Bosnia and Herzegovina Crypto License

Who Should Consider This Route?

May fit: businesses seeking a non-EU base for exchange, custody or transfers

May not fit: projects requiring EU passporting under the Markets in Crypto-Assets Regulation (MiCA), or other financial permissions

Requires review: international platforms, complex token issuance and mixed payment models

Which Regulatory Route Does Your Project Need?

Territory	Authority	Mechanism	Service scope	Verification status
Republika Srpska (RS)	RS Securities Commission	Provider record	Listed virtual-currency services	Confirmed
Federation of Bosnia and Herzegovina (FBiH)	FBiH Securities Commission	Statutory AML supervision	VASP activities	Comparable registration procedure not verified
Brčko District	Directorate of Finance, Tax Administration	Statutory AML supervision	VASP activities	Filing requirements need confirmation

The Republika Srpska Securities Commission also supervises companies based elsewhere that offer services through a branch in Republika Srpska. It checks that they follow AML/CFT rules and lists registered providers in its official register.

Which Activities Can Be Covered?

The national AML framework covers services provided for others:

Exchange
Exchanging cryptocurrency for fiat or another cryptocurrency

Custody
Holding or controlling customers’ virtual currencies

Trading platforms
Organizing virtual-currency trading

Transfers
Receiving and executing customer transfer orders

Services for token issuers
Providing financial services to help another business offer or sell its virtual currency

Issuing your own token, tokenizing an asset or supporting an initial coin offering (ICO) requires a separate review. The rules depend on what the token represents and your business’s role in the project.

What Do We Need From You?

• Founder, shareholder, ultimate beneficial owner and director identification, residence and background documents
• Ownership chart, existing corporate records and source of funds
• Business model, activities, customers and target markets
• Fiat/asset flows, expected volumes and banking needs
• Existing policies, technology arrangements and intended launch date

How Long Does VASP Registration Take?

Gofaizen & Sherle provides the following estimates for setting up and registering a VASP in Republika Srpska:

• Preparation—2 weeks. We collect your information, confirm the planned activities and prepare the initial documents. Timing depends on receiving complete documents and signatures from you.
• Company Formation—2–3 weeks. We prepare and submit the incorporation application. Completion depends on the notary, registration authority and bank handling the share capital deposit.
• VASP Registration—4–5 weeks. This is the estimated time to prepare the compliance documents and submit your application to the Securities Commission. The Commission’s review may take longer if it needs further information. 

These are planning estimates, not guaranteed deadlines. Bank or EMI account applications follow a separate schedule determined by the provider. Your launch date also depends on completing registration and having the necessary operational arrangements in place.date. Bank/EMI onboarding has a separate timetable. Incomplete documents or authority questions can extend the process.

Which Laws Apply to Your Crypto Business?

Your business must follow Bosnia and Herzegovina’s AML/CFT law, along with the rules that apply where it is established and provides services—Republika Srpska, the Federation of Bosnia and Herzegovina or Brčko District.

Legal basis	Authority	Main function
BiH AML/CFT Law, 13/2024	Territorial supervisors and SIPA’s Financial Intelligence Department	Customer checks, monitoring and reporting
RS Securities Market Law, Article 260b	RS Securities Commission	Provider record and supervision
RS record rules, 4/23, 82/24, 112/25	RS Securities Commission	Filing information and supporting evidence

Current Regulatory Status

• Confirmed: the Commission’s May 27, 2026 notice distinguishes record entry from operating approval
• Territory-dependent: National AML obligations do not establish identical filing procedures everywhere
• Before filing: check current forms, officer evidence and the 2026 fee tariff

What Changes Between Territories?

Location	Additional setup check
RS	D.o.o. formation capital: 1 BAM. Assess registered address, staffing and branch requirements
FBiH	D.o.o. formation capital: 1,000 BAM. Confirm local registration and operational requirements
Brčko District	Confirm district incorporation, tax registration and applicable filings

These are corporate capital rules, not a budget for running regulated activities.

What Continues After Registration?

Obligations depend on services, territory and customer risk:

• Review money-laundering risks, verify customers’ identities, monitor transactions and report suspicious activity
• Keep business and compliance records, and notify the relevant authority of changes to ownership or designated officers
• Maintain the responsible AML function and staff training
• Submit RS annual risk reports and financial filings, with audits where required
• Budget for supervision fees and ongoing compliance

The RS reporting requirements are set out in the Commission’s current reporting rule.

What Could Prevent a Lawful Launch?

• Providing RS services before entry in the record
• Failing AML controls or reporting duties
• Treating registration as permission for unrelated products
• Serving foreign markets without checking their requirements

How Does Banking Support Work?

Banks, electronic money institutions (EMIs) and payment service providers (PSPs) make their own account decisions.

Institution assesses	Gofaizen & Sherle supports
Owners and source of funds	Evidence preparation
Countries, counterparties, volumes and flows	Business-model explanation
Compliance and account purpose	Application documentation

A capital-deposit account, an operating account and a client-funds account serve different purposes. One does not replace the others.

What Taxes Will Your Company Pay?

Tax residence and transaction treatment matter alongside headline rates.

Tax	Treatment to assess
Corporate income tax	10% on taxable profits in RS, FBiH and Brčko
VAT	Standard rate: 17%. Assess each service and any applicable exemption
Dividends	Check recipient status, applicable territorial rules and treaties

VAT treatment depends on the type of crypto transaction, while taxes on profit distributions depend on the applicable rules and the recipient’s circumstances.

Which Alternatives Should Be Compared?

Route	Model and market access	Capital basis	Best fit
Bosnia, RS	Provider record, no MiCA passport	D.o.o.: 1 BAM	Non-EU base
Montenegro	Commission registration, no MiCA passport	Confirm for chosen structure	Alternative regional base
EU MiCA	Crypto-asset service provider (CASP) authorization and cross-border notification	€50,000/€125,000/€150,000 service-class thresholds*	EU expansion
Switzerland	Self-regulatory organization (SRO) affiliation where applicable, no MiCA passport	GmbH: CHF20,000, additional rules may apply	Swiss financial intermediary

*MiCA safeguards must meet the higher of the relevant threshold and one quarter of annual fixed overheads. Corporate formation capital and regulatory safeguards are different measures.