e-Promissory Notes in Serbia – Key Regulatory and Business Implications

In 2025, Serbia introduced a fully electronic framework for promissory notes through binding by-laws adopted by the National Bank of Serbia (“NBS”). The reform establishes a centralized, registry-based infrastructure enabling the issuance, registration, enforcement, and deletion of promissory notes entirely in electronic form.

NBS has clarified that clients who choose to use e-promissory notes will not pay any activation fees, and banks will be obligated to accept e-promissory notes as collateral (e.g. for securing loans).

Legal and Practical Scope

The system is implemented through a package of NBS decisions adopted in 2025, including:

  • the decision establishing the Central Register of Electronic Promissory Notes,
  • amendments governing enforcement from clients’ bank accounts, and
  • amendments to the unified NBS tariff.

These measures provide the legal and technological foundation for a registry-based model, replacing reliance on physical documentation.

The Central Register of Electronic Promissory Notes (“CReM”) functions as the core system infrastructure administered by the NBS.

CReM is a newly developed digital platform enabling the complete lifecycle of a promissory note -creation, issuance, transfer, enforcement and deletion – to be performed electronically, without paper, significantly accelerating business processes and reducing operational costs.

All data on e-promissory notes are stored within CReM as part of the Register of Promissory Notes and Authorizations, which has the legal status of a public book, ensuring full transparency, reliability and legal certainty. E-promissory notes retain their role as credible enforcement instruments. In proceedings, creditors will rely on official NBS extracts. Extracts issued from CReM will function as public and authentic documents, replacing the need for physical or scanned promissory notes in enforcement and court proceedings.

Access is enabled through electronic and mobile banking applications, using qualified electronic signatures, including ConsentID for remote signing.

Implementation Timeline

  • 1 December 2025
    Banks must enable legal entities and entrepreneurs to issue and use e-promissory notes.
  • 1 June 2026
    Banks must:
    • provide access through mobile banking,
    • treat electronic and paper promissory notes equally,
    • process CReM messages within prescribed deadlines.

How Enforcement Works in Practice

If the debtor fails to settle its obligation, the creditor initiates enforcement directly through the bank’s application. The bank forwards the request to CReM, which triggers the enforcement workflow. Once legal conditions are met, the debtor’s account is debited. If insufficient funds exist, the bank automatically submits the case to the NBS for forced collection. After execution, the e-promissory note is automatically deleted from CReM. This process is faster, fully traceable, and eliminates risks of hidden or duplicated documentation.

Banks are obligated to respond to payment orders within strict deadlines defined in the CReM Operational Timeline, ensuring rapid and predictable enforcement.

Conclusion

E-promissory notes introduce a secure, cost-efficient, and regulator-controlled digital alternative to traditional paper instruments. With centralized record-keeping, mandatory bank participation, and automated enforcement, the system provides a significant upgrade in legal certainty, speed, and transparency.

Key Takeaways

  • Serbia has introduced a fully operational e-promissory note system under NBS supervision.
  • E-promissory notes can be used as a functional alternative to paper promissory notes, with equivalent legal effect.
  • Banks and corporate users should prepare for mandatory system availability as of December 2025.
  • Existing security documentation may require review to accommodate electronic promissory notes.