Crypto license in Bosnia
and Herzegovina

Bosnia and Herzegovina (BiH) consists of two entities (the Federation of BiH and Republika Srpska (RS)) plus Brčko District. Virtual currency services are licensed only in RS, as only the RS authorities have established a regulator for crypto activities. In RS, virtual assets were formally recognized in 2023 (via amendments to the Securities Market Law) and are governed by the national AML/CFT law (amended February 2024). Any operator (exchange, wallet, custodian, etc.) must form a local company and register with the RS Securities Commission (Komisija za hartije od vrijednosti) to provide crypto services.

Regulatory Framework and Scope of License

The legal basis for crypto licensing in BiH/RS is twofold: a state-level AML/CFT law (Feb 2024) and the RS Securities Market Law. Both laws define “virtual currency service providers” (VCSPs) and the required compliance measures. AML legislation (effective Feb 2024) explicitly addresses virtual currencies and VASPs, aligning with FATF standards. Under RS law, the Securities Commission maintains a register of VCSPs and issues the permits (entries in the register) needed to operate. In practice, RS uses a registration/notification system: within 30 days of company incorporation, a provider must notify the Securities Commission of its intent to offer crypto services and submit the required documentation. Only registered companies may legally conduct crypto activities.

Licensed crypto services include a broad range of activities. Specifically, a licensed Virtual Currency Service Provider (VCSP) in RS may offer:

• Custody/Wallet Services: Holding or managing virtual currencies on behalf of clients (wallet depository services).
• Trading Platforms: Operating an exchange or trading platform for buying/selling virtual currencies.
• Currency Exchange: Converting virtual currencies to/from legal tender.
• Crypto-to-Crypto Exchange: Swapping one virtual currency for another.
• Transfer Services: Receiving and executing orders to transfer or trade virtual currencies on behalf of third parties.
• Token Issuance Services: Assisting with the sale or offering of new virtual currencies (ICO/IEO support services).

These activities essentially cover the same categories targeted by EU MiCA (exchange, custody, wallet, transfer, token issuance), making RS an attractive MiCA‑alternative jurisdiction.

Advantages of the Republika Srpska Jurisdiction

In Bosnia and Herzegovina, virtual currency services are licensed in Republika Srpska (RS). For crypto entrepreneurs, RS combines a supportive legal framework with cost efficiency and access to growing regional markets.

• Stable, pro-business environment & clear crypto rules: Bosnia and Herzegovina offers political and economic stability, while RS provides a favorable, straightforward AML/CFT framework that reduces procedural hurdles compared to many EU regimes.
• Wide service scope: RS law permits exchanges, custodial wallets, platform operations and related virtual-asset services under a single regime.
• Low setup and operating costs: Minimum share capital is BAM 1,000 (≈€500) and a virtual office is sufficient for registration, keeping startup expenses low. Overall labor, office and admin costs in Bosnia further optimize budgets.
• Attractive taxation: Corporate income tax in RS is 10%. Personal income and dividend withholding tax are also a flat 10%, helping firms price competitively.
• Payment and banking access: Companies can open local RS bank accounts and work with EU electronic money institutions for efficient fiat on- and off-ramps.
• Growing local adoption: Crypto usage is steadily rising among businesses and consumers in Bosnia, expanding the addressable market for licensed platforms.
• Strategic market reach: From RS, operators enjoy cost-efficient access to both EU and neighboring Balkan markets.

Taken together, these advantages make Republika Srpska a cost-effective, EU-adjacent base for both startups and established operators, including those planning for MiCA alignment.

Company Formation & Key Requirements

To apply for a crypto license, you must first incorporate a company in RS (typically a d.o.o. – LLC). Key setup requirements include:

• Ownership & Management: At least one individual director is required. The director need not be a local resident permanently but must visit RS briefly to notarize formation documents. Corporate shareholders are allowed (100% foreign ownership permitted).
• Capital: The statutory minimum share capital is BAM 1,000 (≈€500). This must be paid into a blocked RS bank account before registration.
• Registered Office: No physical office is needed. A local virtual office (registered address and mail handling) satisfies legal requirements.
• Mandatory Staff: The company must employ an AML Officer (Money Laundering Reporting Officer, MLRO) under a local contract. (Fluency in Bosnian/Serbian/Croatian is required.) A professional bookkeeper/accountant must also be engaged from day one to handle taxes and reporting (can be outsourced).
• AML/CFT Policies: Before applying, the firm must develop and document robust compliance programs. Required documents include a written AML/CFT policy, risk assessment, customer due diligence procedures, data protection policy, and internal control manuals. These establish the framework for ongoing compliance.

Documents needed: Founders must prepare certified copies of passports (or business registration docs for corporate owners), powers of attorney, and corporate records (registers of shareholders/directors). For the license application itself, expect to submit a detailed business plan, technical infrastructure description, financial model, AML/KYC manuals, and proof of management/owner integrity. Authorities pay particular attention to the backgrounds of directors/owners and the adequacy of AML controls.

Crypto License in Bosnia and Herzegovina Factsheet