1) A central government body, a territorial autonomy body, a local self-government body or an organization vested with public powers (hereinafter referred to as government body); 2) A legal entity founded by or fully or predominantly funded by a government body. (Article 3 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Legislative branch	Yes. A public authority body within the meaning of this Law (hereinafter referred to as public authority) shall mean: 1) A central government body, a territorial autonomy body, a local self-government body or an organization vested with public powers (hereinafter referred to as government body); 2) A legal entity founded by or fully or predominantly funded by a government body. (Article 3 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Judicial branch	Yes. A public authority body within the meaning of this Law (hereinafter referred to as public authority) shall mean: 1) A central government body, a territorial autonomy body, a local self-government body or an organization vested with public powers (hereinafter referred to as government body); 2) A legal entity founded by or fully or predominantly funded by a government body. (Article 3 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Other public bodies	Yes. A public authority body within the meaning of this Law (hereinafter referred to as public authority) shall mean: 1) A central government body, a territorial autonomy body, a local self-government body or an organization vested with public powers (hereinafter referred to as government body); 2) A legal entity founded by or fully or predominantly funded by a government body. (Article 3 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Private sector	Yes. The public authority (hereinafter: authority) in the sense of this law is: 1) an authority of the Republic of Serbia; 2) an autonomous province body; 3) authority of the municipality, city, city municipality and the city of Belgrade; 4) public company, institution, organization and other legal entity, which was established by regulation or decision of the authority referred to in point. 1) to 3) of this paragraph; 5) a business company whose founder or member is the Republic of Serbia, an autonomous province, a local self-government unit, or one or more authorities from point 1) to 4) of this paragraph with 50% or more shares or shares in total, that is, with more than half of the members of the management body; 6) a business company whose founder or member is one or more authorities from item no. 1) to 5) of this paragraph with 50% or more shares or shares in total; 7) a legal entity whose founder is a business company from item no. 5) or 6) of this paragraph; 8) a legal entity or an entrepreneur who performs activities of general interest, in the sense of the law regulating the position of public companies, in relation to information related to the performance of those activities; 9) a legal or natural person who has public powers, in relation to information related to the exercise of those powers; 10) a legal entity that, in the year to which the requested information relates, generated more than 50% of the income from one or more authorities from point 1) to 7) of this paragraph, in relation to the information related to the activity financed by those revenues, with the exception of the church and religious community. (Article 3 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Access to specific documents (subject to reactive and/or proactive disclosure)
Draft legal instruments	Yes. The Government work shall be public. The Government shall be obliged to enable public insight into its work, according to a law governing free access to information of public importance and the Government Rules of Procedure. (Article 9 of the Law on Government, 2005, amended 2018)
Enacted legal instruments	Yes. The Government work shall be public. The Government shall be obliged to enable public insight into its work, according to a law governing free access to information of public importance and the Government Rules of Procedure. The President of the Republic is obliged to issue a decree on promulgation of the laws. (Article 9 of the Law on Government, 2005, amended 2018 Article 113 of the Constitution of the Republic of Serbia, 2006)
Annual budgets	Yes. Information of public importance, within the meaning of this Law, is information held by a public authority body, created during or relating to the operation of a public authority body, which is contained in a document and concerns anything the public has a justified interest to know. The state body is required to publicize information on its budget at least once a year. (Articles 2, 5, 39 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Annual chart of accounts (actual expenditures)	Yes. Information of public importance, within the meaning of this Law, is information held by a public authority body, created during or relating to the operation of a public authority body, which is contained in a document and concerns anything the public has a justified interest to know. State bodies are required at least once a year to publicize information on their budget. (Articles 2, 5, 39 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Annual reports of public entities and programs	Yes. Information of public importance, within the meaning of this Law, is information held by a public authority body, created during or relating to the operation of a public authority body, which is contained in a document and concerns anything the public has a justified interest to know. State bodies are required to publicize information about their services. (Articles 2, 5, 39 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Information access and release
Procedural access
Universal access (agencies, citizens and non-citizens)	Yes. Everyone shall be able to exercise the rights in this Law under equal conditions, regardless of their nationality, temporary or permanent residence or place of establishment, or any personal characteristic such as race, religion, national or ethnic background, gender, etc. (Article 6 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Type of request is specified (written, electronic, oral)	Yes. An applicant shall submit a request in writing to a public authority to exercise the right to access information of public importance (hereinafter referred to as request). A public authority shall also have the duty to grant an applicant access to information where a request for information is made verbally and entered in relevant records, it being understood that such requests shall be entered in special records and relevant time limits shall apply accordingly as if the request were submitted in writing. A public authority may prescribe a sample request form, but it shall nevertheless have to duty to take into consideration all requests not filed on such form. (Article 15 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Assistance to requesters must be provided by law (includes barriers due to language differences, illiteracy, complexity of requests, etc.)	Yes. If a request does not contain the details set out in paragraph 2 of this Article, i.e. if a request is deficient, the authorized person of the public authority shall have a duty to instruct the applicant free of charge on ways to rectify the deficiencies in the request, i.e. he/she shall instruct the applicant to complement the request. (Article 15 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Cost of access is specified (free, request fees, photocopying costs, other administrative costs)	Yes. Access to a document containing requested information shall be granted free of charge. A copy of a document containing requested information shall be issued against reimbursement by the applicant of the necessary costs of reproduction, while if such copy is sent to the applicant, he/she shall also be required to reimburse any costs associated with such sending. The government shall pass a list of reimbursable expenses on the basis of which public authorities shall calculate the costs referred to in the foregoing paragraph. (Article 17 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Deadlines for release of information
20-day response deadline	Yes. A public authority shall, without delay, and within 15 days of receipt of a request at the latest, inform an applicant whether it holds the requested information, grant him/her access to the document containing the requested information or issue or send to the applicant a copy of the document, as the case may be. A copy of a document shall be deemed to be sent to an applicant sent on the day it leaves the office of the public authority from which the information was requested. (Article 16 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Agency granted right to extend response time	Yes. If a public authority is justifiably prevented from informing an applicant within the deadline referred to in paragraph 1 of this Article that it holds the information, from granting him/her access to a document containing the sought information and from issuing and/or sending him/her a copy of the document, the public authority shall, within seven days of receipt of the request at the latest, inform the applicant thereof and set another deadline, which shall not be longer than 40 days of receipt of the request, within which it shall inform the applicant that it holds the information, grant him/her access to the document containing the requested information or issue or send to the applicant a copy of the document, as the case may be. (Article 16 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Maximum total response time of no more than 40 days	Yes. The authority is obliged to inform the requester of the possession of the information without delay, and no later than within 15 days from the date of receipt of the request, i.e. the processed request, to provide him with a document containing complete and accurate requested information, or to issue or send him a copy of that document. A copy of the document was sent to the requester on the day of leaving the office of the authority from which the information was requested, i.e. on the day the email was sent. (Article 16 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Exceptions and Overrides
Exemptions to disclosure
Existence of secrecy/states secrets law	Yes. Law on Secrecy of Data, 2009 (Law on Secrecy of Data, 2009)
Existence of personal privacy/data law	Yes. Law on the Protection of Personal Data 2008, amended 2018 (Law on the Protection of Personal Data 2008, amended 2018)
Specific exemptions to disclosure	Yes. General exemptions include limitations that may be “necessary in a democratic society . . . to prevent a serious violation of an overriding interest . . . “ or which may infringe privacy rights. More specific exemptions to coverage are provided in Article 9 and Article 10, including information whose disclosure may imperil a criminal investigation; risk someone’s personal health,safety, or privacy; endanger national defense or security; undermine the government’s ability to manage the economy; and harm state, official, or business secrets. . Provisions exempt personal data, as well as information that implicates the nation’s territorial integrity, sovereignty, constitutional order, human rights, national security, defense, and foreign affairs. (Articles 8, 9, 10, 13, and 14 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 Article 8 of the Law on the Protection of Personal Data, 2008, amended 2012 Article 2(1-3) of the Law on Secrecy of Data, 2009)
Public Interest test: Specified exemptions to disclosure may be overridden in cases where disclosure of information benefits the public interest.
Appeals
Appeals allowed within public entities	Yes. Certain relevant provisions of the Law on General Administrative Procedure regulate the procedure of a public authority. (Article 21 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 Articles 12 and 214 of the Law on General Administrative Procedure, 2001, amended 2018)
Independent, non-judicial appeals mechanism, e.g., information commissioner. Does not include Ombudsman unless appeals decisions are binding.	Yes. An applicant may lodge a complaint with the Commissioner for Information of Public Importance. (Articles 16, 22, 23 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Judicial appeals mechanism	Yes. The Commissioner’s decisions and conclusions may be appealed in courts through an administrative dispute mechanism. (Article 27 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 Articles 12 and 214 of the Law on General Administrative Procedure, 2001, amended 2018)
Sanctions for non-compliance
Administrative sanctions are specified for violations of disclosure requirements	No. Absent from legal framework.
Fines are specified for violations of disclosure requirements	Yes. The Commissioner will force the executor - the authority to fulfill the obligations from the Commissioner's decision through indirect coercion, by imposing fines. The fine is imposed by decision. The fine is imposed in the range of 20,000 to 100,000 dinars and may be imposed several times. The imposed fine is executed by the court in accordance with the law regulating execution and security. The imposed fines represent the income of the budget of the Republic of Serbia. (Articles 28a of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Criminal sanctions are specified for violations of disclosure requirements	No. Absent from legal framework.
Monitoring and Oversight
Information officers must be appointed in public agencies	Yes. A public entity can designate one or more official persons to respond to requests for information. The article further stipulates the roles and responsibilities of the authorized person(s) and protects official employees who allow access to information that is related to the existence of corruption, officials overstepping their authority, irrational disposal of public assets, or unlawful acts by officials. (Article 38 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Public body that is responsible for applying sanctions	Yes. Commissioner for Information of Public Importance (Article 28 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Public body that is responsible for public outreach (raising public awareness)	Yes. Commissioner for Information of Public Importance (Article 35 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Nodal agency for RTI (implementation support/compliance within public sector). Does not include Ombudsman.	Yes. The Commissioner shall: 1) Monitor compliance of public authorities with the duties provided for in this Law and report to the public and the National Assembly thereof; 2) Make motions to draft or amend regulations for the purpose of implementation and promotion of the right to access information of public importance; 3) Propose to public authorities measures to be taken to improve their operations governed by this Law; 4) Take necessary measures to train employees of government bodies and to advise them on their duties regarding the rights to access information of public importance, with a view to ensuring effective implementation of this Law; The implementation of this Law of shall be supervised by the Ministry responsible for administrative affairs. Inspection enforcement of this Law shall be performed by the ministry responsible for administrative affairs, through its administrative inspectorate. (Articles 35 and 45 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )
Ombudsman involvement in implementation is specified by law	No. Absent from legal framework.
Reporting of data and/or implementation is required	Yes. A state body authorized person shall submit an annual report to the Commissioner on the activities of the body undertaken with the aim of implementing this Law, which shall contain the following data: 1) Number of submitted requests, number of wholly or partly approved requests and the number of rejected or dismissed requests; 2) Number and content of the complaints against the decisions to reject or dismiss a request; 3) Total sum of fees charged for the exercise of the right to access information of public importance; 4) Measures taken with regard to the obligation to publish a directory; 5) Measures taken with regard to maintaining information mediums; 6) Measures taken with regard to staff training.” (Articles 43 of the Law on Free Access to Information of Public Importance, 2004, amended 2021 )

Legislation

Constitution of the Republic of Serbia of 2006_SER (Serbian)	pdf
Law on Free Access to Information of Public Importance of 2004_SER (Serbian)	pdf
Law on Government of 2005_SER (Serbian)	pdf
Law on Secrecy of Data of 2009_SER (Serbian)	pdf
Law on the Protection of Personal Data of 2018_SER (Serbian)	pdf
Law on General Administrative Procedure of 2016_SER (Serbian)	pdf

*Last update: 2017

Public Procurement

The Serbian public procurement system is regulated by the Law on Public Procurement (2013), and several additional regulations. The public procurement body is the Public Procurement Advisory Unit which is an organization under the Ministry of Employment and Economy.

The lowest minimum threshold for conducting a public procurement tender is:

▪ RSD 500,000 (ca. EUR 4,200) for goods, works and services

The minimum number of bidders is 3 in case of low-value public procurement tenders, but there is no such regulation on restricted procedures or negotiated procedures and competitive dialogue. The minimum submission period is 40 days for open procedures, 20 days for restricted procedures and 25 for negotiated procedures from dispatch date. The final beneficial owners have to be disclosed when placing a bid.

There is possibility for preferential treatment for SMEs and domestic providers can be advantaged through award criteria. Sustainability factors can be considered in the awarding process.

There are several options for bid exclusion: supply of false information, prior unjustifiable refusal to sign a contract after awarding, refusal to supply evidence and collateral previously committed to in the bid etc. Bids can be also excluded because of abnormally low bid prices

In the bid evaluation phase, there are conflict of interest restrictions on the composition of the evaluation committee. There is also a requirement that some part of the evaluation committee be independent of the contracting authority.

There is a payable fee in case of an arbitration procedure, which is at least RSD 15,000 (ca. EUR 120). Court decisions are publicly released.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2015	2016	2017	2020	2024
Scope	48	45	38	85	95
Information availability	96	96	83	96	100
Evaluation	81	81	69	75	81
Open competition	83	83	64	64	75
Institutional arrangements	43	43	36	93	93

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Scope
Threshold - lowest PP
What is the minimum contract value above which the public procurement law is applied? (Product type GOODS)	RSD 1,000,000. Below RSD 1,000,000 (approx. EUR 8,500 at current exchange rates), the contracting authority may apply a simplified purchase procedure without publication on the Public Procurement Portal; between RSD 1,000,000 and the RSD equivalent of EUR 143,000 (approx. RSD 16,400,000), an open national procedure is required; above the RSD equivalent of EU thresholds, open international procedures with OJEU-equivalent notice publication are recommended. (Law No. 91/2019, Art. 27; Decision No. 85/2020-36)
What is the minimum contract value above which the public procurement law is applied? (Product type WORKS)	RSD 3,000,000. Below RSD 3,000,000 (approx. EUR 25,500), the contracting authority may apply a simplified purchase procedure; between RSD 3,000,000 and the RSD equivalent of EUR 5,538,000 (approx. RSD 633,000,000), open national procedures apply; above that, international open procedures are recommended. (Law No. 91/2019, Art. 27; Decision No. 85/2020-36)
What is the minimum contract value above which the public procurement law is applied? (Product type SERVICES)	RSD 1,000,000. Same structure as goods; below RSD 1,000,000 simplified purchase is permitted; above that national open procedure applies; above RSD equivalent of EUR 143,000/216,000, international open procedure is recommended. (Law No. 91/2019, Art. 27; Decision No. 85/2020-36)
Threshold - by PP type
What are the minimum application thresholds for the procurement type? (Entity: PUBLIC SECTOR)	RSD 1,000,000. Classical contracting authorities apply a simplified purchase below RSD 1,000,000 (goods/services) or RSD 3,000,000 (works); open national procedure applies between these values and the RSD equivalents of EU thresholds; above EU-equivalent thresholds, open international procedures are recommended. (Law No. 91/2019, Art. 27; Decision No. 85/2020-36)
What are the minimum application thresholds for the procurement type? (Entity: UTILITIES)	RSD 1,000,000. Serbia does not have a separate utilities procurement law; Law No. 91/2019 applies to both classical and utilities entities; entities in water, energy, transport and postal services follow the same threshold structure as classical contracting authorities. (Law No. 91/2019, Art. 2)
What are the minimum application thresholds for the procurement type? (Entity: DEFENCE)	RSD 1,000,000. Defence and security procurement is governed by Regulation No. 93/2020-1; where the Regulation does not apply, the general provisions of Law No. 91/2019 apply; no separate RSD defence threshold is specified in the regulation, as the general thresholds from Decision No. 85/2020-36 apply. (Regulation No. 93/2020-1; Law No. 91/2019; Decision No. 85/2020-36)
Threshold - by product type
What are the minimum application thresholds for the procurement type? (Product type GOODS)	RSD 1,000,000. Simplified purchase below RSD 1,000,000; open national procedure between RSD 1,000,000 and EU-equivalent threshold; open international procedure above EU-equivalent threshold. (Law No. 91/2019, Art. 27; Decision No. 85/2020-36)
What are the minimum application thresholds for the procurement type? (Product type WORKS)	RSD 3,000,000. Simplified purchase below RSD 3,000,000; open national procedure between RSD 3,000,000 and EU-equivalent threshold; open international procedure above EU-equivalent threshold. (Law No. 91/2019, Art. 27; Decision No. 85/2020-36)
What are the minimum application thresholds for the procurement type? (Product type SERVICES)	RSD 1,000,000. Same structure as goods; social services follow a specific light-touch regime in line with EU alignment. (Law No. 91/2019, Art. 27; Decision No. 85/2020-36)
Information availability
Publishing and record keeping
Is there a requirement that tender documents must published in full?	Yes. The contracting authority shall ensure free, direct and unrestricted electronic access to the tender documentation through the Public Procurement Portal from the date of publication of the procurement notice; the internet address is specified in the notice. (Law No. 91/2019, Art. 83)
Are any of these documents published online at a central place?	Yes. Public Procurement Portal of the Republic of Serbia: https://www.ujn.gov.rs (managed by the Public Procurement Office); all notices, tender documentation and award notices are published on this portal. (Law No. 91/2019, Arts. 83 and 85)
Is it mandatory to keep all of these records? -Public notices of bidding opportunities, -Bidding documents and addenda, -Bid opening records, -Bid evaluation reports, -Formal appeals by bidders and outcomes, -Final signed contract documents and addenda and amendments, -Claims and dispute resolutions, -Final payments, -Disbursement data (as required by the country’s financial management system)	Yes. The contracting authority is required to prepare and keep a public procurement file for each procedure, including: the procurement plan, published notices and proof of publication, tender documentation, evaluation commission decisions, evaluation reports, bids submitted, contract award decision and justification, signed contract and any addenda, complaints filed and decisions thereon, and the contract award notice; the file is kept for at least 5 years. (Law No. 91/2019, Arts. 83–85)
Are contracts awarded within a framework agreement published (ie mini contracts)?	Yes. The contracting authority is required to publish the award notice for contracts concluded under a framework agreement; award notices for contracts under framework agreements are published on a quarterly basis within 30 days of the end of each quarter. (Law No. 91/2019, Art. 85)
Sub-contracting
Is it mandatory to publish information on subcontractors (ie names) in some cases?	Yes. The contracting authority may require tenderers to state which parts of the contract will be subcontracted and the identification data of draft subcontractors; this information is included in the bid and forms part of the public procurement file; the contracting authority must inform the subcontractors of the provisions of the contract relating to them. (Law No. 91/2019, Arts. 103 and 104)
If yes, what is the threshold for publication (i.e. the % of total contract value subcontracted)? For example, if the threshold is 75%, and you have subcontracted out only 40% of your contract, no disclosure is required. Consultant will insert 75% in the short answer column.	0%. Regardless of the subcontractors' share of participation, the tenderer must specify which parts will be subcontracted; no percentage threshold triggers or exempts disclosure. (Law No. 91/2019, Arts. 103 and 104)
Evaluation
Preferential treatment
Is there a ban on mentioning specific companies or brands in tender specification/call for tender?	Yes. As a rule it is prohibited to define technical specifications indicating a specific origin, source, production, special procedure, brand or trade name, patent, production licence which has the effect of favouring or eliminating certain economic operators or products; as an exception, a brand name may be indicated where a sufficiently precise and intelligible description of the subject-matter is not possible, accompanied by the words "or equivalent". (Law No. 91/2019, Art. 98(2)(3))
Is there a preferential treatment for small-to-medium enterprises (SMEs)?	Yes. The contracting authority shall determine the object of each lot, on a quantitative basis to better match the capacity of SMEs, or on a qualitative basis according to the different trades and specialisations involved; as a measure to increase SMEs' access to procurement procedures, contracting authorities must provide an explanation for their decision not to divide the contract into lots. (Law No. 91/2019, Art. 106)
Is there a preferential treatment for local/national companies? (companies from other EU MS are considered foreign companies)	No. The public procurement principles include equal treatment and non-discrimination of economic operators; no preferential treatment for local or national companies is permitted; foreign companies from non-EU countries may participate under reciprocity conditions. (Law No. 91/2019, Art. 2(a)(b))
Is there a specific set of rules for green/sustainable procurement?	Yes. Law 92/2023 (in force 1 January 2024) introduced the principle of environmental protection as a new principle in public procurement (amending the title of Art. 6 to read "The principle of cost-effectiveness, efficiency and environmental protection"); the contracting authority is required to specify binding rules in the fields of environment, social and labour relations in the procurement documents; environmental characteristics may be included in performance requirements; award criteria may include environmental aspects. (Law No. 91/2019, Art. 6 (as amended by Law 92/2023); Art. 99)
Bid evaluation
Are there restrictions on allowable grounds for tenderer exclusion?	Yes. The contracting authority has the obligation to exclude any tenderer/candidate who: (1) has been convicted by a final court decision for: participation in a criminal organisation, corruption, fraud, terrorist offences, money laundering, child labour and human trafficking; (2) has not paid social contributions and taxes; (3) has violated obligations in environmental, social and labour law; (4) is in bankruptcy, insolvency or winding-up; (5) has committed a grave professional misconduct; (6) has entered into agreements distorting competition; (7) is in a conflict of interest; (8) has misrepresented information; (9) has attempted to unduly influence the contracting authority's decision-making. (Law No. 91/2019, Arts. 111–114)
Are some bids automatically excluded? e.g., lowest/highest price; unusually low price, etc.	No. Before rejecting a bid due to an abnormally low price, the contracting authority must request in writing from the tenderer details and explanations regarding the bid price; only after evaluating the explanations may the contracting authority reject the bid; automatic exclusion based on price alone is not permitted. (Law No. 91/2019, Arts. 140–143)
Is scoring criteria published?	Yes. The contracting authority specifies in the procurement documents the relative weight of each evaluation criterion; Law 92/2023 introduced quality rather than price as the primary criterion for certain goods and services, requiring contracting authorities to justify price-only criteria in specific cases; the most economically advantageous tender criterion is preferred. (Law No. 91/2019, Art. 115 (as amended by Law 92/2023))
Are decisions always made by a committee?	Yes. The contracting authority is obliged to form an evaluation commission for conducting procurement procedures; commission members are designated by the head of the contracting authority; for complex procurements, external experts may be co-opted. (Law No. 91/2019, Art. 88)
Are there regulations on evaluation committee composition to prevent conflict of interest?	Yes. Persons involved in the evaluation process may not be in a conflict of interest with tenderers; they must sign a declaration of absence of conflict of interest before commencement of evaluation; a conflict of interest exists when a person has a direct or indirect financial, economic or other personal interest that may compromise their impartiality; Law 92/2023 introduced the obligation for the contracting authority to specify in the procurement documents the names of persons involved in the decision-making process. (Law No. 91/2019, Arts. 26–28 and 88 (as amended by Law 92/2023))
Is some part of evaluation committee mandatorily independent of contracting authority?	No. There is no mandatory requirement for evaluation committee members to be independent of the contracting authority; external experts may be co-opted but do not have voting rights in determining the winning offer. (Law No. 91/2019, Art. 88)
Are scoring results publicly available?	Yes. The contracting authority is required to publish the award decision and its grounds on the Public Procurement Portal; the evaluation report is part of the procurement file, which is a public document after conclusion of the contract; the award notice is published on the Portal within the prescribed deadline. (Law No. 91/2019, Arts. 85 and 152)
Does the law specify under which conditions the tender can be cancelled?	Yes. Law 92/2023 amended Art. 152 to specify that the contracting authority/procuring entity shall make the decision to suspend the public procurement procedure within 30 days from the expiration of the deadline for submission of bids, unless a longer period has been specified in the tender documentation; the general grounds for cancellation include: no bids submitted; no admissible bids; impossibility to conclude the contract; legal violations affecting the procedure; force majeure. (Law No. 91/2019, Arts. 152 and 152a (as amended by Law 92/2023))
Open competition
CFT publication
Does the law specify the location for publicizing open calls for tenders?	Yes. Public Procurement Portal of the Republic of Serbia (https://www.ujn.gov.rs); for procurements above EU-equivalent thresholds, additional publication in the Official Gazette of the Republic of Serbia and on the UN/international portals is recommended. (Law No. 91/2019, Arts. 83 and 85)
Does the law specify the location for publicizing restricted calls for tenders?	Yes. Public Procurement Portal of the Republic of Serbia; same publication requirements as open procedures. (Law No. 91/2019, Arts. 83 and 85)
Does the law specify the location for publicizing negotiated calls for tenders?	Yes. Public Procurement Portal of the Republic of Serbia; the negotiated procedure with prior publication requires the same notice publication as open procedures; the negotiated procedure without prior publication does not require portal publication but requires internal justification. (Law No. 91/2019, Arts. 64–75 and 83)
Minimum # of bidders
What is the minimum number of bidders for restricted procedures?	5. The minimum number of candidates for the restricted procedure is 5. (Law No. 91/2019, Art. 66)
What is the minimum number of bidders for negotiated procedures?	3. The minimum number of candidates for the negotiated procedure with prior publication is 3. (Law No. 91/2019, Art. 69)
What is the minimum number of bidders for competitive dialogue procedures?	3. The minimum number of participants for competitive dialogue is 3. (Law No. 91/2019, Art. 72)
Bidding period length
What are the minimum number of days for open procedures?	35. For procurements above EU-equivalent thresholds: minimum 35 days from dispatch of notice to deadline for bid submission; for procurements below EU-equivalent thresholds: minimum 15 days; in cases of duly justified urgency: minimum 15 days regardless of threshold. (Law No. 91/2019, Art. 64)
What are the minimum number of days for restricted procedures?	30. For restricted procedures above EU-equivalent thresholds: minimum 30 days; for those below: minimum 15 days. (Law No. 91/2019, Art. 66)
What are the minimum number of days for competitive negotiated procedures?	30. For negotiated procedures with prior publication above EU-equivalent thresholds: minimum 30 days. (Law No. 91/2019, Art. 69)
Institutional arrangements
Institutions and regulations
Does the law specify the main EXCEPTIONS preventing the application of the public procurement law for tenders/organisations?	Yes. Main exceptions include: (1) contracts subject to international agreements or arrangements concerning the stationing of troops; (2) contracts subject to specific procedures of international organisations; (3) certain service contracts such as: arbitration and conciliation, legal representation services, financial services, employment contracts, research and development services, purchase/rental of land; (4) public-public cooperation (in-house); (5) certain defence and security contracts governed by Regulation 93/2020-1; (6) contracts of special classification. (Law No. 91/2019, Arts. 7–15)
Does the law specify the main types of institutions that must apply the public procurement law?	Yes. Main types: (a) bodies of the Republic of Serbia, autonomous provinces and local governments; (b) any body governed by public law – legal persons established to meet general interest needs, financed for the most part by or under management supervision of contracting authorities; (c) associations formed by contracting authorities; (d) public enterprises; (e) other obligors as defined by law. (Law No. 91/2019, Art. 4)
Does the law specify the main procedure types or procurement methods permitted?	Yes. Open procedure; restricted procedure; negotiated procedure with prior publication; negotiated procedure without prior publication; competitive dialogue; innovation partnership; design contest; simplified purchase procedure; framework agreements. (Law No. 91/2019, Art. 50)
Is there a procurement arbitration court dedicated to public procurement cases?	Yes. The Republic Commission for the Protection of Rights in Public Procurement Procedures ("Republička komisija za zaštitu prava u postupcima javnih nabavki") – independent body competent to review challenges filed before contract conclusion; from 1 January 2024 (Law 92/2023), all requests for protection of rights and appeals must be submitted electronically through the Public Procurement Portal; decisions of the Republic Commission are also delivered electronically via the Portal; decisions may be challenged before the Administrative Court. (Law No. 91/2019, as amended by Law 92/2023, Arts. 158–178)
Is there a procurement regulatory body dedicated to public procurement?	Yes. The Public Procurement Office ("Uprava za javne nabavke"/UJN) – the dedicated regulatory, supervisory and monitoring body for public procurement; manages the Public Procurement Portal; issues guidance and model documents; monitors compliance; submits annual reports to the Government. (Law No. 91/2019, Arts. 158–163)
Does the law specify procurement advisors' profession (i.e. degree to be obtained, official list of members of the professional association) and its role in the tendering process (e.g. right to draft tender documentations, conduct market research identifying bidders)?	No. There are no provisions in the Law regulating a procurement advisers' profession; no official list, degree requirement or professional association registration is required; the closest provision relates to the Register of Bidders regulated by Ordinances No. 17/2020-34 and No. 94/2020-4. (Law No. 91/2019; Ordinances No. 17/2020-34 and 94/2020-4)
Is disclosure of final, beneficial owners required for placing a bid?	Yes. Economic operators organised as joint stock companies with bearer shares are required to provide information on the identity of the beneficial owners of bearer shares; the contracting authority may require and the economic operator has the obligation to communicate such information; failure to comply may result in exclusion. (Law No. 91/2019, Art. 111)
Complaints
Is there a fee for arbitration procedure?	Yes. A fee is charged with the appeal filed with the Republic Commission; the fee is set at 2% of the estimated value of the contract, but not more than a statutory cap; in case of a framework agreement, the fee is calculated based on the estimated value of the largest subsequent contract; the contracting authority is exempt from paying the fee. (Law No. 91/2019, Art. 170)
Is there a ban on contract signature until arbitration court decision (first instance court)?	Yes. The contracting authority may not conclude the contract during the standstill period following the award decision; the submission of a request for protection of rights suspends the procurement procedure until the Republic Commission issues its decision; the Republic Commission may additionally order suspension as a provisional measure. (Law No. 91/2019, Arts. 166–169)
What is the maximum number of days until arbitration court decision from filing a complaint in the case of awarded contracts?	15. The Republic Commission is required to issue its decision within 15 working days from receipt of a complete complaint file; in complex cases this period may be extended by an additional 15 working days; decisions may be challenged before the Administrative Court within 30 days. (Law No. 91/2019, Art. 172)
Is there a requirement to publicly release arbitration court decisions ?	Yes. Decisions of the Republic Commission must be published on the Portal of the Republic Commission and on the Public Procurement Portal; from 1 January 2024, all decisions are delivered electronically via the Public Procurement Portal; decisions are publicly accessible on the Republic Commission's website; Law 92/2023 also granted the Commission for Protection of Competition (CPC) access to the Public Procurement Portal database, enabling it to use procurement data in competition proceedings. (Law No. 91/2019, as amended by Law 92/2023, Arts. 172 and 152a; Law 92/2023)

Legislation

Decision No. 85/2020-36 on the Public Procurement Office (Serbian)	pdf
Law on Public Procurement (Official Gazette RS No. 91/2019) (Serbian)	pdf
Bylaws on public procurement implementing regulations (Official Gazette RS Nos. 17/2020 and 94/2020) (Serbian)	pdf
Regulation No. 93/2020 on the Office for Information Technologies and eGovernment (Serbian)	pdf

*Last update: 2017

Anti Money Laundering

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Risk-based approach						100
Sanctions for natural persons						100
Sanctions for legal persons						100
Pecuniary sanctions for obliged entities						80
Beneficial ownership of legal persons and legal arrangements						43
Supervision of obliged entities						100
Financial Intelligence Units (FIUs)						83
Mutual legal assistance (MLA) and International Cooperation						100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Country score
Risk-based approach
Each Member State shall be legally required to prepare a national risk assessment that outlines appropriate steps to identify, assess, understand and mitigate the risks of money laundering and terrorist financing affecting it.	Yes. The Government shall establish a coordinating body in order to ensure an efficient cooperation and coordination of competent authorities' tasks performed for the purpose of preventing money laundering and the financing of terrorism. The national money laundering, terrorism financing and WMD proliferation financing risk assessment shall be done in a written form and updated at least once in three years.** A summary of the risk assessment referred to in paragraph 2 of this Article shall be made available to the public and may not contain classified information.* (Article 70, AML Law, amended 2025)
Member states shall be legally required to keep the national risk assessment up to date and review it at least every 4 years.	Yes. The Government shall establish a coordinating body in order to ensure an efficient cooperation and coordination of competent authorities' tasks performed for the purpose of preventing money laundering and the financing of terrorism. The national money laundering, terrorism financing and WMD proliferation financing risk assessment shall be done in a written form and updated at least once in three years.** A summary of the risk assessment referred to in paragraph 2 of this Article shall be made available to the public and may not contain classified information.* (Article 70, AML Law, amended 2025)
Member states should legally designate an authority or mechanism to co-ordinate actions to assess risks.	Yes. The Government shall establish a coordinating body in order to ensure an efficient cooperation and coordination of competent authorities' tasks performed for the purpose of preventing money laundering and the financing of terrorism. The national money laundering, terrorism financing and WMD proliferation financing risk assessment shall be done in a written form and updated at least once in three years.** A summary of the risk assessment referred to in paragraph 2 of this Article shall be made available to the public and may not contain classified information.* (Article 70, AML Law, amended 2025)
Sanctions for natural persons
The following conduct, when committed intentionally, is punishable as a criminal offence: the conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action;	Yes. (1) Whoever converts or transfers assets knowing that such assets originate from a criminal offence, with the intention of concealing or misrepresenting the unlawful origin of the assets, or conceals and misrepresents facts on the assets knowing that such assets originated from a criminal offence, or obtains, keeps or uses assets with foreknowledge, at the moment of receiving, that such assets originated from a criminal offence shall be punished with imprisonment of six months to five years and fined. (Article 245, Criminal Code)
The following conduct, when committed intentionally, is punishable as a criminal offence: the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity;	Yes. (1) Whoever converts or transfers assets knowing that such assets originate from a criminal offence, with the intention of concealing or misrepresenting the unlawful origin of the assets, or conceals and misrepresents facts on the assets knowing that such assets originated from a criminal offence, or obtains, keeps or uses assets with foreknowledge, at the moment of receiving, that such assets originated from a criminal offence shall be punished with imprisonment of six months to five years and fined. (Article 245, Criminal Code)
The following conduct, when committed intentionally, is punishable as a criminal offence: the acquisition, possession or use of property, knowing at the time of receipt, that such property was derived from criminal activity.	Yes. (1) Whoever converts or transfers assets knowing that such assets originate from a criminal offence, with the intention of concealing or misrepresenting the unlawful origin of the assets, or conceals and misrepresents facts on the assets knowing that such assets originated from a criminal offence, or obtains, keeps or uses assets with foreknowledge, at the moment of receiving, that such assets originated from a criminal offence shall be punished with imprisonment of six months to five years and fined. (Article 245, Criminal Code)
Aiding and abetting, inciting and attempting a money laundering offence is punishable as a criminal offence.	Yes. (1) Whoever commences a criminal offence with premeditation, but does not complete it, shall be punished for the attempted criminal offence if such offence is punishable by law with a term of imprisonment of five years or more, and for the attempt of other criminal offence only when the law explicitly provides for the punishment of attempt. (2) A perpetrator shall be punished for an attempt with a punishment prescribed for the criminal offence or with a lighter punishment. //// Article 34 (1) Whoever with intent incites another to commit a criminal offence shall be punished as prescribed by law for such offence. (2) Whoever with intent incites another to commit a criminal offence whose attempt is punishable by law, and such offence has not been attempted at all, shall be punished as for the attempted criminal offence. Aiding and Abetting Article 35 (1) Anyone aiding another with intent in committing a criminal offence shall be punished as prescribed by law for such criminal offence, or by a mitigated penalty. (2) The following, in particular, shall be considered as aiding in the commission of a criminal offence: giving instructions or advice on how to commit a criminal offence; supply of means for committing a criminal offence; creating conditions or removal of obstacles for committing a criminal offence; prior promise to conceal the commission of the offence, offender, means used in committing a criminal offence, traces of criminal offence and items gained through the commission of criminal offence. (Article 30, 34 and 35, Criminal Code)
Money laundering offences are punishable by a maximum term of imprisonment of at least four years.	Yes. (1) Whoever converts or transfers assets knowing that such assets originate from a criminal offence, with the intention of concealing or misrepresenting the unlawful origin of the assets, or conceals and misrepresents facts on the assets knowing that such assets originated from a criminal offence, or obtains, keeps or uses assets with foreknowledge, at the moment of receiving, that such assets originated from a criminal offence shall be punished with imprisonment of six months to five years and fined. (Article 245, Criminal Code)
A prior or simultaneous conviction for the criminal activity from which the property was derived is not a prerequisite for a conviction for money laundering offences	Yes. (1) Whoever converts or transfers assets knowing that such assets originate from a criminal offence, with the intention of concealing or misrepresenting the unlawful origin of the assets, or conceals and misrepresents facts on the assets knowing that such assets originated from a criminal offence, or obtains, keeps or uses assets with foreknowledge, at the moment of receiving, that such assets originated from a criminal offence shall be punished with imprisonment of six months to five years and fined. (Article 245, Criminal Code)
A conviction for money laundering offences is possible where it is established that the property was derived from a criminal activity, without it being necessary to establish all the factual elements or all circumstances relating to that criminal activity, including the identity of the perpetrator;	Yes. (1) Whoever converts or transfers assets knowing that such assets originate from a criminal offence, with the intention of concealing or misrepresenting the unlawful origin of the assets, or conceals and misrepresents facts on the assets knowing that such assets originated from a criminal offence, or obtains, keeps or uses assets with foreknowledge, at the moment of receiving, that such assets originated from a criminal offence shall be punished with imprisonment of six months to five years and fined. (Article 245, Criminal Code)
Sanctions for legal persons
Legal persons can be held liable for the breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113 committed on their behalf or for their benefit by any person, acting individually or as part of a body of that legal person and having a leading position within that legal person, based on any of the following: a power to represent the legal person; an authority to take decisions on behalf of the legal person; an authority to exercise control within the legal person.	Yes. A legal person shall be held accountable for criminal offences which have been committed for the benefit of the legal person by a responsible person within the remit, that is, powers thereof. The liability referred to in paragraph 1 of this Article shall also exist where the lack of supervision or control by the responsible person allowed the commission of crime for the benefit of that legal person by a natural person operating under the supervision and control of the responsible person. (Article 6, Law on the liability of legal entities)
Legal persons can be held liable where the lack of supervision or control has made possible the commission of any money laundering offences for the benefit of that legal person by a person under its authority.	Yes. A legal person shall be held accountable for criminal offences which have been committed for the benefit of the legal person by a responsible person within the remit, that is, powers thereof. The liability referred to in paragraph 1 of this Article shall also exist where the lack of supervision or control by the responsible person allowed the commission of crime for the benefit of that legal person by a natural person operating under the supervision and control of the responsible person. (Article 6, Law on the liability of legal entities)
Legal persons held liable are punishable by criminal or non-criminal fines.	Yes. The following sentences may be imposed against a legal person: 1) fine; 2) termination of the status of a legal entity. Fine and the termination of the status of a legal entity may be imposed solely as principal sentences. (Article 13, Law on the liability of legal entities)
Legal persons held liable are punishable by other sanctions, such as: exclusion from entitlement to public benefits or aid; temporary or permanent exclusion from access to public funding, including tender procedures, grants and concessions; temporary or permanent disqualification from the practice of commercial activities; placing under judicial supervision; a judicial winding-up order; temporary or permanent closure of establishments which have been used for committing the offence.	Yes. Legal consequences of the conviction relating to termination or forfeiture of certain rights shall include: 1) termination of practising certain activities or business operations; 2) forfeiture of certain permits, approvals, concessions, subsidies or other forms of incentives granted by a decision of a government authority or an authority of the local selfgovernment unit. Legal consequences of the conviction comprising prohibition upon acquiring certain rights shall include: 1) prohibition to practise certain activities or business operations; 2) prohibition upon participation in the public procurement procedure; 3) prohibition upon participation in privatisation of business entities; 4) prohibition upon acquiring certain permits, approvals, concessions, subsidies or any other forms of incentives granted by a decision of a government authority or an authority of the local self-government unit. (Article 28, Law on the liability of legal entities)
Pecuniary sanctions for obliged entities
In the event of a breach of Regulations (EU) 2024/1624 and (EU) 2023/1113, where obligations apply to legal persons, pecuniary sanctions can be imposed and administrative measures can be applied not only to the legal person, but also to the senior management and to other natural persons who under national law are responsible for the breach.	Yes. Article 115-121 (Articles 115-121, AML Law amended 2025)
Pecuniary sanctions shall be imposed on obliged entities for serious, repeated or systematic breaches, whether committed intentionally or negligently, of the requirements laid down in the following provisions of Regulation (EU) 2024/1624: Chapter II (Internal policies, procedures and controls of obliged entities); Chapter III (Customer due diligence); Chapter V (Reporting obligations); Article 77 (Record retention).	Yes. Article 115-121 (Articles 115-121, AML Law amended 2025)
Supervisors are able to apply administrative measures to an obliged entity, where they identify: breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113, either in combination with pecuniary sanctions for serious, repeated and systematic breaches, or on their own; weaknesses in the internal policies, procedures and controls of the obliged entity that are likely to result in breaches of the requirements; that the obliged entity has internal policies, procedures and controls that are not commensurate with the risks of money laundering, its predicate offences or terrorist financing to which the entity is exposed.	Yes. If the authority referred to in paragraph 1 of this article finds, in the course of supervision, any irregularities or illegalities in the implementation of this law and regulations passed based on this law it is authorised to take one or more of the following measures:* 1) publish on its website a public notification identifying the specific natural and/or legal person where such irregularities or illegalities were found with, as well as the type, or nature of the breaches of the law and/or other regulations;* 2) request that such conduct be terminated and to refrain from repeating it or request that the irregularities, illegalities and deficiencies be removed within the timeframe it sets;* 3) submit a request to the competent state body instituting appropriate proceedings, including criminal proceedings, and inform the apml without delay thereof;* 4) temporarily prohibit the discharge of the office to the person who is a member of the obliged entity’s management body or temporarily prohibit any other natural person responsible for the breach from being appointed to that office or discrahging such offices at the obliged entity;* 5) in the case of severe, systemic or recurring illegalitites or irregularities, impose a fine, as an administrative measure, of up to double the amount of the benefit generated through the breach of this law, and if the benefit cannot be determined up to RSD 120 million;* 6) take other measures and activities for which it is authorised under the law.*** (Article 104, AML Law amended 2025)
Where obliged entities fail to comply with administrative measures applied by the supervisor within the applicable deadlines, supervisors are able to impose periodic penalty payments in order to compel compliance with those administrative measures.	No. Absent from legal framework (Absent from legal framework)
Supervisors are required to publish on their website, in an accessible format, decisions imposing pecuniary sanctions, applying administrative measures or imposing periodic penalty payments.	Yes. If the authority referred to in paragraph 1 of this article finds, in the course of supervision, any irregularities or illegalities in the implementation of this law and regulations passed based on this law it is authorised to take one or more of the following measures:* 1) publish on its website a public notification identifying the specific natural and/or legal person where such irregularities or illegalities were found with, as well as the type, or nature of the breaches of the law and/or other regulations;* (Article 104, AML Law amended 2025)
Beneficial ownership of legal persons and legal arrangements
Beneficial ownership information must be held in a central register in the Member State where the legal entity is created or where the trustee of an express trust or person holding an equivalent position in a similar legal arrangement is established or resides, or from where the legal arrangement is administered.	Yes. The Central Records shall be kept by the Business Registers Agency (hereinafter: the Agency) in electronic form, through the registrar. Any natural person meeting the conditions from Article 3, paragraph 1, item 7 of this Law and the natural person referred to in Article 3, paragraph 2 of this Law shall be registered in the Central Records as the beneficial owner. (Article 5, Law on the Central Records of Beneficial Owners)
Member States shall ensure that the entities in charge of the central registers are empowered to request from legal entities, trustees of any express trust and persons holding an equivalent position in a similar legal arrangement, and their legal and beneficial owners, any information necessary to identify and verify their beneficial owners, including resolutions of the board of directors and minutes of their meetings, partnership agreements, trust deeds, power of attorney or other contractual agreements and documentation.	No. Absent from legal framework (Absent from legal framework)
Where no person is identified as the beneficial owner, the central register shall include: (a) a statement that there is no beneficial owner or that the beneficial owners could not be determined, accompanied by a corresponding justification (b) the details of all natural persons who hold the position of senior managing officials in the legal entity equivalent to the following information: all names and surnames, place and full date of birth, residential address, country of residence and nationality or nationalities of the beneficial owner, number of identity document, such as passport or national identity document, and, where it exists, unique personal identification number assigned to the person by his or her country of usual residence, and general description of the source of such number	Yes. Exceptionally, if it is not possible to identify the natural person from paragraph 1, item 7), subitems (1)-(3) of this Article for the registered entities referred to in Article 2, paragraph 1, items 1), 2), 3), 4), 6) and 7) of this Law, as well as in cases where all reasonable actions and measures have been taken to identify the beneficial owner, but the beneficial owner has nevertheless not been determined, the beneficial owner of the registered entity shall be the natural person registered for representation or the one registered as a member of the governing body of that entity. (Article 3, 7), Law on the Central Records of Beneficial Owners)
Entities in charge of the central registers are required to verify, within a reasonable time upon submission of the beneficial ownership information, and on a regular basis thereafter, that such information is adequate, accurate and up to date.	Yes. The Agency shall verify whether the registered entity in the Central Records has: 1) registered data on the beneficial owner and, simultaneously with the registration, uploaded the documents based on which the beneficial owner has been 9 determined, within the deadline specified in Article 8, paragraph 4 of this Law from the date of the occurrence of the grounds for registration under Article 7, item 1) of this Law; 2) confirmed the accuracy and up-to-dateness of the registered data on the beneficial owner within the period specified in Article 9 of this Law. The Agency shall verify whether the trustee of the trust or the person comparable to the trustee in a legal relationship similar to a trust has confirmed the accuracy and up-to-dateness of the registered data on the beneficial owner within the deadline specified in Article 9 of this Law. (Article 14, Law on the Central Records of Beneficial Owners)
Competent authorities, if appropriate and to the extent that such requirement does not interfere unnecessarily with their functions, are required to report to the entities in charge of the central registers any discrepancies they find between information available in the central registers and the information available to them.	Yes. The competent authorities referred to in Article 12, paragraph 3 of this Law, in performing their supervisory duties within their scope of work, shall verify whether the registered entity, trustee of the trust, and the person comparable to the trustee in a legal relationship similar to a trust have registered data on the beneficial owner in the Central Records within the deadline specified in Article 8, paragraphs 4 and 5 of this Law from the date of the occurrence of the grounds for registration under Article 7, items 2) and 3) of this Law, whether they have registered accurate data, and whether the registered entity, trustee of the trust, and the person comparable to the trustee in a legal relationship similar to a trust retain the data and documents based on which they have registered the beneficial owner. (Article 14, Law on the Central Records of Beneficial Owners)
The information contained in the central registers must include any change to the beneficial ownership of legal entities and legal arrangements and to nominee arrangements, following their first recording in the central register.	Yes. The grounds for registration in the Central Records shall be: 1) entry of the registered entity in the relevant register; 2) changes in the ownership structure and members of the governing body of a registered entity, as well as other changes based on which it can be assessed whether the conditions for acquiring the status of beneficial owner of the registered entity from Article 3 of this Law are met; (Article 7, Law on the Central REcords of Beneficial Owners)
The entity in charge of the central register is empowered, whether directly or by application to another authority, including judicial authorities, to carry out checks, including on-site inspections at the business premises or registered office of legal entities, in order to establish the current beneficial ownership of the entity and to verify that the information submitted to the central register is accurate, adequate and up-to-date.	No. Absent from legal framework (Absent from legal framework)
Where verification leads an entity in charge of a central register to conclude that there are inconsistencies or errors in the beneficial ownership information, the entity in charge of a central register is able to withhold or refuse to issue a valid certificate of proof of registration, or to suspend the validity of an existing certification of proof of registration.	No. Absent from legal framework (Absent from legal framework)
The entity in charge of the central register is empowered to, whether directly or by application to another authority, including judicial authorities, apply effective, proportionate and dissuasive measures or impose such pecuniary sanctions for failures, including of a repeated nature, to provide the central register with accurate, adequate and up-to-date information about their beneficial ownership.	Yes. A registered entity – legal entity shall be fined between RSD 500,000 and RSD 2,000,000 for a misdemeanour if: 1) it fails to register the data about the beneficial owner of the registered entity in the Central Records and simultaneously upload the documents based on which the beneficial owner of the registered entity has been determined, no later than 30 days from the date when the grounds for recording under Article 7, items 1) and 2) of this Law arise (Article 8, paragraph 4); 2) it fails to register accurate data under Article 6, paragraph 3 of this Law in the Central Records (Article 8, paragraph 6); 3) it fails to confirm the accuracy and up-to-dateness of the registered data about the beneficial owner in the Central Records within the prescribed period (Article 9); 4) it fails to keep the data and documents based on which it registered the beneficial owner of the registered entity (Article 12, paragraph 2); 5) it fails to make available and submit, without delay and no later than three working days from the date of receipt of the request, the data and updated documents based on which it registered the beneficial owner of the registered entity, upon the request of the competent authority authorised to conduct supervision in accordance with the law governing the prevention of money laundering and terrorism financing and the law governing inspection supervision (Article 12, paragraph 3); 6) it fails to register the data about the new beneficial owner of the registered entity in the Central Records and simultaneously upload the documents based on which the new beneficial owner of the registered entity has been determined, no later than 30 days from the date of deletion of the person for whom it has been established by a final court judgment that he is not the beneficial owner (Article 13, paragraph 5). (Article 19, Law on the Central Records of Beneficial Owners)
Competent authorities have immediate, unfiltered, direct and free access to the information held in the interconnected central registers without alerting the legal entity or legal arrangement concerned. These competent authorities include: self-regulatory bodies in the performance of supervisory functions of AML rules; tax authorities; national authorities with designated responsibilities for the implementation of Union restrictive measures; AMLA for the purposes of joint analyses; EPPO; OLAF; Europol and Eurojust when providing operational support to the competent authorities of Member States.	Yes. Access to the DATA AND documents from paragraphs 1 - 4 of this Article and their downloading through the Agency’s website (portal) can be carried out by state authorities, as well as the authorities responsible for supervision and obligors within the meaning of the law governing the prevention of money laundering and terrorism financing, 24 HOURS OF THE DAY. (Article 6, Law on the Central Records of Beneficial Owners)
Beneficial ownership information held in central registers may be made available to obliged entities upon payment of a fee, which shall be limited to what is strictly necessary to cover the costs of ensuring the quality of the information held in the central registers and of making the information available. Those fees shall be established in such a way as not to undermine effective access to the information held in the central registers.	Yes. Access to the DATA AND documents from paragraphs 1 - 4 of this Article and their downloading through the Agency’s website (portal) can be carried out by state authorities, as well as the authorities responsible for supervision and obligors within the meaning of the law governing the prevention of money laundering and terrorism financing, 24 HOURS OF THE DAY. (Article 6, Law on the Central Records of Beneficial Owners)
Any natural or legal person that can demonstrate a legitimate interest in the prevention and combating of money laundering, its predicate offences and terrorist financing has access to the following information on beneficial owners of legal entities and legal arrangements held in the interconnected central registers, without alerting the legal entity or legal arrangement concerned: the name of the beneficial owner; the month and year of birth of the beneficial owner; the country of residence and nationality or nationalities of the beneficial owner; for beneficial owners of legal entities, the nature and extent of the beneficial interest held; for beneficial owners of express trusts or similar legal arrangements, the nature of the beneficial interest.	Yes. ACCESS TO THE DATA CONCERNING THE UNIQUE PERSONAL IDENTIFICATION NUMBER, PASSPORT NUMBER, ID CARD NUMBER FOR A FOREIGNER AND COUNTRY OF ISSUE OF DOCUMENT, REGISTRATION NUMBER FOR A FOREIGNER, REFUGEE CARD NUMBER, AS WELL AS ACCESS TO DOCUMENTS REFERRED TO IN PARAGRAPH 4 OF THIS ARTICLE CAN ONLY BE CARRIED OUT BY PERSONS DEMONSTRATING A LEGITIMATE INTEREST. (Article 6, Law on the Central Records of Beneficial Owners)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	No. Absent from legal framework (Absent from legal framework)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: civil society organisations, including non-governmental organisations and academia, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	No. Absent from legal framework (Absent from legal framework)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: natural or legal persons likely to enter into a transaction with a legal entity or legal arrangement and who wish to prevent any link between such a transaction and money laundering, its predicate offences or terrorist financing;	No. Absent from legal framework (Absent from legal framework)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: Member States’ public authorities in the context of public procurement procedures, in respect of the tenderers and operators being awarded the contract under the public procurement procedure;	No. Absent from legal framework (Absent from legal framework)
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	No. Absent from legal framework (Absent from legal framework)
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: civil society organisations that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing.	No. Absent from legal framework (Absent from legal framework)
Where entities in charge of central registers decide to grant access to beneficial ownership information, they shall issue a certificate granting access for 3 years. Entities in charge of central registers shall respond to any subsequent request to access beneficial ownership information by the same person within 7 working days.	No. Absent from legal framework (Absent from legal framework)
Member States shall ensure that entities in charge of central registers shall only refuse a request to access beneficial ownership information on one of the following grounds: the applicant has not provided the necessary information or documents pursuant to paragraph 1; a legitimate interest to access beneficial ownership information has not been demonstrated; where on the basis of information in its possession, the entity in charge of the central register has a reasonable concern that the information will not be used for the purposes for which it was requested or that the information will be used for purposes that are not connected to the prevention of money laundering, its predicate offences or terrorist financing; one or more of the situations referred to in Article 15 applies; the legitimate interest to access beneficial ownership information granted by the central register of another Member State does not extend to the purposes for which the information is sought; where the applicant is in a third country and responding to the request to access information would not comply with the provisions of Chapter V of Regulation (EU) 2016/679.	No. Absent from legal framework (Absent from legal framework)
In exceptional circumstances to be laid down in national law, where the access to beneficial ownership information would expose the beneficial owner to disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation, or where the beneficial owner is a minor or otherwise legally incapable, Member States shall provide for an exemption from such access to all or part of the personal information on the beneficial owner. Member States shall ensure that such exemptions are granted on a case-by-case basis upon a detailed evaluation of the exceptional nature of the circumstances and confirmation that those disproportionate risks exist. The right to an administrative review of the decision granting an exemption and the right to an effective judicial remedy shall be guaranteed.	No. Absent from legal framework (Absent from legal framework)
Supervision of obliged entities
Each Member State shall ensure that all obliged entities established in its territory are subject to adequate and effective supervision. To that end, each Member State shall appoint one or more supervisors to monitor effectively, and to take the measures necessary to ensure compliance by the obliged entities with Regulations (EU) 2024/1624 and (EU) 2023/1113.	Yes. Article 109 of the AML Law established as supervisory authoriity the National Bank of Serbia for a determined number of entities. Article 110 of the AML Law establishes the rest of the supervisory authorities (Articles 109-110, AML Law amended 2025)
Financial Intelligence Units (FIUs)
Each Member State shall establish an FIU in order to prevent, detect and effectively combat money laundering and terrorist financing.	Yes. The Administration for the Prevention of Money Laundering is hereby established as an administrative authority under the ministry competent for finance. The APML shall perform financial-intelligence activities: it shall collect, process, analyse and disseminate to the competent authorities information, data and documentation obtained in line with this Law, and perform other activities related to the prevention and detection of money laundering and terrorism financing in accordance with law. (Article 72, AML Law amended 2025)
The FIU as the central national unit shall be responsible for receiving and analysing suspicious transaction reports and other information relevant to money laundering, associated predicate offences or terrorist financing.	Yes. If the APML finds that there are reasons to suspect money laundering or terrorism financing in respect of certain transactions or persons, it may request the following from the obliged entity: 1) data from the customer and transaction records kept by the obliged entity based on Article 99, paragraph 1 of this Law; 2) information about the customer’s money and assets held with the obliged entity; 3) data on turnover of customer’s money or assets by the obliged entity; 4) data on other business relations of a customer established by the obliged entity; 5) other data and information necessary for detecting or proving money laundering or terrorism financing. (Article 73, AML Law amended 2025)
The FIU shall be responsible for disseminating the results of its analyses and any additional relevant information to the competent authorities where there are grounds to suspect money laundering, associated predicate offences or terrorist financing.	Yes. If the APML finds, based on the obtained data, information and documentation, that there are reasons to suspect money laundering or terrorism financing in relation to a transaction or person, it is required to inform the competent state authorities thereof in writing, so that they may undertake measures within their competence, and provide them with obtained documentation. (Article 78, AML Law amended 2025)
The FIU shall be operationally independent and autonomous, which means that the FIU shall have the authority and capacity to carry out its functions freely, including the ability to take autonomous decisions to analyse, request and disseminate specific information. It shall be free from any undue political, government or industry influence or interference.	No. The Administration for the Prevention of Money Laundering is hereby established as an administrative authority under the ministry competent for finance. The APML shall perform financial-intelligence activities: it shall collect, process, analyse and disseminate to the competent authorities information, data and documentation obtained in line with this Law, and perform other activities related to the prevention and detection of money laundering and terrorism financing in accordance with law. (Article 72, AML Law amended 2025)
The FIU, regardless of their organisational status, is authorised to have access to the information that they require to fulfil their tasks, including financial, administrative and law enforcement information.	Yes. In order to assess whether there are reasons to suspect money laundering or terrorism financing in relation to certain transactions or persons, the APML may request data, information and documentation necessary for detecting and proving money laundering or terrorism financing, from the state authorities, organizations and legal persons entrusted with public authorities. The APML may request from the authorities and organizations referred to in paragraph 1 of this Article, data, information and documentation necessary for detecting and proving money laundering or terrorism financing, which is related to persons who participated or cooperated in transactions or business activities of persons in respect to whom there are reasons to suspect money laundering and terrorism financing. The authorities and organisations referred to paragraph 1 of this Article are required to provide the APML in writing with requested data, within eight days following the receipt of the request, or to enable the APML access to data and information, free of charge. The APML may request the provision of data in urgent cases within the deadline shorter than stipulated in paragraph 3 of this Article. (Article 74, AML Law amended 2025)
FIUs are empowered to take urgent action, directly or indirectly, where there is a suspicion that a transaction is related to money laundering or terrorist financing, to suspend or withhold consent to that transaction.	Yes. The APML may issue a written order to the obliged entity for a temporary suspension of transaction, including access to a safe-deposit box, if it finds grounded suspicion on money laundering, terrorism financing or predicate criminal offense* with respect to a transaction or person conducting the transaction, of which it shall inform the competent authorities so that they may take follow up measures within their competence. The APML Director may, in urgent cases, issue an oral order for temporary suspension of a transaction, including access to a safe-deposit box, which shall be confirmed in writing on the next working day at the latest. Temporary suspension of a transaction, including access to a safe-deposit box, on the basis of paragraphs 1 and 2 of this Article may last 72 hours following the moment of temporary suspension of a transaction. If the deadline referred to in this paragraph falls on non-working days, the APML may issue an order to extend the deadline for additional 48 hours. During the course of temporary suspension of a transaction, including access to a safe deposit box, the obliged entity is required to abide by the APML orders concerning the transaction or the person conducting it. The competent authorities referred to in paragraph 1 of this Article are required to undertake without delay measures within their competence and to promptly inform the APML thereof. If within the deadline referred to in paragraph 3 of this Article the APML determines that there is no grounded suspicion on money laundering, terrorism financing or predicate criminal offense, the APML is required to inform the obliged entity that it is allowed to conduct the transaction, including the access a safe-deposit box. If the APML does not inform the obliged entity on the results of the actions undertaken within the deadline referred to in paragraph 3 of this Article, the obliged entity is deemed to be allowed to conduct the transaction, including the access the safe-deposit box. The obliged entity may temporarily suspend a transaction, including access to a safe-deposit box, for a maximum of 72 hours if it has reasonable suspicion on money laundering or terrorism financing with respect to a transaction or person conducting the transaction or for whom the transaction is being conducted, and if the suspension is necessary for timely fulfilment of obligations laid down in this Law. (Article 75, AML Law amended 2025)
Mutual legal assistance (MLA) and International Cooperation
Member States shall ensure that the FIU to whom the request is made is legally required to use the whole range of its available powers which it would normally use domestically for receiving and analysing information when it replies to a request for information from another FIU.	Yes. The APML may request data, information and documentation necessary for the prevention and detection of money laundering or terrorism financing from the competent authorities of foreign countries. The APML may only use the data, information and documentation obtained on the basis of paragraph 1 of this Article for the purposes prescribed by this Law. The APML may not disseminate the data, information and documentation obtained on the basis of paragraph 1 of this Article to another state authority without prior consent of the state authority of the foreign country that is competent for the prevention and detection of money laundering and terrorism financing, which provided the data to the APML. The APML may not use the data, information and documentation, obtained on the basis of paragraph 1 of this Article, contrary to the conditions and restrictions determined by the state authority of the foreign country that provided the data to the APML. /// The data, information or documentation related to transactions or persons or their beneficial owners for whom there are reasons to suspect money laundering, terrorism financing or a predicate criminal offense, may be shared with the state authorities of foreign countries competent for the prevention and detection of money laundering and terrorism financing at their written and justified request, or at its own initiative. * (Articles 80-81, AML Law amended 2025)
Member States shall ensure that FIUs are legally required to exchange, spontaneously or upon request, any information that may be relevant for the processing or analysis of information by the FIU related to money laundering, its predicate offences, or terrorist financing, and the natural or legal person involved, regardless of the type of predicate offences that may be involved, and even if the type of predicate offences that may be involved is not identified at the time of the exchange.	Yes. The APML may request data, information and documentation necessary for the prevention and detection of money laundering or terrorism financing from the competent authorities of foreign countries. The APML may only use the data, information and documentation obtained on the basis of paragraph 1 of this Article for the purposes prescribed by this Law. The APML may not disseminate the data, information and documentation obtained on the basis of paragraph 1 of this Article to another state authority without prior consent of the state authority of the foreign country that is competent for the prevention and detection of money laundering and terrorism financing, which provided the data to the APML. The APML may not use the data, information and documentation, obtained on the basis of paragraph 1 of this Article, contrary to the conditions and restrictions determined by the state authority of the foreign country that provided the data to the APML. /// The data, information or documentation related to transactions or persons or their beneficial owners for whom there are reasons to suspect money laundering, terrorism financing or a predicate criminal offense, may be shared with the state authorities of foreign countries competent for the prevention and detection of money laundering and terrorism financing at their written and justified request, or at its own initiative. * (Articles 80-81, AML Law amended 2025)

Legislation

Law on Financing Political Activities, 2011, amended 2014	missing file:
Law on Public Service Broadcasting, 2014, amended 2016	missing file:
Law on the Elections of Members of Parliament, 2000, amended 2011	missing file:
Criminal Code, 2005, amended 2014	missing file:

*Last update: 2017

Asset Recovery

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Asset Offices						100
Confiscation						56
International cooperation						75

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Country score
Asset Offices
Each Member State shall legally designate at least one asset recovery office to facilitate cross-border cooperation in relation to asset-tracing investigations and to conduct asset recovery functions in both criminal matters and civil or administrative matters.	Yes. Serbia has a specialised Directorate for the Management of Seized and Confiscated Assets under the Ministry of Justice, created by the Law on Seizure and Confiscation of the Proceeds from Crime; together with the public prosecutor and police, it fulfils asset recovery functions including tracing, (Law on Seizure and Confiscation of the Proceeds from Crime (Law No. 97/2008), Articles 1, 5 and 8–9.)
Each Member State shall legally designate at least one competent authority to function as an asset management office for the purpose of the management of frozen and confiscated property until the disposal of that property further to a final confiscation order.	Yes. The same law establishes the Directorate as an independent administrative body responsible for managing seized and confiscated proceeds of crime, including storage, safeguarding, (Law on Seizure and Confiscation of the Proceeds from Crime, Articles 8–10 (Directorate for the Management of Seized and Confiscated Assets – competences to manage, safeguard and sell property).)
Confiscation
Member States shall take the necessary measures to enable the freezing of property necessary to ensure a possible confiscation of that property. The freezing measures shall consist of freezing orders and immediate action. (Freezing measures)	Yes. The Law on Seizure and Confiscation provides for temporary seizure of assets upon motion of the public prosecutor, with court orders securing property that may become subject to permanent confiscation, in addition to seizure measures under the Criminal Procedure Code. (Law on Seizure and Confiscation of the Proceeds from Crime, Articles 11–21 (temporary seizure of assets); Criminal Procedure Code,)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of instrumentalities and proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Conviction based confiscation)	Yes. The Criminal Code provides that no one may retain material gain obtained by a criminal offence and that such gain shall be seized on conditions laid down in the Code, (Criminal Code of Serbia, Article 91 (grounds for confiscation of material gain).)
Member States shall take the necessary measures to enable the confiscation of property the value of which corresponds to instrumentalities or proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Confiscation of equivalent value)	Yes. If it is not possible to seize the money, items of value or other material gain obtained by a criminal offence, (Criminal Code, Article 92(1) (seizure of material gain and obligation to hand over other assets of corresponding value or to pay a pecuniary amount).)
Member States shall take the necessary measures to enable the confiscation of proceeds, or other property the value of which corresponds to proceeds, which, directly or indirectly, were transferred by a suspected or accused person to third parties, or which were acquired by third parties from a suspected or accused person. (Third-party confiscation)	Yes. Confiscation of material gain may be ordered from the offender and from any other person to whom the material gain has been transferred or who has acquired it, (Criminal Code, Article 92(2)–(3) (seizure of material gain from persons to whom it has been transferred or who have acquired it, with protection of bona fide acquirers).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of property belonging to a person convicted of a criminal offence where the offence committed is liable to give rise, directly or indirectly, to economic benefit, and where a national court is satisfied that the property is derived from criminal conduct. (Extended confiscation)	Yes. The combination of Criminal Code provisions on material gain and the special Law on Seizure and Confiscation allows for confiscation of property derived from crime, including substitute assets and property held in the name of others, (Criminal Code, Articles 91–92; Law on Seizure and Confiscation of the Proceeds from Crime, Articles 1–3 (scope of offences and proceeds).)
Member States shall take the necessary measures to enable the confiscation of instrumentalities, proceeds or property, or proceeds or property transferred to third parties, where criminal proceedings have been initiated but could not be continued because of illness, absconding, or death of the accused or the limitation period of the offence is below 15 years and has expired. (Non-conviction based confiscation)	No. Confiscation of proceeds is tied to criminal proceedings and to the procedure under the special law; the law is not framed as a general non‑conviction based confiscation regime as understood in international discussions, and confiscation without conviction is not generally available in the situations listed in Article 15 of Directive (EU) 2024/1260. (Criminal Code, Articles 91–93; Law on Seizure and Confiscation of the Proceeds from Crime (procedures linked to criminal proceedings, not a general NCBC regime).)
Confiscation without a prior conviction shall be limited to cases where, in the absence of the circumstances above, it would have been possible for the relevant criminal proceedings to lead to a criminal conviction for, at least, offences liable to give rise, directly or indirectly, to substantial economic benefit, and where the national court is satisfied that the instrumentalities, proceeds or property to be confiscated are derived from, or directly or indirectly linked to, the criminal offence in question. (Non-conviction based confiscation)	No. The special law on seizure and confiscation complements the Criminal Code and Criminal Procedure Code but is not characterised as a confiscation‑only procedure without conviction; it does not match the NCBC model envisaged by Directive (EU) 2024/1260. (Law on Seizure and Confiscation of the Proceeds from Crime, Articles 1–4 (scope and link to criminal proceedings); Criminal Code, Articles 91–93.)
Member States shall take the necessary measures to enable the confiscation of property identified in the context of an investigation in relation to a criminal offence, provided that a national court is satisfied that the identified property is (i) derived from criminal conduct committed within the framework of a criminal organisation and (ii) that conduct is liable to give rise, directly or indirectly, to substantial economic benefit. A ‘criminal offence’ in this case is punishable by deprivation of liberty of a maximum of at least four years. (Confiscation of unexplained wealth)	No. Although the Serbian regime allows confiscation of proceeds from serious offences, including organised crime, there is no distinct unexplained‑wealth confiscation regime that reverses the burden of proof in the sense of Article 16 of Directive (EU) 2024/1260. (Criminal Code, Articles 91–92; Law on Seizure and Confiscation of the Proceeds from Crime (no separate unexplained‑wealth confiscation mechanism).)
Member States are legally required to adopt a national strategy on asset recovery and update it at regular intervals of no longer than five years. (Deadline of 24 May 2027)	No. Serbia has undertaken asset recovery reforms and strategic projects but has not adopted a statutory national asset recovery strategy with a mandatory five‑year (No explicit national asset recovery strategy requirement in the Criminal Code, Criminal Procedure Code or the Law on Seizure and Confiscation of the Proceeds from Crime.)
International cooperation
To facilitate cross-border cooperation, Member States shall legally require measures to enable the swift tracing and identification of instrumentalities and proceeds, or of property which is, or might become, the object of a freezing or confiscation order in the course of proceedings in criminal matters.	Yes. The Law on Seizure and Confiscation and the Criminal Procedure Code allow for seizure and confiscation of proceeds of crime in line with international and regional standards, (Law on Seizure and Confiscation of the Proceeds from Crime, Articles 1–4 and 11–28; Criminal Procedure Code)
Member States shall legally require the necessary measures to ensure that their asset recovery offices provide, upon request from an asset recovery office in another Member State, any information that those asset recovery offices have access to, and that is necessary for the performance of the tasks of the asset recovery office requesting that information	Yes. The Directorate for the Management of Seized and Confiscated Assets and the competent authorities cooperate with foreign counterparts under international and regional instruments, sharing information needed to trace, (Law on Seizure and Confiscation of the Proceeds from Crime, Articles 8–10; MLA provisions implementing UNCAC and Council of Europe)
Member States may legally allow for cost-sharing agreements with other Member States on the execution of freezing and confiscation orders.	No. Serbian legislation on confiscation and mutual legal assistance does not contain a specific statutory rule on cost‑sharing (No explicit cost‑sharing provision in the Law on Seizure and Confiscation of the Proceeds from Crime or Criminal Procedure Code.)
Countries should be able to share confiscated property with other countries, in particular when confiscation is directly or indirectly a result of co-ordinated law enforcement actions	Yes. Serbia (National implementation of UN Convention against Corruption and Council of Europe conventions on confiscation (including asset‑sharing clauses).)

Legislation

Law on Financing Political Activities, 2011, amended 2014	missing file:
Law on Public Service Broadcasting, 2014, amended 2016	missing file:
Law on the Elections of Members of Parliament, 2000, amended 2011	missing file:
Criminal Code, 2005, amended 2014	missing file:

*Last update: 2017

Serbia

Country Facts

Political Financing

Quantitative Data

Primary Metric

Qualitative Data

Bans and limits on private income

Public funding

Regulations on spending

Reporting, oversight and sanctions

Institutions receiving financial reports from political parties and/​or candidates

Is it specified that a particular institution(s) is responsible for examining financial reports and/​or investigating violations?

Other institutions with a formal role in political finance oversight

Sanctions for political finance infractions

Legislation

Financial Disclosure

Quantitative Data

Primary Metric

Alternative Metric

Qualitative Data

Head of State

Disclosure items

Income and Assets

Incompatibilities

Filing frequency

Sanctions

Monitoring and Oversight

Public access to declarations

Ministers

Disclosure items

Income and Assets

Incompatibilities

Filing frequency

Sanctions

Monitoring and Oversight

Public access to declarations

Members of Parliament

Disclosure items

Income and Assets

Incompatibilities

Filing frequency

Sanctions

Monitoring and Oversight

Public access to declarations

Civil servants

Disclosure items

Income and Assets

Incompatibilities

Filing frequency

Sanctions

Monitoring and Oversight

Public access to declarations

Legislation

Conflict of Interest

Quantitative Data

Primary Metric

Alternative Metric

Qualitative Data

Head of State

Restrictions

Sanctions

Monitoring and Oversight

Ministers

Restrictions

Sanctions

Monitoring and Oversight

Members of Parliament

Restrictions

Sanctions

Monitoring and Oversight

Civil servants

Restrictions

Sanctions

Monitoring and Oversight

Legislation

Freedom of Information

Quantitative Data

Primary Metric

Qualitative Data

Scope and Coverage

Institutions receiving financial reports from political parties and/or candidates

Is it specified that a particular institution(s) is responsible for examining financial reports and/or investigating violations?