COVID-19 Update #49: Serbia/Montenegro/Bosnia and Herzegovina

Changes to the yesterday report are marked.


  • 10114 registered cases.
  • State of emergency lifted.
Health measures
  • Self-isolation at home or quarantine for 14 days for those who enter the country, except for:
    • crew members in international road, rail, water and air transport;
    • Serbian or foreign agricultural workers and owners of agricultural land across the border, subject to proof of land ownership or confirmation of the owner that the person crossing the border works on the land;
    • Serbian cross-border and foreigners with a valid work permit employed in Serbia, subject to the obligation to present at the border crossing proof of work engagement;
    • Persons on humanitarian aid visits, invited by or granted a special permit by the Serbian authorities.
  • Self-isolation at home for a period of 14 days for health professionals, prison guards, officials of the Ministry of Internal Affairs and military personnel, after entering the country or exposure to COVID-19 positive persons but show no symptoms.
  • Self-isolation at home can be suspended before its expiry to those going abroad, if they show no symptoms of COVID-19.
  • Self-isolation at home for 14 days for cured patients.
Movement of people
  • Total closure of borders, except for road transport crews, foreigners who own agricultural land in Serbia and those with a valid work permit employed in Serbia and other persons with special permit.
  • Foreigners entering the country will have to present negative PCR testing not older than 72 hours, while Serbian citizens must either present negative PCR test not older than 72 hours or stay in quarantine for 14 days upon entry.
  • Foreign crew transiting Serbia by inland waterways cannot be replaced within Serbia; 14 days of self-isolation at home or quarantine upon disembarking for Serbian crew members.
  • Ban on gatherings of more than 50 people (indoors and outdoors). Public gatherings must be notified to the police 5 days in advance.
  • Movement of asylum seekers and irregular migrants housed in asylum centers and reception centers in Serbia is temporarily restricted, and an increased surveillance and security of these facilities established. These categories of people will be allowed to leave the facilities on an exceptions only basis and for a limited period of time (e.g. visit to a doctor), with a special permission of the Commissariat for Refugees and Migration of the Republic of Serbia. Access to asylum centers is restricted.
  • Employees in healthcare and social security sectors and members of police force who are on sick leave because of COVID-19 infection contracted as a result of work-related exposure are entitled to salary in lieu equal to 100% of their salary (as opposed to 65% when illness is work unrelated).
Transport and international traffic
  • Intercity bus operators under the obligation to ensure at least 25% of the registered schedule, until 1 September.
  • Serbian Chamber of Commerce will merge the procedures for adjustment of schedules in intercity transport of passengers for 2020 and 2021.
  • The audit of individual licences for international cargo transport for 2020 that was due in April will be done simultaneously with the June audit.
  • CEMT certificates on the capacity of cargo vehicles and trailers for road transport, issued for the purpose of  using the CEMT multilateral quota in the current year, which expired or will have expired between 12 March 2020 and 29 June 2020 shall be deemed to be valid until 30 June 2020. The efficiency of CEMT multilateral quotas will not be assessed during the state of emergency.
  • All border crossings (road, river and rail) closed from 8 a.m. 20 March 2020, except for road transport crews and other persons with special permit.
  • Controlled reopening of airports for commercial flights announced to begin on 18 May 2020, when Air Serbia will commence flights to London, Frankfurt, Vienna and Zurich. The airports are currently open for:
    • Cargo and mail transport;
    • Search and rescue;
    • Humanitarian flights;
    • Emergency medical transport;
    • Technical landing and positioning of Serbian aircrafts;
    • Emergency landing of aircrafts;
    • State aircrafts and special purpose flights.
  • Air carriers will be obliged to obtain approval of the Civil Aviation Directorate of the Republic of Serbia (CAD) and the Ministry for Transport for each flight, and submit to CAD a special permit from the Government for carriage of passengers without residence in Serbia and an affidavit attesting that the carrier notified the passengers on the conditions for entry into Serbia.
Courts, notaries, bailiffs
  • Procedural deadlines in judicial proceedings that were suspended for the duration of the state of emergency resume as of today.
  • Preclusive procedural deadlines in administrative proceedings that start running from the service of process or a receipt of particular procedural notice will, if the process was served or notice received during the state of emergency, start running on 21 May 2020.
  • Precautionary procedural deadlines for the taking of an administrative act, termination of administrative proceedings or decision-making upon procedural remedies, will be considered expired on 6 June 2020.
  • Recommendation to bailiffs to suspend debt collection and other enforcement actions.
  • Certification of signatures, manuscripts and transcripts before notaries, as well as hearings in non-contentious cases suspended, except in particularly urgent and justified cases.
  • Schools closed until the end of school year, except for the end of the year grading and high school entrance exams.
  • Universities are allowed to organize lectures and exams from 15 May 2020 provided they follow all prescribed protective measures.
Work place
  • Draft decree imposing significant OHS measures on employers published.
  • Recommendation to employers to compensate full salary and not just 65% to employees who are on sick leave because of COVID-19 infection contracted as a result of work-related exposure.
  • Recommendation to employers to allow employees whose work at workplace is required during the state of emergency to use the remainder of their 2019 annual leave by 31 December 2020 (statutory cut-off date in normal circumstances is 30 June 2020).
  • Recommendation to employers to allow employees exhaust annual leave before sending them to forced leave of absence.
  • Employers who employ persons who did not have the status of employees in the course of 2019 until 6 July 2020 will qualify for tax incentives even though the original deadline for such qualifying new employment expires on 30 April 2020 (see our earlier newsletter on the topic).
Trade and hospitality
  • Price control imposed for protective equipment and disinfectants until 18 May 2020. Prices can only be raised within the limits of the annual inflation rate.
  • Limitation on purchases of protective equipment (10 masks/protective gloves per person) and disinfectants (2 large packs/5 small packs per person).
  • Exemption on payment of custom duties for ethyl-alcohol ›80%.
Financial measures

Fiscal incentives (see our separate newsletter)

  • Deferral of payroll tax and social security contributions for March, April and May 2020, or April, May and June 2020; repayment in 24 instalments starting on 4 January 2021.
  • Deferral of 2020 corporate income tax advance instalments due in March, April and May 2020 until the final deadline for submission of 2020 CIT return. Companies whose fiscal year does not correspond to calendar year may defer their obligation to pay 2020 CIT advances due on 15 April, 15 May and 15 June, respectively, until the deadline for submission of final CIT return for the relevant tax period. Deferred tax obligation is payable from the end date of the deferral period, in not more than 24 instalments. No interest on the tax obligation accrues during the deferral and repayment periods.
  • VAT relief on donations during COVID-19 crisis.

Direct financial aid (see our separate newsletter)

  • Three net statutory March 2020 minimal wages per each full-time employee (and proportionally for each part-time employee) to entrepreneurs and SMEs, payable over a period of three months.
  • Three times 50% statutory March 2020 net minimal wage to large companies per each full-time employee (and proportionally for each part-time employee) sent on forced paid leave in the period March-May 2020), payable over a period of three months.
  • Direct aid can be used only in conjunction with fiscal aid.

Conditions for fiscal and direct aids

  • Commercial entity qualifies for the aid if it has not reduced the employee headcount in the period from 15 March 2020 until 10 April 2020 for more than 10%. Furthermore, the entities which avail themselves of the aid measures but then reduce their employee headcount in the period from 15 March 2020 until the end of October 2020 for more than 10% stop qualifying for the aid and must repay all received aid, with default interest. Fixed-term employees whose contracts expire during the relevant period do not count towards the 10% threshold.
  • Commercial entity that applies for fiscal and direct aid may not pay out dividends to its shareholders in the course of 2020, except in the form of shares.

Payment moratoriums

  • Three-month moratorium on debt to banks and financial leasing companies.
  • Moratorium on loans granted by the Republic Development Fund until 30 September 2020.
  • Interest-free three-month moratorium on payment of utility bills for retirees. Interest will not be calculated and a 5% discount will be granted to all Serbian citizens who pay their electricity bills for March, April and May by 30 June 2020.
  • Interest on tax debt reduced to benchmark interest rate of the National Bank of Serbia (normally, the interest rate is equal to NBS‘ benchmark rate plus 10 percentage points).

Other financial and monetary measures

  • Easier rules for issuance of corporate ‘Corona bonds’ (see our  newsletters here and here).
  • National Bank of Serbia reduced benchmark reference rate to 1.5%.
  • Special capital adequacy rules for exposures on corporate EUR or EUR-denominated private sector corporate loans granted after 1 January 2021.
  • During the state of emergency, the Deposit Insurance Agency may invest foreign exchange assets it manages into securities issued by the Republic of Serbia without limitation (normally, it cannot invest more than 1/4 of its assets into the state paper).
  • State guarantees to banks for loans to entrepreneurs, SMEs and agricultural households (see our separate newsletter).
  • Subsidized loans and direct aid to agricultural households.

Subsidized working capital loans

  • The Government of Serbia ear-marked RSD 24 billion for subsidized working capital loans to be disbursed via the Development Fund of the Republic of Serbia to entrepreneurs, SMES, registered agricultural households and registered cooperatives, in each case provided they have financial statements for at least two fiscal years (except for entrepreneurs that do not prepare financial statements) and are solvent and not under financial reorganization measures. Loans will be repayable in 24 monthly instalments, after 12-month grace period. Annual interest rate is 1%. Maximum loan amount per SME borrower is RSD 1 million (RSD 200,000 for entrepreneurs and agri-cooperatives). Maximum loan amount per group of related borrowers is RSD 10 million for entrepreneurs and micro companies, RSD 40 million for small enterprises and RSD 120 million for medium enterprises. The condition is that the borrower has not reduced the number of employees since 16 March 2020 until the application for the loan and during the entire loan repayment period for more than 10%. Loans in the amount of RSD 25 million must be secured with pledge or mortgage. Loan applications can be made until the earlier of 10 December 2020 and distribution of all available funds ear-marked for this programme.
  • Commercial entity qualifies for subsidized loan if it has not reduced the employee headcount in the period from 15 March 2020 until the expiry of three months from the loan disbursement for more than 10%. Fixed-term employees whose contracts expire during the relevant period do not count towards the 10% threshold.
  • Commercial entity that applies for a subsidized loan is not allowed to pay out dividends to its shareholders in the course of 2020, except in the form of shares.

Other direct aid measures

  • EUR 100 direct aid to each adult citizen with permanent residence in Republic of Serbia as of 25 April 2020. Retirees and social aid beneficiaries receive this aid automatically on 15 May 2020, while other citizens have to apply for the money via call centre or e-mail of the Treasury Department in the period from 15 May until 5 June 2020.
  • Direct aid package to be extended to include three monthly instalments of RSD 30,000 each to be paid to independent artists via local self-governments. Details still to be hammered out.
  • One-off aid in the amount of RSD 4,000 (cca. EUR 34) to retirees.
  • 10 % salary increase for healthcare sector starting from 1 April 2020.
Corporate law, reporting and professional licenses
  • Deadlines extended for:
    • Regular shareholders’ assembly meeting – until the expiry of 90 days from the end of the state of emergency (5 August 2020);
    • Filling of the annual audited financial statements for joint-stock companies and investment funds until the expiry of 60 days from the end of the state of emergency (6 July 2020).
    • Filing of financial statements for other entities:
      • 90 days from the end of the state of emergency (5 August 2020) for annual financial statements;
      • 120 days as from the end of the state of emergency (4 September 2020) -for consolidated financial statements;
      • 30 days from the end of the state of emergency (6 June 2020) for extraordinary financial statements (e.g. in case of liquidation or status change).
    • Tax returns:
      • when financial year corresponds to calendar year – until the expiry of 90 days from the end of the state of emergency (5 August 2020);
      • when financial year is different from calendar year – until the expiry of 120 days from the end of the state of emergency (4 September 2020);
      • for entrepreneurs who keep books – until the expiry of 90 days from the end of the state of emergency (5 August 2020).
    • Licences of certified auditors which expire during the state of emergency will remain valid until the expiry of 30 days from end of the state of emergency (6 June 2020);
    • Licences of real estate evaluators which expire during the state of emergency and within the period of 30 days from the end of the state of emergency will remain valid until the expiry of 60 days from the end of the state of emergency (6 July 2020).
Other measures
  • All identity documents of Serbian citizens (ID cards, passports, driver’s licenses, vehicle permits and weapon certificates) which expired during the state of emergency will be considered valid if the renewal requests are made by 6 June 2020. Registration stickers for registered vehicles will be issued exclusively at technical inspection outlets, until 1 July 2020.
  • Foreign citizens whose legal status in Serbia expired during the state of emergency can submit request for the approval/renewal of the status (e.g. temporary residence permit) until 6 June 2020 and will be considered to legally reside in Serbia until the decision based on the request is rendered
  • The National Bank of Serbia issued a recommendation to voluntary pension funds to refrain from dismissing members who are temporarily late with payment of contributions.
  • The Serbian Business Registers Agency reopens for direct contract with clients on 11 May 2020.
  • Elections scheduled for 21 June but election campaign activities still suspended, most likely until 11 May 2020.
  • Travel agencies will provide replacement of cancelled travel arrangements paid before 15 March until by the end of 2021 or refund by 15 January 2022.


  • 324 registered cases.
Health measures
  • Until 18 May 2020, Montenegrin nationals and foreigners with temporary or permanent residence who enter Montenegro on or after 28 March 2020 to be isolated for 28 days (previously, 14 days). Until 18 May 2020, Montenegrin citizens and foreign citizens with residence permit in Montenegro may enter the country only under special organization and must go into a quarantine upon the entry.
  • Quarantine for persons who have been or are suspected to have been in contact with infected persons or with persons suspected to be infected. After the expiry of the quarantine, the persons have to self-isolate at home for additional 14 days if they do not exhibit COVID19 symptoms.
  • Institutional isolation is mandatory for asymptomatic COVID19 positive persons who were previously in quarantine, self-isolation, or hospital treatment.
  • Publication of the identity (name and address) of the persons in isolation.
  • Strict control of compliance. Obligation of the authorities to file criminal charges for non-compliance.
  • Commercial shops, markets, banks, post offices, state and municipality authorities, and other retail businesses have to put in place protective measures (social distancing, protective masks, use of disinfectants).
  • Compulsory sale of protective equipment and disinfectants owned by wholesale drug stores to the public health system, at market prices.
  • Recommendation for citizens to wear masks, whether store-bought or homemade. If mask is not available, citizens are advised to cover their mouth with a scarf, in order to minimise the risk of transmission of the coronavirus.
Movement of people
  • Entry to Montenegro possible only to Montenegrin nationals with special permit, foreigners with permanent or temporary residence in Montenegro, foreign sailors in transit who sign-off in ports of Bar, Budva, Kotor, Luka Kumbor – Portonovi, and Tivat (Gat I and Gat II), as well as foreign truck drivers, with special measures of health sanitary monitoring.
  • Ban on any organised cross-border passenger transport until 18 May 2020, except for charter flights for return of Montenegrin citizens to Montenegro and foreigners to their home countries, subject to special permit.
  • Ban on international passenger travel until 18 May 2020, except for announced arrival of Montenegrin citizens subject to obligatory quarantine.
  • Ban on public passenger intercity transport. Conditional lifting of the ban on public rail transport announced for 1 June 2020.
  • Public passenger transport and transport by private vehicles reopens only inside the regions (coastal, central, and north) on 11 May 2020.
  • Public waterways passenger transport reopens on 11 May 2020.
  • Ban on intercity transport by private vehicles except for transport of goods, employees working outside their place of residence and people returning to their place of residence until 18 May 2020.
  • Vrela Ribnička, a neighbourhood in Podgorica, sealed.
  • Until 18 May 2020, curfew imposed between 11 p.m. and 5 a.m. every day,  except for (i) employees performing regular work tasks, (ii) employees of foreign diplomatic and consular missions, (iii) essential workers (health workers, inspectors, police, army, communal workers,  firemen, journalists and guest in media shows); all three groups with confirmation from the employer, and (iv) those caring for persons with health conditions, as evidenced by the confirmation issued by the general practitioner; (v) pet walks for a maximum of 60 minutes; and (vi) children with autism and persons in wheelchair accompanied by one person.
  • Ban on public gatherings until 18 May 2020; only solo walks  permitted, except (i) if persons are from the same household, from 4 May 2020; (ii) for employees performing work tasks; (iii) children up to twelve years of age and children with autism and other disabilities, who may be accompanied by one adult from the same household; and (iv) for persons in wheelchair who may be accompanied by one person.
  • Religious ceremonies allowed but protective measures have to be taken (notice on maximum number of persons has to be placed, social distancing, one person per 10 square meters, mandatory disinfectants and masks; up to 20 persons in the open space which belongs to the building).
  • Beaches and outing spots closed until 18 May 2020. Conditional lifting of the ban on beaches and beach bars announced for 18 May 2020.
  • Ban on gatherings in private spaces, including homes, for persons who are not members of the same household, until 18 May 2020.
  • Ban on visits to hospitals and social and child-care institutions.
  • Ban on visits to prisons except for attorneys and court-appointed experts.
  • In state administrative bodies, limited number of people allowed on the premises (one person per 10 square meters), and screens between employees and customers. Employees are obliged to wear masks while on the premises.
  • Funerals only within family.
  • Maximum two adults can be in a passenger vehicle at the same time.
  • Until 18 May 2020, ban of sports and recreational activities in public spaces, except for individual recreational activities subject to respecting social distancing measures. Pools, sports and recreational facilities reopen on 6 May 2020 but no audience allowed, maximum 12 people to attend a training at the same time in the same room, 10 square meters per athlete, 30 -minute breaks between trainings,  no sharing of the equipment.
  • Entry ban for cruisers and yachts to international ports: Bar, Budva, Kotor, Kumbor Port – Portonovi, and Tivat (Gat I and Gat II), except for organised arrival of foreign vessels and their crews, who will be obliged to remain in self-isolation in the port for 14 days with sanitary health monitoring. Port concessionaires must take measures to prevent importation and transmission of coronavirus on the basis of recommendations of the Institute for Public Health.
Cargo transport
  • Transport of goods is not banned, but special health and sanitary measures are taken at the borders.
  • Commercial Court of Montenegro postponed all hearings until 22 May 2020.
  • Judges of the Higher Courts to decide which non-urgent hearings will be held.
  • Other courts postponed hearings until further notice, except in employment, family law cases and cases where accused is in detention.
  • All courts will resume regular work as of 25 May 2020. Courts will continue to receive submissions only through Post of Montenegro and e-mail; on-premise communication with parties suspended until further notice. All courts are obliged to ensure application of safety, hygienic and social distancing measures. Parties will undergo disinfection procedure before entering court premises and they will be provided with protective equipment. Smaller courts which don not have spatial conditions to ensure distancing measures will organise hearings in other suitable premises in the same municipality.
  • Closed.
  • During the shut-down of schools and kinder-gardens, one parent of a child not older than 11 years of age is entitled to a paid leave from work, with the exception of healthcare employees, and employees in certain state institutions. State has not undertaken to refund the employers.
  • Recommendation to employers to organize remote work where possible.
  • Sick leaves longer than 30 days are automatically extended until 15 May 2020.
  • Construction workers must wear masks and gloves during work including during transport to and from the construction site.
  • Leaving the construction site during working hours is prohibited.
  • Food must be delivered to the construction site.
  • Physical distance between employees during their transport must be ensured.
  • On bigger sites (with 40 or more employees) work and accommodation (if provided) must be organized in groups of maximum 20 employees. Physical distance between groups should be kept at all times.

The date of expiry of these measures is not determined and they will apply while there is a danger from importation and spreading of the contagious disease caused by the new coronavirus.

Notice on the above measures must be visible on the construction site.

Trade and hospitality
  • Conditional reopening of shopping malls for 18 May 2020.
  • Ban until 18 May 2020 on:
    • on-premise consumption in hotels, except for hotel guests;
    • nightclubs, on-premise consumption outlets (except for food delivery), playrooms, casinos.
  • Conditional reopening of  hotels and other outlets announced for 18 May 2020.
Financial aid and incentives
  • 90-day moratorium on loan/financial leasing repayments upon request of the borrower. For more details, see our special newsletter.
  • Prohibition on the banks to pay dividends to shareholders, except in the form of treasury shares. The measure applies until revoked.
  • Banks allowed to increase exposures to a single entity or a group of related entities beyond the statutory limits of 25% of the bank’s own funds, with the Central Bank’s prior approval.
  • The Investment-Development Fund offers working capital loans to companies in the sector of medical supplies, tourism and hospitality, and food processing, up to EUR 3 million per borrower.
  • Moratorium on rent payments to the state as lessor.
  • State will make advance payments on capital investment projects against bank guarantee.
  • Ministry of Culture earmarked EUR 500,000 for cultural workers (musicians, actors, freelancers as well as companies in the film industry); funds to be granted on public tender.
  • Excise on medical alcohol sold in pharmacies removed.
  • Extension of the deadline for submission of income tax returns for natural persons until 15 May 2020.
  • Interest-free 60-day moratorium on customs debt and VAT on imports due in April and May, for debtors ordered to shut-down due to COVID19 epidemics, against a bank guarantee. Deadline for VAT refunds 45 days.
  • Exemption from payment of the fixed part of the electrical bill for the period from 1 April until 30 June 2020 for entrepreneurs and companies in the tourism sector and sectors that are shut-down due to COVID19 epidemic.
  • Additional instruments of financial support by the Investment and Development Fund – details still to be published.
  • Moratorium on certain debt collection in favour of the state budget – details still to be published.
  • One-off financial aid for unemployed and pensioners in agriculture sector.
  • Double subsidies on electricity bill for existing subsidy recipients who receive social benefits.
  • Subsidies for entrepreneurs, micro, small and medium-sized enterprises which do not have outstanding tax liabilities for 2019 or are under a reprogram, and have not been in breach of any state measures to combat the epidemic. Businesses that are shut-down as a result of state measures and businesses in the tourism sector are entitled to 100% of one-month gross minimum wage for April and May for all employees who have been on their payroll at least since February 2020. Businesses from jeopardised industries are entitled to 50% of one-month gross minimum wage for April and May for employees on the payroll at least since February 2020. Businesses which employ new people are entitled to 70% of gross minimum wage for each new employee, over a period of six months, except for businesses in the sectors of finance, insurance, electricity and gas, telecommunications, water supply, waste water management, waste management, and state and local entities. New employees have to remain employed for at least 12 months. Companies that have employees who are using their right to a paid leave to take care of children under the age of 11 due to shut down of kindergartens and schools are entitled to 70% of their gross minimum wage for the entire period of the leave. Companies whose employees have been in quarantine or self-isolation are entitled to 70% of their gross minimum wage for one month.
  • Special support package for agriculture and fisheries which includes repurchase and storage of surplus products and subsidized loans of up to EUR 20.000, financing of insurance premiums.

For more details on financial support available to companies in Montenegro affected by the coronavirus epidemic see our special newsletter.

  • Market inspections will monitor whether there is price abuse with respect to basic food products, hygiene products, drugs and medical devices.
Other relevant measures
  • The Chamber of Commerce waived membership fee for the period from 1 April 2020 until 30 June 2020 for the members whose operations have been shut-down by the order of the government.
  • Ban on public procurement except urgent ones and in the health sector.
  • Personal ID documents issued after 2008 which have expired will be deemed valid until 1 June 2020.
  • Permanent and temporary residence and work permits, and vehicle permits if the vehicle is insured and has passed technical inspection which have expired will be deemed valid until 1 June 2020.
  • Health certificates of persons who work on jobs with severe conditions which have expired will be deemed valid until 30 June 2020.
  • Licences and other documents necessary for public passenger and cargo transport which have expired will be deemed valid until 30 June 2020.
  • Strict control of legality of transport of passengers and goods.
  • State and local authorities and state companies with public authorities ordered to deliver decisions by post.
  • Municipal police officers asked to file criminal complaints for non-compliance with the measures.
  • Removal of chairs and tables in front of restaurants and cafes ordered.
  • One-off aid in the amount of EUR 50 to retirees with lowest pensions.
  • Online birth certificates and certificates from the register of Montenegrin citizens available free of charge until 18 May 2020.

Bosnia and Herzegovina

  • 2142 confirmed cases (Republika Srpska 1129; Federation B&H 993; Brčko 20).
  • Bosnia and Herzegovina declared emergency situation.
  • Republika Srpska declared state of emergency; in force as of 3 April 2020.
Health measures
  • Individuals with residence in Bosnia coming from abroad to Republika Srpska are quarantined in special facilities, and those coming to Federation B&H are placed under health monitoring and movement restriction as determined by federal sanitary inspector, for a period of 14 days;  in Republika Srpska, quarantine measures do not apply to drivers in international traffic – local drivers have to isolate in their homes in between the tours while foreign drivers are not allowed to leave their vehicles while in transit; accredited diplomatic and consular staff; health workers; cross-border agricultural workers, subject to proof of land ownership/possession; President, Prime Minister, members of Government and Serbian member of the Presidency of Bosnia and Herzegovina); in Federation B&H, health monitoring and movement restriction measures do not apply to persons moving in the border area traffic, cross-border workers, drivers, pilots, and crews in international traffic – local drivers have to isolate in their homes in between the tours while foreign drivers are not allowed to leave their vehicles while in transit.
  • Foreign citizens coming to Republika Srpska on business must present invitation letter and certificate of an authorized laboratory on SARS-COV-2 negative test not older than 48 hours, and must spend 14 days in self-isolation (if their business is done earlier than within 14 days, they may cease isolation and leave Republika Srpska. The Government still needs to clarify what self- isolation means in the context of a business trip.
  • In Banja Luka and certain other towns in Republika Srpska, infected persons are placed in the isolation facilities.
  • Publication of the identity (name and address) of persons who have breached home isolation measures; people who breached isolation measures to be isolated in quarantine facilities.
  • Healthcare facilities to be organized to serve, as priority, persons infected by coronavirus.
Movement of people
  • Ban on entry to Bosnia and Herzegovina for foreign citizens. The ban does not apply to:
    • health workers;
    • persons in need of medical assistance;
    • civil protection representatives, members of the military forces of NATO countries, members of EUFOR’s and staff of the NATO’s headquarters in Bosnia;
    • foreigners with residence in Bosnia;
    • cargo road transport crews performing international transport; cargo transit is limited to 12 hours from entry into Bosnia and Herzegovina and foreign crews to be isolated in their vehicles;
    • aircraft crews whose final destination is Bosnia and Herzegovina;
    • diplomatic and consular staff accredited/with residence in Bosnia and Herzegovina;
    • persons granted a permit by the Council of Ministers of Bosnia and Herzegovina;
    • drivers and persons accompanying them in funeral vehicles;
    • international cargo railway and waterway crews;
    • foreigners in transit through Bosnia to their country of residence;
    • cross-border agricultural workers and owners of agricultural land, subject to proof of land ownership or confirmation of the owner that the person crossing the border works on the land.

Republika Srpska

Until 11 May 2020:

  • Curfew between 10 p.m. and 5 a.m.
  • Senior citizens (65+) living in urban areas may leave their homes between 7 a.m. and 1 p.m. every day; senior citizens in rural area (up to 75) may leave their homes to engage in agricultural activities; persons having registered apiaries allowed to move between their home and apiary every day from Monday to Friday, except between 10 p.m. and 5 a.m., and on weekends without any time limitations.
  • Bans do not apply to:
    • Healthcare workers on duty;
    • Officers on duty;
    • Persons granted by employers a confirmation on required movement for the purpose of work process;
    • Persons granted a special permit for movement by the Ministry of Interior;
    • Persons in urgent need of medical assistance;
    • Cargo road transport crews.
  • Ban on gatherings of more than 3 people outdoors. Social distancing measures (2 m between persons and use protective masks); use protective masks and gloves mandatory in indoor public spaces.
  • Ban on all public gatherings until 25 May 2020.
  • Intercity and suburban public transport suspended. Reopening on 11 May. Health and safety measures will apply.
  • Truck drivers must have special permits issued by their employers for transport during curfew.

Federation B&H

  • Until 15 May 2020, senior citizens (65+) may leave their homes only on Mondays, Wednesdays, and Fridays between 9 a.m. and 1 p.m. and those younger than 18 on Tuesdays, Thursdays, and Saturdays between 2 p.m. and 8 p.m. (transport by vehicles allowed every day). The restriction does not apply to agricultural workers while working, persons on duty in a legislature, executive, judiciary branches (members of parliaments, members of the Presidency and Council of Ministers of Bosnia and Herzegovina, entities’ governments, notaries, attorneys, judges, prosecutors, etc), employees, persons in need of urgent medical assistance, persons caring for children or senior persons, and children with special needs.
  • Persons must keep distance of at least 2 m while outdoor and use protective mask, scarf or similar face covers.
  • Ban on public transport, excluding taxi, until 15 May 2020.
  • Employees of health institutions not to leave Federation B&H.
  • Ban on public gatherings until 15 May 2020.
Air traffic
  • Closure of all airports for passengers flights until 1 June 2020.
Road traffic
  • Closure of border crossings with Serbia:
    • Mali Zvornik (in the area of BP BiH BPU Zvornik) and IBCP Brasina – railway station inside the territory of Serbia (in the area of BiH IBCP Zvornik – railway border crossing point);
    • Priboj (in the area of BP BiH GP BPU Mokronozi) and Most in Carevo Polje (in the area of BiH – under the Agreement within IBCP Uvac;
    • Jamena – river (scaffolding) BCP (in the area of BP BiH BPU Donje Crnjelovo).
  • Cargo transport in transit through Bosnia directed to the following border crossings: Croatia-Bosnia (Bijača – Nova Sela, Gradiška – Stara Gradiška, and Šamac – Slavonski Šamac), Serbia-Bosnia (Rača – Sremska Rača), Montenegro-Bosnia (Klobuk – Ilino Brdo).
  • Closure of 28 border crossings for border area traffic between Croatia and Bosnia.
Railway/waterway traffic
  •  Inter-entity and local railway lines cancelled.
Courts and state administration
  • Procedural deadlines in court proceedings suspended in Republika Srpska (during the state of emergency) and in Federation of B&H  (during emergency situation), except in urgent proceedings (family law cases, discrimination and harassment at work place cases, company registration, detentions, criminal proceedings for public health and state of emergency related crimes, etc); statute of limitations tolled during the state of emergency.
  • Procedural deadlines in administrative proceedings suspended in Republika Srpska where participation of parties to the proceedings cannot be ensured due to COVID-19-realted measures or for other justified reason. Procedural deadlines for legal remedied against first instance decisions in tax proceedings suspended. Procedural deadlines are not suspended in urgent cases(proceedings involving life and health of people, public order, and public safety are under risk, etc).
  • Hearings postponed except in urgent cases (detentions, criminal cases under risk statute of limitations to expire, misdemeanours for breaching COVID-19 related measures, security measures). Courts instructed to prepare protective equipment and organize the work in full capacity starting from 15 May. Hearings to be organized with the application of social distancing measures.

Republika Srpska

  • Shut-down of kinder-gardens, schools, universities; on 11 May, limited reopening of kinder-gardens in Banja Luka.

Federation B&H

  • Shut-down of universities, schools and kinder-gardens.
Work place

Federation B&H

  • Time spent in isolation or self-isolation is treated as sick leave. It will be paid by employer but will be refunded by the cantonal health fund within 45 days from the request for refund. Sick leave certificate can be issued in a state-run healthcare institution or in a private practice.
  • Recommendations for employers:
    • reduction working hours and organization of remote work if possible;
    • annual and other leaves to be allowed according to the law;
    • to allow leave to parents of children not older than 10 years (one parent per family); unclear whether paid or unpaid leave;
    • all business trips to be cancelled;
    • meetings with a larger number of participants to be cancelled, and if necessary, to be organized in large rooms ensuring with sufficient distance between participants (1-2 meters).
Trade and hospitality

Republika Srpska

  • On 11 May 2020, reopening of:
    • Hospitality businesses for on-premise consumption (currently only take away and delivery  from 7 a.m. to 7 p.m. allowed);
    • Private dental ordinations;
    • Gaming operators;
    • Fitness and training places;
    • Beauty salons and hairdressers;
  • Wellness and spa centres, swimming pools, children playrooms, sports events and training facilities remain closed until 25 May 2020.
  • Hospitality, wholesale and retail shops, private dentists, beauty salons and hairdressers, bakeries, food delivery services, public kitchens, gaming outlets, agri-pharmacies, fitness centres must adjust working hours to comply with curfew.
  • Working hours of open markets between 7 a.m. and 3 p.m; working hours of livestock markets between 6 a.m. and 1 p.m.
  • All businesses must comply with health and protective measures determined for each specific business by the Health Institute of Republika Srpska.

Federation B&H

Until 15 May 2020, closure of:

  • Cinemas, museums, theatres, concert halls, art galleries, public swimming pools and bathing areas, sports and recreation centres;
  • Hospitality facilities (restaurants, bars, nights clubs, fast foods, casinos, betting shops and all similar facilities) excluding services of food production and delivery, public kitchens, production and serving food for hotels’ guests;
  • Children playrooms;
  • Open markets excluding those selling agri-food products;
  • Shopping malls (excluding outlets selling food products, hygienic products, pharmacies and wholesale drugstores);
  • Private dental practices.
  • Retail outlets must limit the number of customers in the shop; distance between customers must be at least 2 m; employees and customers must use protective masks and gloves.
  • Banks obliged to devise a set of relief measures to be offered to clients whose ability to repay the loans has been affected by the COVID-19 crises (including six-month moratorium on loan repayments, grace periods, debt reprogramme, modification of exposures). The measures should be selected by the banks themselves, and offered on individual or portfolio basis. No fees can be charged to, and no higher interest can be imposed on, the clients in this respect. Relief does not apply to non-performing loans.
Price control
  • Price control imposed on a number of products.
Government support

Republika Srpska

  • Tax and social contributions for March 2020, to be financed from the Solidarity Fund, for employees whose employers are shut down as a result of COVID-19 related measures but paid net March salaries to employees. Requests to be submitted until 11 May 2020. The list of qualifying employers is available at the web page of the Ministry of the Economy and Entrepreneurship.  The employers who are not included in the list are invited to contact the Ministry.
  • Statutory minimum salary (BAM 520, i.e. approximately EUR 265) for April 2020, with accompanied tax and social contributions, to be financed from the Solidarity Fund, for employees whose employers are shut-down as a result of COVID-19-related measures or temporarily ceased or reduced their operations because of economic consequences of the pandemic (loss of markets, disruption to supply chain and similar). Requests to be submitted until 10 June 2020. The list of employers which qualify for the aid to be prepared by the competent ministries. Applications for the aid to be filed until 15 May 2020.
  • Deadline for payment of the first and second instalments of real estate tax, due by 30 June 2020 and 30 September 2020, respectively, extended until 30 September 2020 and 31 December 2020, respectively.
  • Annual statutory minimum income tax applicable to small entrepreneurs reduced from BAM 600 (approx. EUR 306) to BAM 240 (approx. EUR 122).
  • Gaming operators released from certain fees (on electronic games via terminals, betting games, games at slot machines).
  • Three-month moratorium, starting on 1 April 2020, for loans granted by Investment-Development Bank of Republika Srpska. Six-months moratorium or grace period for individuals, upon request.
  • Deadline for submission of tax returns due by the end of March (communal fee for entrepreneurs, special republic fee, registered weapon tax, etc.) extended until 30 April 2020.
  • Deadline for payment of annual income tax and forest and fire protection fees extended until 30 June 2020; payment in instalments allowed until the end of 2020, upon request, for taxpayers affected with COVID-19 related measures who must submit an affidavit to that effect until 30 June 2020.
  • Three-month moratorium on concession fees and rent for agricultural land leased from Republika Srpska.
  • One-off aid in the amount of BAM 1,000 (approx. EUR 511,00) from the Solidarity Fund to each employee in the public healthcare sector and police officers who was working minimum three weeks between 15 March 2020 and 15 April 2020.

Federation B&H

  • Subsidy for social contributions for employees in private sector, termination of the obligation to pay monthly advances of corporate income tax; suspension of default interest on public revenues and default interest in creditor-debtor relations; a guarantee fund for issuing guarantees of Federation B&H established. The law comes into force on 9 May.
  • Rent for the facilities leased from the Federation B&H reduced for 50%.
  • Special health insurance contributions payable for employees working abroad reduced for BAM 10,00 (EUR 5).
  • Deadline for submission of tax returns due by the end of March extended until 30 April 2020; communication with Tax Administration only via registered mail, e-mail or fax; entry into Tax Administration’s facilities forbidden.
  • Recommendation to taxpayers to submit requests for reduction of advance corporate income tax payments in accordance with Article 52, paragraph 4, point c) of the Income Tax Act which provides a monthly advance tax to be reduced upon request of a taxpayer in the case of natural or other disaster significantly affecting taxpayer’s business.
  • Tax Administration of the Federation of B&H instructed to accept taxpayers’ requests for debt rescheduling.
  • Lump-sum tax applicable to private entrepreneurs reduced for 50%.
Other relevant measures
  • Relief on indirect tax for equipment (masks, gloves, disinfectants, protective suits, respirators and similar equipment), medicines and ambulance vehicles donated by Bosnian and international entities for the prevention, control and elimination of COVID-19.
  • All citizens of Republika Srpska will have health insurance until 11 May 2020 without having to obtain certificate on paid contributions.
  • All citizens of Federation B&H will be covered by health insurance during the emergency situation and for a period of 30 days thereafter.
  • Reduced hours of post offices; international shipping for certain destination countries suspended.
  • All public institutions and private entities in Federation of B&H serving clients at counters must ensure at least 1.5-meter distance between persons.
  • Visits to persons in social care institutions and detention-rehabilitation centres banned.
  • All administrative authorities and other public institutions in Republika Srpska ordered to organize work with minimum number of people, limit number of customers in facilities, ensure at least 2-meter distance between persons.


Note: Dear readers, you will appreciate that the governmental measures we report on are not always clear and straightforward. We give our best to interpret them properly. However, this CORONA-19 Update is not a legal advice and we do not undertake any responsibility to the readers for accurateness of information and interpretations reported here.

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