Reporting Obligations to the National Bank of Serbia for Loan Agreements with Non-Residents

If you, as a resident of the Republic of Serbia, plan to conclude a framework loan agreement with a non-resident (foreign creditor), it is essential to know that you are obliged to report this credit transaction to the National Bank of Serbia (NBS).

What Does the Regulatory Framework Say?

In accordance with the Decision on Reporting on Foreign Credit Transactions, the NBS has established the procedures, deadlines, and reporting forms for loans obtained from abroad.

Key Requirement:

Within 10 days from any of the following events:

• conclusion, amendment, or termination of the agreement;
• loan disbursement or repayment;
• or cessation of obligations for other reasons (e.g., debt offset, transfer of claims, etc.),

you must submit the appropriate documentation and reporting forms to the NBS.

What Forms Are Submitted and When?

1. Credit Debt Report (Form KZ-2)

This report must be accompanied by the following documents:

• A copy of the loan agreement or other document confirming the debt;
• Proof that the foreign creditor is registered in accordance with the laws of their country (only for the first report regarding that non-resident);
• A decision from the governing body of the resident-debtor (if the borrower is a bank or legal entity under state influence), including details on the amount, purpose, and terms of the loan;
• A decision regarding the issuance of a guarantee or surety (if the loan is secured by one);
• A plan for the use of funds, except in the case of short-term credit lines, revolving loans, or activated foreign guarantees.

2. Report Amendment (Form KZ-5)

If there is a change to a previously reported loan or termination of the agreement, you must submit:

• An annex to the contract or document detailing the amendment or termination;
• Updated decisions from the governing bodies (if applicable).

3. Specification to the Report (Form KZ-7)

This form is required when:

• There are multiple creditors or borrowers involved in the transaction;
• The funds are used for multiple purposes;
• The loan is a syndicated loan provided by a group of foreign creditors through an agent.

4. Usage and Repayment Realization (Form KZ-3B)

Used to report:

• Actual usage of loan funds and repayment schedule;
• Cessation of obligations due to reasons other than repayment, such as:
  • debt offset,
  • claim transfer,
  • repayment by a third party, etc.

Supporting documentation must be attached in such cases.

Conclusion

Reporting foreign credit transactions to the NBS is not only a legal obligation, but also part of the national system for monitoring foreign currency flows.
If you are entering into a loan agreement with a non-resident, make sure to submit all required documentation and forms within 10 days. Doing so helps you stay compliant and ensures transparency in your international financial operations.

Practical Tips:

• Keep track of deadlines — 10 days go by quickly;
• Maintain proper records of all contractual changes;
• Consult professionals in foreign exchange operations if you’re unsure about any aspect of your obligations.

For additional information or support regarding reporting to the National Bank of Serbia, feel free to contact the Creative Finance team.
Our team of experts is at your disposal for any questions, assistance with preparing the required documentation, and ensuring timely reporting.