Gaming Law 2024 Comparisons

In recent decades, Serbia has taken significant steps to modernise its gambling laws and bring them in line with international standards. The legalisation of online gambling in 2011 marked a pivotal moment in the development of Serbia’s gambling industry. The country has since emerged as a growing player in the Balkans’ online gambling market. Serbia has always stood out as a historic hub for e-sports, serving teams from across Eastern Europe and Commonwealth of Independent States (CIS) countries, and as a home to a large number of B2B live studio providers due to the absence of a B2B licence and highly favourable business conditions. This has fostered a profitable environment for such businesses, enhancing Serbia’s appeal as a centre for gaming-related ventures.

Also, Serbia’s efforts to regulate its gambling sector more transparently have opened up new opportunities for both domestic and international operators. Serbia’s relatively relaxed advertising regulations compared to other European markets provide more flexibility for promoting gambling services. However, operators should be aware that ongoing regulatory reforms could introduce stricter requirements, particularly around responsible gambling (RG) practices.

In September 2024, the Ministry of Finance released a comprehensive draft proposing significant amendments to the existing gambling legislation. These amendments, currently under review, outline a range of new obligations, increased fees and enhanced control measures for gaming operators. If enacted, they will take effect 30 days post-approval, with by-laws to be adopted within 120 days to guide implementation. Immediate fee increases will boost national revenue, while the new provisions seek to align Serbia’s gambling industry with international standards, prioritising regulatory compliance, social accountability and market transparency.

Online games in the Serbian gambling industry are regulated on the basis of land-based terms, namely “classic games of chance”, “special games of chance” and “prize games”.

Classic games of chances are basically under state monopoly (National Lottery of Serbia), as this sector includes different types of lotteries, tombola-based games and general sports forecasting (which differs from sports betting, as it involves guessing the outcome of sports competitions).

Special games of chance include casinos, sports betting and slot-machines, while prize games are games organised for advertising purposes in which all participants are given the opportunity to earn a predetermined prize in the form of either goods or services.

For the purposes of this guide, prize games will not be reviewed further. Therefore, considering general sectors of online gambling, the Serbian gambling market includes:

• online casinos (slots, poker, etc) – regulated and permitted for licensing;
• online sports betting – regulated and permitted for licensing;
• online bingo and lotteries, other tombola-based games and sports forecasting – regulated but fully covered by state monopoly and therefore restricted;
• fantasy sport – unregulated; and
• social gaming – unregulated.

As indicated previously, Serbia regulates classic games of chance, special games of chance and prize games.

Classic games of chance include:

• lotteries, instant lotteries and other lottery-based games;
• sports betting (guessing the outcome of football and other sports competitions);
• lotto, keno and similar games;
• tombolas, bingo and other similar tombola-based games;
• fonto; and
• short message service (SMS) lotteries.

Special games of chance include:

• casinos, with the permitted types of games being blackjack, American roulette, French roulette, baccarat (chemin de fer), craps, draw poker, Texas hold ’em, ultimate Texas hold ’em, Caribbean diamond poker, casino stud poker, Caribbean 7 stud poker, Omaha poker, three-card poker, “let it ride” poker, sic bo, money wheel, punto banco and Serbian-Russian roulette”;
• sports betting, which can be organised in land-based betting shops for betting on (i) the outcome of sporting events (match results), horse racing and dog racing; (ii) the outcome of other real events, such as dancing, singing and music; and (iii) the outcome of computer-generated virtual events (eg, e-sports); and
• slot-machines, which can be operated in a casino or separately in a slot club.

The key legislation that regulates the gambling industry in Serbia is the Law on Games of Chance 2020 (Law No 18/20; hereinafter referred to as the “Gambling Law”). Additional laws and sub-laws pertinent to the gambling industry include:

• anti-money laundering laws (Law Nos 113/17, 91/19 and 153/20);
• laws limiting the disposal of property in order to prevent terrorism and the spread of weapons of mass destruction (Law Nos 29/15, 113/17 and 41/18); and
• the Regulation on the Types of Games of Chance (Law No 152/20, etc).

According to the Gambling Law, gambling is defined as “games of chance”, which are games in which:

• for a fee, participants are provided with the opportunity to win money, items, services or rights; and
• winning or losing does not depend on the knowledge or skill of the participants, but rather on chance or some uncertain event.

The legal definition of gambling excludes “skill games”, where qualified participants use their knowledge and skills, and the outcome depends solely on their performance. It also excludes “entertainment games”, such as those played on computers and simulators, pinball machines, darts and billiards, where participants pay to play but cannot win money, goods or services – only additional free games of the same type.

The following definitions are relevant to land-based gambling in Serbia:

• classic games of chance are defined as games that involve a large number of participants competing to be the sole or joint winner of a predefined prize fund; and
• special games of chance are defined as games in which the participants play against each other, or against the operator, in order to win a prize dependent on the stakes.

Special games of chance are further defined as follows.

• A casino is a furnished space for organising special games of chance, at tables and using automatic equipment, where the players play against the house or against one another on tables featuring small balls, small dice, cards or other similar items.
• A betting shop is a furnished space for operating sports betting equipped with one or more numbered “pay-in”/“pay-out” counters, used for placing and collecting bets. Participants can bet on the outcomes of sports events, other real events or virtual events suggested by the operator. The outcome of these events must be unpredictable, and neither the operator nor the players can influence it. The potential winnings are set when the bet is placed and cannot be changed thereafter.
• A slot-machine club is a furnished space for operating slot-machines – ie, electromechanical, electronic and similar devices that work based on an algorithm for random events – where the players pay a certain amount to acquire the ability to obtain a win dependent on the game rules.

Under the Gambling Law, online gambling is defined as all games of chance (classic or special) organised by means of electronic communication, such as the internet, telephone, television, radio, SMS or any other form of electronic communication.

Since online gambling is regulated under the general land-based gambling legislation, there are no separate definitions for online gambling offerings as they are considered to be the same as land-based ones (ie, online casinos and casinos, online sports betting, sports betting, etc). Definitions of land-based gambling offerings can be reviewed in 3.3 Definition of Land-Based Gambling.

There are a large number of offences that can be committed by operators or players, ranging from small misdemeanours to crimes. These include:

• operating without a licence;
• transfer of a licence;
• participation in or enabling participation in offshore gambling;

• operating gambling in gambling-free zones;

• allowing minors to gamble;
• non-payment of winnings;
• non-compliance with the requirement regarding the minimum amount of gambling equipment (for land-based operations);

• non-compliance with the special location requirements for gambling establishments; and

• the absence of gambling certification.

There is a general fine ranging from EUR850 to EUR17,000 for breaching the Gambling Law. This fine applies to all misdemeanours except operating without a licence.

In addition, for general offences, the responsible persons (eg, directors or representatives of the operator) shall also pay fines – in addition to the sanction for the company – ranging from EUR42 to EUR1,200.

Unlicensed gambling offences are covered by the Criminal Code of Serbia, and the penalty is up to two years’ imprisonment.

In September 2024, regulatory changes gained momentum with a draft proposal for amendments to the Gambling Law (the “Draft Law”). If approved, these proposed changes aim to limit gambling advertising, protect minors and reduce the visibility of betting ads, aligning the restrictions with those for alcohol and tobacco. These include:

• stricter gambling advertising regulations, including the requirement for additional warning labels;
• a mandatory self-exclusion system and player protection regulations; and
• the introduction of “multi-terminal” devices allowing multiple players to gamble simultaneously, each with separate accounts.

Following this, in October, the gambling regulator clarified the 100-metre distance rule between gambling venues, improving regulatory transparency and engaging directly with operators.

More details regarding forthcoming changes to the Draft Law can be reviewed in 4.3 Recent or Forthcoming Changes, 5.2 Recent or Forthcoming Changes, 6.6 Recent or Forthcoming Changes and 12.2 Recent or Forthcoming Changes.

The key regulatory authority applicable to the gambling sector in Serbia is the Games of Chance Administration under the Ministry of Finance.

The Serbian gambling regulator is committed to creating a balanced environment by enhancing market structure and making legal guidelines clearer. This approach targets both the expansion of the regulated market and the reduction of offshore activity, as well as maximising budget contributions from licensed operators. The regulator has sought to increase fees and enforce compliance while also presenting enticing incentives for licensed operators, such as favourable tax rates and a simplified entry process. Therefore, the Serbian regulatory approach can be considered prescriptive.

As indicated previously, the most recent changes to the Gambling Law expected to enter into force (the Draft Law) include the proposition of the Ministry of Finance to increase fees for licences, emphasising social responsibility through new control measures and restrictions on cash payments.

There are also some new concepts, such as self-exclusion options for online players, video surveillance requirements and prohibitions on inter-player games (eg, Texas hold ’em poker), which reflect efforts to enhance regulatory oversight and prevent money laundering.

Further notable changes focus on RG, including limits on alcohol sales within gaming facilities and mandatory distances from educational institutions for betting locations. Organisers could be also required to obtain prior consent for specific operational changes, such as the organisation of tournaments and provision of account registration services, and will face enhanced penalties for non-compliance.

For further details regarding the Draft Law please, review 3.7 Recent or Forthcoming Legislative Changes, 5.2 Recent or Forthcoming Legislative Changes, 6.6 Recent or Forthcoming Legislative Changes and 12.2 Recent or Forthcoming Changes.

The following licences are applicable to the gambling industry in Serbia:

• licence for online gambling (any type of activity);
• licence for land-based casinos;
• licence for land-based sports betting;
• licence for land-based slot-machines; and
• licence for lotteries.

There is no licence for B2B gambling providers in Serbia.

The availability of gambling licences in Serbia depends on the type of licence. Only Serbian companies can apply for a licence, and the restrictions are as follows.

• Licence for online gambling – available without restrictions except for online lotteries, which are considered part of the land-based “lottery monopoly”.
• Licence for land-based casino – the maximum amount of casino licences that can be issued is restricted to ten, and two of these have already been issued. Moreover, such licences are issued only via government tender (auction), which further complicates the process of obtaining a licence.
• Licence for land-based sports betting – no restrictions.
• Licence for land-based slot-machines – no restrictions.
• Licence for lottery – under state monopoly (Državna Lutrija Srbije).

Please note that since lottery licences are unavailable due to the state monopoly, details of these licences will not be provided in this guide.

The licence duration is ten years for all available licences, with the exception of the land-based sports betting licence for horse racing – this can be granted to the operator for the duration of the equestrian racing season.

Key application requirements for operators and suppliers vary depending on the type of activity, though there are some general ones. For example, the Gambling Law generally requires gambling operators to ensure that their founders, owners, key associates and appointed persons have clean legal records, particularly regarding serious criminal offenses, AML and terrorism financing violations. Certification from a state authority confirming compliance must be submitted for each application.

Further, basic documents and information must be submitted with a gambling licence application, as follows:

• business and legal entity information – business name, registered address, the decision on the entry of the legal entity into the appropriate register, and share capital details;
• ownership and financial structure – evidence of ownership structure down to the beneficial owner, as per the Central Register of Beneficial Owners, and the incorporation status of the legal entity;
• financial statements – balance sheet, profit and loss statements for the previous year, and audit reports for the financial statements of the founder or members for the previous two years (if applicable), including financial statements covering a period of up to six months before the request;
• criminal record check – confirmation from the competent state body that neither the applicant nor key associates thereof have been convicted of relevant criminal offenses or violated money laundering and terrorism financing regulations; if this cannot be provided, an affidavit under oath may be submitted, with the possibility of additional evidence requirements of the authorities; and
• game rules – the rules of the relevant game(s).

There are also some specific requirements in addition to those listed in the foregoing, which vary depending on the offering.

• Applicants for online gambling licences shall provide:
1. procedures for identifying and registering players, handling interrupted communication, and system protection and backup;
2. details for restoring saved positions;
3. an impact study addressing the prevention of adverse effects on players;
4. proof of ownership or usage rights for premises housing online gambling equipment;
5. the fee for approval of the licence (EUR2,500 per month);
6. share capital of not less than EUR250,000;
7. a deposit (guarantee) in a Serbian bank dedicated to ensuring the payment of winnings to players, and settlement of obligations for the duration of the licence period, of not less than EUR300,000; and
8. a “risk deposit” for each day of operation of not less than EUR10,000.
• Applicants for land-based casino licences shall provide:
1. proof that the applicant or its majority founder holds a share in at least one casino and has at least five years of experience operating casino games;
2. a three-year business plan for the legal entity;
3. a bank guarantee covering the minimum licence fee for the tender (licence fee may not be less than EUR500,000);
4. share capital of not less than EUR1 million;
5. a deposit (guarantee) in a Serbian bank dedicated to ensuring the payment of winnings to players, and settlement of obligations for the duration of the licence period, of not less than EUR300,000; and
6. a risk deposit for each day of operation of not less than EUR50,000.
• Applicants for land-based sports betting licences shall provide:
1. proof of ownership, use, or lease of appropriate premises, with a minimum of 30 betting shops, unless applying for a sports betting licence for horse racing;
2. a list of pay-in/pay-out desks and evidence of compliance with numerical labelling requirements;
3. evidence of the facility location for betting games (for details, see 5.1 Premises Licensing);
4. the fee for approval of the licence (EUR100 per month per betting shop);
5. share capital of not less than EUR250,000;
6. a deposit (guarantee) in a Serbian bank dedicated to ensuring the payment of winnings to players, and settlement of obligations for the duration of the licence period, of not less than EUR5,000 (except for operators with at least 300 betting shops, who shall provide a deposit of EUR1.5 million); and
7. a risk deposit for each day of operation of not less than EUR150 per pay-in/pay-out desk.
• Applicants for slot-machine licences shall provide:
1. proof of ownership or lease for at least 100 slot-machines within Serbia, with details on their location;
2. evidence of compliance with technical standards and machine certification;
3. the fee for approval of the licence (EUR25 per month per slot-machine);
4. share capital of not less than EUR250,000;
5. a deposit (guarantee) in a Serbian bank dedicated to ensuring the payment of winnings to players, and settlement of obligations for the duration of the licence period, of not less than EUR500 per slot-machine (except for operators with at least 2,000 slot-machines, who shall provide a deposit of EUR1 million); and
6. a risk deposit for each day of operation of not less than EUR100 per pay-in/pay-out desk.

Licence issuance is generally 30 days after finalisation of the application. The regulator will review the uploaded documents and issue either an approval or refusal, or a request for additional documentation/information.

The fees associated with gambling licence applications are as follows:

• fee for gambling licence application – EUR3;
• fee for individuals requesting interpretation, clarification or opinion regarding the application of gambling regulations – EUR17
• fee for legal entities or entrepreneurs requesting interpretation, clarification or opinion regarding the application of gambling regulations – EUR140;
• fee for the issuance of documents (decision on the approval to operate or termination of the right to operate, or decisions amending the approval) – EUR6; and
• fee for issuing reminders to pay outstanding administrative fees – EUR3.

Gambling licence fees shall be paid within eight days of receiving the decision on approval of the licence, as follows:

• online gambling licence – EUR2,500 per month;
• land-based casino licence – decided via tender but not less than EUR500,000;
• land-based sports betting licence – EUR100 per month per betting shop; and
• slot-machine licence – EUR25 per month per slot-machine.

There are no annual gambling license fees, but rather only monthly ones. As specified earlier, the fees are as follows:

• online gambling licence – EUR2,500 per month;
• land-based casino licence – decided via tender but not less than EUR500,000;
• land-based sports betting licence – EUR100 per month per betting shop; and
• slot-machine license – EUR25 per month per slot-machine.

Casinos

The government determines casino locations through a tender process to support regional development. All gaming tables must be certified and approved before use. Each table must display a label with essential details: label number, operator name, certification laboratory, unique serial number, casino location and licence validity details.

Casinos must be organised so that gaming areas, guest spaces and staff areas form a single, cohesive unit. Entry to the casino must be controlled by a reception service that identifies all individuals (players, guests, etc). A casino must be situated in a dedicated building or within an at least three-star hotel. Essential facilities include a cash register, exchange office and secure area for valuables and audio-video recordings. Operators must also provide continuous audio and video surveillance over all tables and slot-machines, as well as monitoring entries, exits, players and visitors to ensure compliance with gambling laws.

Sports Betting Shops

Betting shops must be at least 200 metres from educational institutions and 100 metres from other betting shops, slot-machine clubs or casinos. Operators are required to use a certified information and communication system that securely stores, archives and exchanges data with the regulator’s software for supervision purposes.

Each pay-in/pay-out desk in a betting shop must be pre-approved by the regulator and visibly labelled with information including the printer type, manufacturer, operator name, serial number, location and licence validity details. Operators are also required to provide continuous audio and video surveillance at the betting shop, with special monitoring of pay-in/pay-out desks, entries, exits and visitor activities to prevent any rule violations.

Slot-Machine Clubs

Slot-machine clubs must be at least 200 metres from educational institutions and 100 metres from other slot-machine clubs, betting shops or casinos. Operators must implement a certified information and communication system for their slot-machine operations.

Each club must have a minimum of five slot-machines from the same operator, and any slot-machine introduced for the first time must be less than one year old. Machines can only be used if certified, with a visible label displaying the label number, operator name, certification lab, serial number, location and licence validity details. Continuous audio and video surveillance must be maintained over all slot-machines, as well as monitoring entries, exits and visitor activities in the club.

The Draft Law amending the current Serbian Gambling Law, published in September 2024, introduces several major amendments to the land-based gambling regulations, as follows.

• Mandatory requirement for consent from the regulator prior to organising tournaments in casinos.
• The right of the regulator to monitor video surveillance in the casino in real time through a link, which the operator will be obliged to provide.
• New fees for obtaining licences, with a doubling of the licence fees for casinos (proposed minimum licence fee of EUR1 million), as well as slot-machines (proposed fee of EUR50 per machine) and sports betting (proposed fee of EUR200 per betting shop).
• Tax increases are also proposed; the details can be reviewed in 12.2 Recent of Forthcoming Changes.
• The word casino, synonyms and translations thereof, and derived words can be used only by licensed casino operators, inside or outside of casino buildings, with some restrictions.
• New restrictions are introduced for serving food and alcoholic beverages in slot clubs and betting shops, and only low-alcohol beverages (less than 5% volume) are allowed. It is forbidden for the gaming area to be directly connected to the area where food and drinks are served.

• The Draft Law also specifies which educational institutions are subject to the minimum distance requirement (from slot clubs and betting shops), applying to all institutions attended by children, minors and young adults up to the age of 19. As proof of adherence to the distance requirement, in addition to a certificate from the Republic Geodetic Institute, it will now be necessary to provide opinions from traffic experts.

• Any change in the capital structure of the gambling operator is subject to the prior approval of the regulator. Along with a request for approval, it will be necessary to submit proof of compliance with tax obligations and a certificate showing the criminal record of the intended purchaser of shares.

In Serbia, there is one type of online B2C online gambling licence. This general licence allows the operation of online casinos, online slots and online betting.

The application requirements for an online gambling licence are specified in 4.7 Application Requirements. In addition, online gambling operators are obliged to use an information and communication system, which must be certified and approved prior to use.

There is no relevant B2B licence provider in Serbia. However, the regulator maintains a list of 11 authorised entities permitted to repair gambling equipment. These authorised repairers are approved but not licensed by the regulator, similar to the approval process for certified laboratories.

Serbian gambling legislation does not regulate affiliates.

Serbian gambling legislation does not regulate white-label providers.

According to Serbian regulations, online operators shall use an information and communication system for operating online gambling that securely stores, archives and exchanges data with the regulator’s software for further supervision of compliance with gambling and AML regulations.

Such information and communication systems must meet the following conditions:

• use legally procured software of appropriate quality for secure electronic exchange of data with the regulator’s software;
• have adequate responsiveness and availability for the electronic exchange of data with the regulator’s software;
• enable direct and secure data exchange with the regulator’s software;
• utilise a process protecting against unauthorised use of the system and data loss; and
• provide security mechanisms for sending unique secret keys.

The Draft Law proposed several changes to the online gambling industry. If approved, Serbian online operators will be mandated to provide RG tools, such as a facility for self-exclusion for players, either permanently or temporarily (minimum of 24 hours); financial limits on payment and loss amounts; and a process for reporting self-excluded players to the regulator.

Under the Draft Law, licensing fees and the overall financial burden of online operators also increased:

• the deposit to guarantee winnings payments has been raised from EUR300,000 to EUR500,000;

• the monthly licence fee increased significantly from EUR2,500 to EUR10,000; and

• taxation also increased, as detailed in 12.2 Recent or Forthcoming Changes.

Finally, the regulator will be able to easily ban foreign entities operating unregistered online games, and inspectors can block IP addresses and prevent related bank transactions to stop offshore gambling.

Serbian legislation includes key RG requirements, where all employees of gambling operators who have direct contact with players must be trained in preventive measures against addictive disorders related to problem gambling and must be in contact with players regarding gambling problems.

Measures regarding RG in Serbia include the following:

• operators are mandated to prohibit minors (those under 18 years of age) from participating in gambling;
• operators are obliged to disable access for player accounts immediately upon receipt of a request for temporary or permanent self-exclusion from players;
• operators are mandated to constantly display the time and date while players are playing;
• operators shall comply with financial limits reported by players on a daily, weekly and monthly basis; and

• operators shall also provide, on their premises/websites, information on addiction prevention and contact information for health ministry-approved institutions for the treatment of addiction.

There are also some responsible advertising rules, mandatory notification of the bank regarding the participation of minors in gambling and rules pertaining to the prevention of addictive disorders, etc.

The Gambling Law provides the following main tools aiding RG:

• self-exclusion – the operator is obliged to disable access to a given account immediately upon receipt of a request for self-exclusion, for a certain period of time or permanently, where self-exclusion depends on the player’s request;
• financial limits – a player may limit, in writing or electronically, the maximum amount he or she can pay within a certain period of time, or the maximum losses he or she may incur within a certain period of time, where the operator is obliged to allow participants to set financial limits; and
• advertising restrictions, which are mainly used for protecting children and minors (restriction of advertising near schools, health or other institutions, and on websites intended for children and minors); the advertisements must not suggest solutions to professional, economic or personal problems.

Recent changes mainly concerned advertising procedures. Advertising rules have tightened, mandating that all gambling advertisements carry warnings about addiction and the prohibition of underage gambling. Compliance with these provisions has specific deadlines, most notably a 15-month transition period for fulfilling capital, security and surveillance requirements.

The key AML legislation applicable to gambling operators is the Law on Prevention of Money Laundering and Terrorist Financing (Law No 113/17), the AML Law (Law No 153/20) and the Law on Restriction of Disposal of Property for the Prevention of Terrorism and Proliferation of Weapons of Mass Destruction (Law Nos 29/15, 113/17 and 41/48).

There is also a rulebook for complying with the AML Law and some guidelines to assess the risk of money laundering and terrorist financing for taxpayers who operate online or land-based gambling.

According to the AML Law, gambling operators should ensure that they comply with the following.

Reporting Suspicious Transactions

Operators must report to the AML regulator any transaction where there are reasonable grounds to suspect money laundering or terrorism financing, as soon as it is executed and no later than three days after execution.

Operators are obliged to develop a list of indicators for identifying persons and transactions for which there are grounds for suspicion of money laundering or terrorist financing. The gambling regulator maintains a list of indicators for recognising persons and transactions for which there is a basis for suspicion of money laundering and terrorist financing in the case of online or land-based gambling.

Player Verification

Operators must ensure that personal identification data is verified by inspecting the relevant documents. The person whose identity is being verified must be present during the inspection. If there is cause to doubt the credibility of the document used for verification, a written statement on the truthfulness and reliability of the data and document must be obtained.

Conducting Customer Due Diligence

Operators are mandated to undertake customer due diligence measures when a player withdraws winnings or make deposits to their account – or both – in amounts of at least EUR2,000, regardless of whether a single transaction or a series of interrelated transactions are involved.

Serbia has recently introduced, and is expected to further align with, European AML standards, primarily driven by the EU’s Sixth Anti-Money Laundering Directive (AMLD6) and national policy updates. Key forthcoming changes include enhancing risk-based approaches to customer due diligence and introducing stricter requirements regarding beneficial ownership transparency. This means that online casino operators in Serbia may soon need to adjust their AML frameworks to accommodate these elevated standards, including adopting a more robust transaction monitoring system.

Additionally, Serbia’s Administration for the Prevention of Money Laundering (APML) has emphasised its commitment to Financial Action Task Force (FATF) standards, while Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL) assessments encourage ongoing improvements to Serbia’s AML/Combating the Financing of Terrorism (CFT) systems, fostering compliance with global AML requirements. This will involve refining the collection of data on customers’ financial activities and enhancing reporting consistency across operators, which will likely require updates to operators’ suspicious transaction reporting (STR) protocols.

The primary regulators in the advertising sector are the Regulatory Authority for Electronic Media and the gambling regulator.

According to the Law on Advertising, advertising is the presentation of information – in any form – associated with business or professional activities designed to encourage the sale of goods and services, as well as the transfer of rights and obligations. An “advertising message”, meanwhile, is a notice with advertising content, regardless of form or the manner or means by which it is transmitted.

Key advertising provisions under Serbian legislation relevant to gambling operators are generally restrictive in nature. The main regulations pertain to:

• safety for minors – gambling ads must not target minors, must include a warning about age restrictions and cannot appear in places accessible to children, etc;
• prohibition of unlicensed gambling – advertising unlicensed gambling activities is strictly prohibited; and
• responsible advertising – ads must not mislead about the odds of winning, imply that skill can affect outcomes or suggest gambling as a solution to financial or personal problems, etc.

For a more detailed overview of the gambling-related advertising regulations, please review 9.4 Restrictions on Advertising.

The main restrictions on advertising are imposed by the Gambling Law itself. According to this Law, it is prohibited to:

• advertise gambling without making reference to the ban on the participation of minors;
• advertise unlicensed gambling activities;
• advertise gambling without a warning about problem gambling; and
• advertise gambling in facilities where bets are received and payments are made.

Several restrictions are also imposed by the Law on Advertising:

• gambling shall not be advertised in open areas, except in places that are at least 100 metres from the nearest preschool, school, health or other institution intended for children or minors;
• gambling shall not be advertised on websites intended for children or minors;
• gambling shall not be advertised on radio and television programmes, or in print media, intended for children;
• gambling advertising must contain a warning about the prohibition of participation by children and minors;
• gambling advertising must not exploit the inexperience or lack of knowledge of children or minors;
• gambling advertising must not use children or minors; and
• gambling advertising must not characterise participation in gambling activities as a means of maturation for children or minors.

Regarding general restrictions on the content of advertising, the following rules apply in Serbia:

• advertisements must not contain unfounded statements about the chances of winning or income that players can expect when playing;
• advertisements must not suggest that skill can affect the outcome of a game if this is not the case;
• advertisements must not represent gambling as a socially desirable activity; and
• advertisements must not suggest that participation in gambling is a substitute for employment or financial investment or a solution to professional, financial or personal problems.

In Serbia, violations of gambling advertising regulations may result in various penalties, depending on the nature and severity of the offense.

Advertising that targets minors, lacks mandated warnings or uses inappropriate product placements can lead to the following penalties:

• legal entities face fines ranging from EUR2,500 to EUR17,000, depending on the infraction’s severity; and
• individuals and entrepreneurs may incur fines ranging from EUR427 to EUR4,272, and additional legal measures might also apply.

In addition, the law allows for protective measures that may restrict certain activities of an offender for up to one year. In cases of repeated or severe violations, the authorities might also publicly announce the offender’s sanctions.

Recent changes in Serbian advertising regulations for gambling focus on bolstering responsible advertising practices and ensuring clear boundaries to minimise potential harms. Under the updated laws, gambling advertisements must include visible messages promoting RG and discouraging underage gambling. Specific ads targeting – or appearing to target – minors are strictly prohibited, as is any content that could glamorise excessive gambling. Moreover, stringent limitations are in place for ads that could encourage addictive behaviours, or that frame gambling as a guaranteed means of financial success.

In addition to these content-related changes, technical measures are being implemented to control where and when these ads appear, particularly in relation to geo-targeting and time restrictions.

In Serbia, when there is a change in control or acquisition involving a gambling company, specific disclosure and compliance requirements must be followed. The most critical requirement is to notify and obtain clearance from the Serbian Commission for the Protection of Competition (CPC), if certain thresholds that relate primarily to revenue and market share are met. Any transactions that significantly affect market dynamics, including those exceeding such thresholds, must receive CPC approval to proceed. This aligns with Serbia’s merger control regulations, which closely follow EU competition standards.

Notification for merger clearance is mandatory if:

• the combined annual turnover of the involved entities exceeds the set threshold (EUR100 million and a Serbian turnover of at least one party exceeding EUR10 million, or EUR20 million and a Serbian turnover of more than EUR1 million of at least two parties); and
• the parties hold a significant local market share.

Controversial cases usually conclude within a month, as decided by the authorities.

The CPC can launch an in-depth review, which can take up to four months. In cases where a takeover bid is involved, disclosure to and approval from the Serbian Securities Commission are necessary, which can add up to 70 days to the overall process if competing bids emerge.

Failure to notify or attempting to close a transaction without clearance can lead to penalties of up to 10% of the company’s local annual turnover, as well as corrective actions like forced divestitures to restore competition. There are limited exceptions for urgent public bids, where transactions may proceed under stringent conditions (eg, restricted voting rights until final clearance).

The main triggers of a change in corporate control for gambling companies include acquisition thresholds, mandatory reporting obligations and regulatory review processes. These requirements apply particularly when an acquisition involves a significant percentage of a company’s share capital or voting rights, as this can impact the company’s licensure and regulatory standing.

When changes in corporate control occur, Serbia’s regulatory framework mandates disclosure to the relevant authorities, including the CPC if the transaction may affect market competition. For gambling companies, additional regulatory scrutiny may be involved, especially if the acquisition triggers a requirement for a “fit and proper” evaluation, which assesses the acquirer’s suitability based on their financial standing, previous conduct and ability to uphold regulatory standards.

Transactions involving licensed entities often require the approval of the gambling regulator to ensure compliance with the Gambling Law and the AML Law, which can extend the review timeline. Additionally, Serbian legislation obligates companies to notify relevant bodies if there is a change in beneficial ownership beyond specified thresholds, ensuring that new ownership structures are transparent and compliant with existing regulatory obligations.

The primary requirements for passive investors in acquisitions or control changes are as follows.

• Notification of significant shareholding: Passive investors acquiring a substantial portion of shares (typically more than 10%) may need to disclose their stake to regulatory authorities, such as the CPC. This requirement ensures transparency and allows regulators to monitor potential impacts on market control.
• Fit and proper requirements: Even passive investors may need to undergo a fit and proper assessment if they cross certain ownership thresholds (eg, acquiring a stake that grants significant influence over company decisions). This assessment, overseen by Serbian gambling authorities, examines the investor’s financial stability, legal standing and compliance history to ensure the investment aligns with regulatory standards.
• Compliance with AML requirements: Passive investors, particularly those gaining beneficial ownership, may have obligations under Serbian AML/FATF laws. They must provide documentation confirming the source of funds, particularly if they reach thresholds that could affect company control.
• Non-interference assurance: If a passive investor’s stake approaches levels that could influence corporate governance, they may be required to provide written assurances to regulators that they will remain non-interfering, meaning they will not participate in strategic or operational decisions.

The obligation for all stakeholders, including passive investors, to maintain a certain level of share capital in cases of ownership changes has increased. Enhanced controls over investments, compliance with the gambling regulator’s requirements and transparency of the ownership chain are some of the changes introduced to bolster transparency and financial accountability.

Further legislative developments are expected to continue refining these measures, supporting the Serbian goal of creating a robust regulatory framework while fostering a safe and transparent gambling environment.

Gambling Regulator - The Games of Chance Administration

This authority is responsible for overseeing all gambling activities in Serbia, including issuing licences, enforcing compliance with the Gambling Law, monitoring RG practices and imposing sanctions for violations. It also supervises advertising in the gambling sector, ensuring that it aligns with regulatory standards.

AML Regulator – The Administration for the Prevention of Money Laundering

This body enforces Serbia’s AML regulations. It requires gambling operators to comply with AML and counter-terrorist financing obligations, which include reporting suspicious transactions, conducting due diligence and maintaining transparency in financial activities. The AML regulator also audits and inspects operators to ensure compliance.

Data Protection Authority – The Commissioner for Information of Public Importance and Personal Data Protection

This authority oversees data privacy and ensures that gambling operators manage personal data responsibly, in compliance with Serbian data protection laws. It handles matters related to data breaches, consent for data usage and the rights of individuals regarding their personal information.

Advertising Regulator - The Regulatory Authority for Electronic Media

This authority monitors and regulates gambling advertisements across electronic media, ensuring they meet content standards, do not target minors and promote RG. In addition to its licensing and compliance role, it regulates gambling advertisements more broadly, including online and offline ads, enforcing content restrictions and compliance with ethical advertising standards specific to gambling.

Sanctions for violations in the Serbian gambling industry, including in relation to advertising, AML and RG, are generally enforced by the gambling regulator and other regulatory bodies, like the APML and the courts.

Enforcement actions typically involve administrative fines and licence suspensions – or revocations – for operators who do not adhere to regulations, including for advertising or AML. The most common sanctions are imprisonment, financial penalties, confiscation and warnings.

For example, in February 2024, the gambling regulator – along with police departments – uncovered illegal gambling operations in Belgrade and Kraljevo, detaining one individual and temporarily shutting down two facilities. Equipment for poker, bingo and sports betting was seized, and criminal charges were prepared for unauthorised operation. Earlier, in September 2021, the same co-ordinated operation led to the discovery of 17 illegal casinos in Smederevo. Authorities seized slot-machines, gambling equipment and a large sum of money, filing criminal charges against those responsible.

Historically, Serbia has actively enforced sanctions, especially under its evolving AML frameworks aligned with FATF standards. Enforcement involves monitoring financial transactions related to gambling and imposing compliance obligations on casinos and betting operators to prevent money laundering and other illicit activities.

For misdemeanours such as unlicensed gambling marketing, failure to pay winnings and violating RG provisions, legal entities shall be fined amounts ranging from EUR852 to EUR17,000. A licensed gambling operator’s responsible person can be fined amounts ranging from EUR43 to EUR1,278 for failure to pay winnings.

Please review 3.5 Key Offences and 3.6 Penalties for Unlawful Gamblingfor additional details of enforcement.

In 2020, the AML framework was updated to align with EU directives, introducing among other things fines for non-compliance that range from modest penalties to substantial fees depending on the nature and frequency of the infractions.

Additionally, the Serbian government recently adopted a national risk assessment to help guide enforcement and reduce money laundering risks in gambling and real estate. The Ministry of Finance and the State Lottery of Serbia conduct regular audits ensuring compliance, and penalties for violations include substantial fines, criminal charges and potential operational bans for businesses that fail to meet compliance standards.

The following taxes are applicable to gambling operators:

• online gambling – 15% gross gambling revenue (GGR) for online betting and 10% GGR for online casinos and online slots, but not less than EUR10,000 per month;
• land-based casino – 3% of the income for games where players compete against each other (eg, poker), and 25% GGR for all other casino games;
• land-based sports betting – 15% GGR, but not less than EUR550 per month per betting shop; and
• land-based slot-machines – 10% GGR, but not less than EUR40 per month per slot-machine.

There is also a general 15% income tax for all businesses with Serbian tax residency.

More recent changes to taxation in the gambling field in Serbia – namely new tax amounts – came with the publication of the Draft Law in September 2024:

• online gambling – 15% GGR for all types of games (replacing the previously lower tax rate for online betting);

• land-based casino – tax for a new game sector (tournaments in arcades in which participants are in competition), 25% GGR for all types of games (replacing the previously lower tax rate for poker-like games) and a minimum fee of EUR2,000 for table games;

• land-based sports betting – 15% GGR, but not less than EUR1,000 (replacing the rate of EUR550); and
• land-based slot-machines – 15% GGR (instead of 10% GGR), but not less than EUR100 (instead of EUR50).

Serbian gambling legislation does not regulate personal licences.

Please see 13.1 Types of Authorisations and Licences.

Please see 13.1 Types of Authorisations and Licences.

Please see 13.1 Types of Authorisations and Licences.

Please see 13.1 Types of Authorisations and Licences.

Please see 13.1 Types of Authorisations and Licences.