The 4H view: Everything you need to know about Serbia

EGR has partnered with 4H Agency to bring its readers a series of long-form articles on the requirements and key facts and figures for a host of emerging markets throughout the world.

Tapping into 4H’s talent pool of expert, the articles will outline the regulatory framework and entry requirements for interested parties, as well as an insider’s view on how the market could shape up in the coming years.

Here, the series continues with Serbia, with commentary from 4H’s head of Eastern Europe desk and partner Ivan Kurochkin.

Market overview

Serbia, a landlocked country situated in the heart of the Balkans, has a complex and evolving gambling market. For much of the 20th century, Serbia was part of Yugoslavia, and its regulatory framework for gambling reflected the broader regional policies of the time. 

Initially, the sector was heavily regulated and controlled by the state. However, 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. Also, Serbia’s efforts to regulate its gambling sector more strictly have opened up new opportunities for both domestic and international operators.

As of 2023, Serbia’s population was roughly 6.6 million people, with a GDP of $75.2bn, positioning it as a mid-sized economy in the region. With a GDP per capita of $11,361, Serbia’s consumer base is relatively modest, but the country’s high internet penetration rate – 90% as of 2024 – makes it an attractive market for online gambling operators. 

The Corruption Perceptions Index (CPI) ranks Serbia 104th globally, with a score of 36, indicating that while the market is developing, transparency and regulatory enforcement remain key concerns for international operators.

The Serbian gambling market is diverse, covering a broad range of activities, including land-based casinos, sports betting, and online gambling.

GGR for the Serbian gambling market was estimated to be around $1.03bn in 2023. This figure highlights the growing potential of the market, especially as regulatory reforms continue to shape a more structured and transparent environment.

Regulations

The regulatory framework for gambling in Serbia is built around the Law on Games of Chance, which governs the organization, taxation, and supervision of gambling activities. The government maintains an exclusive right over the national lottery, which is managed by the National Lottery of Serbia.

The local regulator Games of Chance Administration, a division of the Ministry of Finance, is responsible for licensing and ensuring compliance with the law. All gambling activities must be registered, and operators are required to maintain their financial stability by adhering to stringent capital requirements and anti-money laundering (AML) policies.

Licence types

Serbia offers several types of licences for both online and land-based gambling:

• Land-based casino licences (limited to a maximum of 10 casinos, with two already issued)
• Slot machine hall licences
• Land-based sports betting licences
• Online gambling licences, which cover casino games, sports betting, and other forms of online gambling

Licence requirements

The requirements for obtaining a gambling licence in Serbia are stringent and focus on financial stability, transparency, and compliance with responsible gambling measures. Specific requirements include:

• Registration as a legal entity in Serbia
• Capital requirements: Approximately $1.1m for land-based casinos and $278,000 for online operators, slot machines and sports betting
• Financial guarantees: Online operators must maintain a bank deposit or guarantee of roughly $333,500 throughout the licence period
• Thorough background checks for key persons involved in the company, ensuring no criminal history
• Responsible gambling and AML compliance: Operators must ensure compliance with AML regulations and offer responsible gambling tools like self-exclusion options

Licence cost and term

Licences in Serbia are typically granted for 10 years. The fees for these licences vary depending on the type of operation:

• Land-based casino licences require an annual fee starting at $556,000. The licence renewal fee is also $556,000
• Online gambling licences have a monthly fee of approximately $3,000
• Slot machines licences have a monthly fee of $28 per machine
• Sports betting licences have a monthly fee of $110 per betting shop

Taxation

Gambling operators in Serbia are subject to a gambling tax based on GGR. The tax rates vary by sector:

• Land-based casinos are taxed at 25% of GGR. Tax for games in which players compete against each other is 3% of the value of received payments (or the turnover)
• Slot machines are taxed at 10% of GGR, with a minimum monthly fee not less than $45 per machine
• Online gambling is taxed at 15% of GGR
• Sports betting is taxed at 15% of GGR and tax should not be less than $610 per month per betting shop

In addition, players’ winnings from casinos and sports betting are exempt from personal income tax unless they exceed $950, after which a 20% tax applies.

Responsible gambling and AML

Serbia has gradually introduced responsible gambling measures, aligning with international best practices. Operators are required to implement systems that prevent minors from gambling and offer self-exclusion options for players who request them. 

According to local regulations, players may limit the maximum amount they can deposit within a certain period of time, as well as limit the maximum amount of loss they may suffer in a certain period of time and include a ban on access to the gambling or betting platform for a certain period of time or permanently. 

The operator, in turn, is obliged to disable access for given accounts immediately upon receipt of the request for self-exclusion.

AML regulations also play a significant role in the Serbian gambling market. After being removed from the FATF grey list in 2019, Serbia has made significant improvements.

One critical measure is the customer due diligence (CDD) requirement. Gambling operators must verify player identities when transactions – such as deposits or withdrawals – reach around $2,200 or more, whether through a single transaction or a series of related transactions. Operators are responsible for collecting and verifying personal identification information from their players.

In addition to CDD, operators must file suspicious activity reports (SARs) with the Administration for the Prevention of Money Laundering (APML), a department within the Serbian Ministry of Finance. 

Any transaction suspected of being linked to money laundering or terrorist financing must be reported within three days of its execution. The APML also monitors compliance with AML laws and conducts regular evaluations of gambling operators to ensure they follow strict protocols.

Serbia also ensures that operators develop internal systems for detecting potentially risky transactions, which must be regularly updated to reflect the latest AML regulations. 

Compliance failures can result in severe penalties, including fines and possible revocation of licences. These measures reflect Serbia’s commitment to aligning its gambling industry with international AML standards and maintaining the integrity of its financial system.

Marketing and advertising restrictions

Serbia has implemented robust advertising regulations to ensure that gambling promotions do not target vulnerable persons, such as minors, or mislead the public regarding the nature of gambling. Advertising for gambling services in Serbia is subject to several restrictions aimed at protecting vulnerable populations. Key rules include:

• Gambling advertisements must clearly state that gambling is prohibited for minors
• Ads must not falsely suggest that gambling can solve financial problems or represent it as a socially desirable activity
• Advertising is prohibited near schools and institutions that serve minors and is restricted in media aimed at children

However, despite these regulations, the market has not seen widespread or frequent violations in recent years. Authorities, including the Games of Chance Administration, actively monitor compliance, and occasional fines have been imposed on operators that fail to adhere to responsible advertising practices. 

For example, some violations have occurred when ads breached content rules by not including adequate warnings about gambling risks or by positioning gambling as a solution to financial challenges.

These restrictions are seen as part of Serbia’s broader strategy to align its gambling industry with international standards. While the regulatory environment is relatively stringent, it provides clear guidelines that most operators follow, thus avoiding major legal or public controversies.

Market specifics for entry

The Serbian gambling market offers a mix of opportunities and challenges for new entrants. The relatively low barrier for obtaining licences, particularly for online gambling, makes it an attractive destination for operators looking to expand their European footprint. 

However, the market is competitive, with a strong presence of both local 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 practices.

Current numbers of issued licences

• Land-based casino: two
• Land-based sports betting: 19
• Slot machines halls: 61
• Online gambling: 26

The 4H view

On 11 September 2024, the Serbian Ministry of Finance launched a consultation on proposed amendments to the Law on Games of Chance. While it remains uncertain how these changes will affect the legislation and the gambling industry continues to operate under its current regulatory framework, we anticipate that the ongoing discussions and reforms will lead to new developments in the near future.

The anticipated reforms are expected to align Serbia’s responsible gambling policies more closely with international standards. This could involve stricter self-exclusion mechanisms and greater protections for vulnerable players, ensuring a safer gambling environment.

From a market growth perspective, the online gambling sector represents the most promising area. With 90% of the population connected to the internet and a broad cultural acceptance of gambling, the opportunities for online operators are substantial.

However, as international brands increasingly enter the market, local operators will need to differentiate themselves by offering localised services, such as custom payment solutions and marketing strategies that resonate with Serbian players.

Serbia also stands out as a historic hub for esports, serving teams from across Eastern Europe and CIS countries, and as a home to a large number of B2B live casino 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.

Serbia’s commitment to transforming its gambling sector is evident. By fostering a well-regulated environment, the country seeks to create mutual benefits for all stakeholders. For players, this means access to safe and transparent platforms. 

For operators, it provides a profitable and secure market. At the same time, the government gains enhanced oversight, improved consumer protection and increased tax revenues.

Looking ahead, we expect the Serbian gambling market to maintain its competitive edge while remaining accessible, especially for operators that are able to swiftly adapt to regulatory changes. This adaptability will be key to thriving in the evolving legal landscape.

Ivan is one of the founders of 4H Agency, partner and head of the Eastern Europe desk at 4H. After 10+ years’ experience in consulting every type of clients from the testing laboratories to global operators and B2B providers on a variety of matters related to the gambling operations, Ivan has proven himself to be a business-oriented multijurisdictional advisor for entering new markets across the globe.

Ivan’s background helps him to choose the best and most efficient scenarios for expansion to new market or for bringing existing operations of 4H’s clients to a significantly new level. Ivan is also an expert in the field of responsible gambling and frequent author for industry media.