COREDO > Cryptocurrency Licence (VCSP) in Bosnia and Herzegovina

Cryptocurrency Licence (VCSP) in Bosnia and Herzegovina

Bosnia and Herzegovina is one of the most dynamically developing jurisdictions in Southeast Europe in the field of virtual asset regulation. The country, which received EU candidate status in December 2022, is building its own regulatory framework for the cryptocurrency business outside the scope of the MiCA regulation, opening attractive opportunities for entrepreneurs from around the world.

COREDO specialists will help you register a company in Bosnia and Herzegovina, prepare a complete set of documents, and obtain VCSP status within the timeframes established by the regulator.

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Cost of the service
from 24 500 EUR

Regulatory Framework for Cryptocurrency Activities

The legal foundation for the cryptocurrency business in Bosnia and Herzegovina consists of two key regulatory acts operating at different levels of state governance.

At the state level, the Law on the Prevention of Money Laundering and Terrorist Financing (Zakon o sprečavanju pranja novca i finansiranja terorističkih aktivnosti) entered into force in February 2024. This law brought national legislation into compliance with FATF recommendations and designated virtual asset service providers (VASP) as obliged entities. Under Article 5 of this law, cryptocurrency companies are required to conduct customer identification, carry out money laundering and terrorist financing risk assessments, and provide information to state authorities.

At the level of Republika Srpska, amendments to the Law on Securities Market were adopted in May 2022 and published in the Official Gazette of Republika Srpska (Službeni glasnik Republike Srpske, No. 63/2022). The law defines virtual currency as a digital record of value that is not issued or guaranteed by a central bank or other state authority, which natural and legal persons accept as a means of exchange. The Securities Commission of RS was granted authority to supervise legal entities providing virtual currency exchange services and electronic wallet custody, and maintains the corresponding register.

It is important to note that the Federation of Bosnia and Herzegovina (the second entity of the country) and the Brčko District have not yet established an analogous VCSP registration system. Therefore, cryptocurrency business registration is carried out in Republika Srpska.

Types of Cryptocurrency Licences (VCSP)

The VCSP licence in Republika Srpska covers a broad range of activities related to virtual currencies. The licence holder is entitled to provide the following services:

Custody and administration of virtual currencies on behalf of third parties (custodial services).

Operation of trading platforms enabling clients to conduct transactions with virtual currencies.

Purchase and sale of virtual currencies for fiat currency.

Exchange of virtual currencies for other virtual currencies.

Transfer of virtual currencies, including acceptance and execution of purchase and sale orders on behalf of third parties.

Underwriting and placement of virtual currencies, including services related to token issuance.

The unified VCSP regime allows a company to conduct multiple types of activities simultaneously under a single registration, simplifying the operational structure of the business.

Advantages of the Jurisdiction

Bosnia and Herzegovina offers a number of competitive advantages for cryptocurrency business operators.

Absence of MiCA restrictions.

Since the country is not an EU member, the MiCA regulation (Regulation (EU) 2023/1114) with its stringent requirements for share capital and operational resilience does not apply. This significantly lowers the entry barrier for new market participants.

Low tax burden.

The corporate income tax rate in Republika Srpska is 10%. There are no special taxes on cryptocurrency operations — transactions with virtual currencies are classified as operations with intangible assets under the Profit Tax Law. Holding cryptocurrencies alone is not a taxable event.

Minimal capital requirements.

The minimum share capital for company registration in Republika Srpska is 1,000 BAM (approximately EUR 500), which is significantly lower than the requirements in most other European jurisdictions.

No physical office requirement.

Registration and obtaining VCSP status does not require a physical office — a registered office is sufficient, allowing the business to be managed remotely.

Fast registration timelines.

The total timeline for obtaining VCSP status is 1 to 3 months, which is considerably faster compared to most licensed EU jurisdictions, where the process may take 6 to 12 months.

EU candidate status.

Bosnia and Herzegovina received EU candidate status in December 2022, and in March 2024 the European Council decided to open accession negotiations. This creates the prospect of gradual integration into the single European market.

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Cost of COREDO Services

The cost of COREDO’s comprehensive service package for obtaining a cryptocurrency licence (VCSP) in Bosnia and Herzegovina starts from EUR 24,500 + VAT.

The package includes the following services: preparation of documents for registration and incorporation of a new company in Bosnia and Herzegovina (remote registration available); provision of a registered office for one year; payment of state fees related to company registration and licence acquisition; assistance in opening a bank account in Bosnia and Herzegovina — corporate and segregated; full legal support throughout the VCSP licensing process; preparation of standard internal documentation, including Terms of Service and AML/CFT policy; company registration and incorporation in accordance with the country’s legislation.

The stated cost and timelines may vary depending on the specifics of a particular project. Contact our specialists for an individual estimate.

Payment Terms

COREDO offers a staged payment system ensuring transparency of financial relations at each stage of the engagement:

40% — advance payment before the start of document preparation and company registration.

40% — interim payment before submission of the application to the Securities Commission of RS.

20% — final payment after receiving a positive decision from the regulator and the company’s entry into the VCSP register.

Additional services are paid for by mutual agreement of the parties.

Requirements for the Applicant

To obtain VCSP status in Republika Srpska, the applicant must fulfil a number of mandatory requirements.

Legal entity registration.

The company must be registered in Republika Srpska in accordance with local legislation. International business companies (IBC) are not eligible for VCSP status.

Management and beneficial owners.

The company’s directors and founders must have an impeccable business reputation. The ownership structure must be disclosed and information about the ultimate beneficial owners (UBO) must be provided.

Appointment of an AML officer (MLRO).

The company must appoint a Money Laundering Reporting Officer with appropriate qualifications and experience in the field of AML/CFT.

Internal policies and procedures.

The company is required to develop and implement internal AML/CFT policies, customer identification (KYC) procedures, risk assessment methodology, and a description of operational processes.

Bank account.

A corporate bank account must be opened in Bosnia and Herzegovina for conducting operational activities.

List of Required Documents

To begin the process of company registration and obtaining a VCSP cryptocurrency licence, the client must provide COREDO with the following documents and information:

Three proposed company names.

Identity documents of the company’s directors and founders — a photo or scan of a passport and identity card or driving licence (both sides).

Proof of residential address of directors and founders, dated no more than three months prior (bank statement, utility bill, or landline telephone bill).

Proof of funds of the founders — bank statement for the last three months or a tax declaration.

A detailed description of the proposed business activities (business plan).

Information about the AML officer (MLRO), including a CV with experience in AML/CFT.

A completed and signed KYC form.

A draft of internal AML/CFT policies and customer identification procedures.

A description of the ML/FT risk assessment methodology.

The regulator may request additional documents during the review process. It is in the client’s interest to provide them as promptly as possible.

Procedure for Obtaining a VCSP Licence

The process of obtaining a cryptocurrency licence in Bosnia and Herzegovina with COREDO’s support includes several sequential stages.

Preliminary consultation and project assessment (1–2 days).

COREDO experts analyse the client’s business model, determine the optimal company structure, and prepare a project roadmap. An initial compliance risk assessment is conducted at this stage.

01

Company registration in Republika Srpska (2–5 weeks).

COREDO carries out the full cycle of legal entity registration: preparation of incorporation documents, registration in the register of legal entities, obtaining a registered office, and opening a bank account. Registration can be conducted remotely.

02

Preparation of compliance documentation (in parallel with Stage 2).

COREDO’s legal team develops a complete package of internal policies and procedures: AML/CFT policy, KYC and customer identification procedures, risk assessment methodology, description of business processes and operational procedures.

03

Application submission and interaction with the regulator (4–6 weeks).

The prepared document package is submitted to the Securities Commission of Republika Srpska. COREDO manages communication with the regulator, responds to enquiries, and supplements the document package as necessary.

04

Obtaining VCSP status and entry into the register.

Following a positive decision by the Commission, the company is entered into the register of virtual currency service providers and receives the right to conduct licensed activities.

05

The total timeline of the procedure is 1 to 3 months, depending on the complexity of the project and the promptness of document provision.

Our Experts

The process of obtaining a VCSP cryptocurrency licence in Bosnia and Herzegovina is supported by COREDO’s leading specialists.

Pavel Kos

Head of Legal. Pavel has been working at COREDO since 2017 and possesses deep expertise in financial licensing and cryptocurrency regulation across dozens of jurisdictions. He oversees the legal support of projects from initial consultation through licence acquisition and subsequent compliance servicing. LinkedIn:

Basang Ungunov

Lawyer. Basang specialises in the preparation of legal documentation for cryptocurrency and financial companies, including the development of internal AML/CFT policies, legal opinions, and supporting documents for regulators. LinkedIn:

Frequently Asked Questions

Are cryptocurrencies recognised as legal tender in Bosnia and Herzegovina?

No, cryptocurrencies are not legal tender and do not have the status of money in Bosnia and Herzegovina. However, their use for trading and investment purposes is not prohibited. Virtual currencies are defined in the legislation of Republika Srpska as digital records of value that natural and legal persons are entitled to accept as a means of exchange.

Why is the VCSP licence issued specifically in Republika Srpska?

Republika Srpska is the only entity of Bosnia and Herzegovina that has established a fully functioning registration system for virtual currency service providers. The Securities Commission of RS has maintained the VCSP register and supervised their activities since 2022. The Federation of Bosnia and Herzegovina and the Brčko District have not yet implemented an analogous system.

Is physical presence in Bosnia and Herzegovina required to obtain the licence?

No, the process of company registration and obtaining a VCSP licence can be carried out remotely. COREDO provides a registered office and full support without the need for the client’s personal presence.

What taxes do cryptocurrency companies pay?

The corporate income tax rate in Republika Srpska is 10%. No special taxes on cryptocurrency operations have been established — profit from virtual currency operations is taxed on a general basis as income from operations with intangible assets. Simply holding cryptocurrencies is not a taxable event.

What is the timeline for obtaining a VCSP licence?

The total timeline is 1 to 3 months and depends on the complexity of the project, the promptness of document provision, and the regulator’s current workload. Company registration takes 2–5 weeks, and the application review by the Securities Commission takes 4–6 weeks.

Does the VCSP licence allow serving clients from EU countries?

The VCSP licence does not automatically grant the right to provide services in EU countries (unlike CASP passporting under the MiCA regulation). However, a company with a VCSP licence may serve clients from various countries, provided it complies with the legislation of the jurisdictions where its clients are located. A separate CASP licence may be required for operating directly in the EU market.

What obligations arise after obtaining the licence?

After registration as a VCSP, the company is required to comply with AML/CFT legislation: conduct customer identification (KYC), carry out transaction monitoring, submit suspicious activity reports (SAR), maintain up-to-date internal policies, and ensure the MLRO’s qualifications. The regulator has the right to conduct inspections to verify compliance with these requirements.

Can COREDO help with opening a bank account?

Yes, as part of the comprehensive service package, COREDO provides assistance in opening a corporate and segregated bank account in Bosnia and Herzegovina. Our specialists liaise with banks and help prepare the necessary document package.

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COREDO has been operating in the legal and compliance services market since 2016, providing professional support for obtaining cryptocurrency licences in dozens of jurisdictions. Our specialists are ready to conduct a preliminary assessment of your project and provide an individual consultation on obtaining a VCSP licence in Bosnia and Herzegovina.

Contact us for a free consultation: info@coredo.eu | +420 228 886 867