The National Bank of Serbia’s decision to revoke ALTA Banka’s operating licence, followed by the opening of bankruptcy proceedings, has raised a number of practical questions for the bank’s clients. These include individuals, entrepreneurs and companies that held funds with the bank or used it to process payments.
For many clients, an account was more than a place to keep money. It was used to receive salaries and income from abroad, pay personal and business expenses, finance day-to-day operations or make payments to business partners. The bank’s closure does not automatically mean that all funds are lost. However, the available recovery route depends on the legal status of the depositor, the nature of the assets and the circumstances of each case.
On 3 November 2026, the Commercial Court in Belgrade opened bankruptcy proceedings against ALTA Banka and appointed the Deposit Insurance Agency as bankruptcy administrator. Banka Poštanska štedionica has been selected as the payout bank for insured deposits. This article outlines the main steps and issues relevant to different categories of clients.
1. Deposit insurance: who is eligible?
Deposits with ALTA Banka are insured up to EUR 50,000 per depositor. The limit applies to the aggregate amount of all deposits held by the same depositor with the bank, not separately to each account. The insured amount is calculated in accordance with the statutory rules, including any relevant liabilities owed by the depositor to the bank.
For individuals, eligibility does not depend on citizenship. Foreign nationals, including citizens of the Russian Federation, are not excluded from the deposit insurance scheme merely because they are not Serbian citizens. Temporary or permanent residence in Serbia, or registered residence, is not in itself the decisive criterion. What matters is whether the person is a depositor and whether the funds qualify as an insured deposit under Serbian law.
Accordingly, a Russian national holding a personal account with ALTA Banka may qualify for insured-deposit compensation on the same statutory terms as a Serbian citizen. For example, if the aggregate balance across several accounts with the bank is the equivalent of EUR 45,000, it may fall within the insured limit, provided the funds qualify as insured deposits.
A distinction must be made between an entrepreneur, a Serbian company with foreign ownership and a foreign legal entity. In addition to individuals, the deposit insurance scheme covers entrepreneurs and qualifying micro, small and medium-sized legal entities. A company incorporated in Serbia is not excluded merely because it is wholly or partly owned by Russian shareholders, provided it meets the statutory criteria for the relevant company category.
By contrast, a foreign legal entity holding a non-resident account in Serbia should not be treated in the same way as a Serbian company whose shareholder is a foreign legal entity. Large legal entities are also outside the deposit insurance scheme. Each business depositor should therefore establish who is the account holder, where the company is incorporated, how it is classified and the total amount of its deposits.
2. How and when will insured deposits be paid?
Insured deposits will be paid through Banka Poštanska štedionica, the appointed payout bank. According to information published by the Deposit Insurance Agency, details of the payout commencement date and the relevant branches are expected to be published on the Agency’s website by 6 November 2026. The statutory deadline for commencing payment is no later than seven business days from the opening of bankruptcy proceedings.
Depositors should monitor official notices published by the Deposit Insurance Agency at www.aod.rs and follow the instructions provided. Individuals will generally need a valid identity document, while entrepreneurs and legal entities should prepare documents confirming the identity and authority of the person acting on their behalf. For foreign nationals, this will ordinarily be a passport, together with any additional documents required by the payout bank.
Dinar deposits are paid in dinars, while foreign-currency deposits are paid in euros, in accordance with the exchange-rate and calculation rules prescribed by law as at the date the bankruptcy proceedings were opened. Insured depositors do not need to file a creditor claim in the bankruptcy proceedings merely to receive the insured amount; the insured portion is paid through a separate procedure.
Clients currently outside Serbia, including Russian nationals residing in the Russian Federation or another country, should check in advance whether the relevant step can be completed through an authorised representative and what documentation the payout bank requires. The requirements for receiving insured deposits should not be assumed to be identical to those for filing a creditor claim in bankruptcy.
3. Balances above the insured limit and uninsured depositors
Any amount exceeding EUR 50,000, as well as deposits held by persons who do not fall within the category of insured depositors, must be pursued as a claim in the bankruptcy proceedings. The court sets the claim-filing deadline within the statutory range of 30 to 90 days from publication of the bankruptcy notice in the Official Gazette of the Republic of Serbia. The operative deadline is the one stated in the court notice; it does not run from the date of the court decision or from the date on which the creditor became aware of the bankruptcy.
Creditors should obtain and review the court notice as soon as it is published. Clients located abroad should make arrangements to monitor the proceedings and prepare their supporting documents without delay.
A creditor claim should identify the creditor and the legal basis of the claim, specify the principal and accrued interest separately, include supporting evidence, identify any security interests and provide payment details. Supporting documents may include account-opening agreements, statements, balance confirmations, business records, court decisions and other relevant evidence.
The bankruptcy administrator examines filed claims within the statutory period, after which an examination hearing is held. Creditors should check whether their claims have been admitted or disputed. Where a claim is disputed, the creditor may be referred to litigation to establish the claim and must comply with the deadlines set by law and the court.
The ranking of claims in a bank bankruptcy is governed by special statutory rules. A creditor’s position depends on the type and legal basis of the claim, any security and the applicable statutory priority. Depositors may benefit from a specific priority under the law, while shareholders rank last. The actual recovery will depend on the value of the bankruptcy estate and the bank’s total liabilities.
4. Specific considerations for Russian nationals and Russian-owned businesses
For Russian nationals living or doing business in Serbia, citizenship in itself is not an obstacle to claiming deposit insurance. The practical issue is who is formally named as the depositor and whether the account belongs to an individual, an entrepreneur, a Serbian company with Russian ownership or a foreign legal entity.
If a client is currently in Russia, certain steps in the bankruptcy proceedings may, depending on their nature and the requirements of the relevant authority, be carried out through a representative in Serbia. Powers of attorney and public documents issued abroad may require a specific form of certification, translation into Serbian and, depending on the applicable international rules, an additional certificate or legalisation. The requirements should be checked before documents are issued, as they depend on the type of document and the purpose for which it will be used.
Russian-owned businesses should address continuity of operations separately from the recovery of their funds. In addition to determining the status of their deposits, they should arrange an alternative business account, update payment instructions, notify customers and suppliers and review obligations to employees, public authorities and business partners. Banks may apply enhanced due diligence to ownership structures, beneficial owners and the source of funds. Complete corporate documentation may facilitate the account-opening process but cannot guarantee its outcome.
5. Business operations, loans, guarantees and payment services
The suspension of payment services through ALTA Banka may have an immediate impact on business operations. Companies and entrepreneurs should arrange an alternative account without delay and ensure that salaries, taxes, social contributions, supplier invoices and other due liabilities can be paid. Business partners should be notified in writing of the new payment details, and invoices and transfers that were in progress when payment services were suspended should be reviewed.
The bank’s bankruptcy does not automatically extinguish the obligations of its borrowers. Loans, credit cards, overdrafts and other liabilities remain payable in accordance with the relevant agreements and the official instructions of the bankruptcy administrator. Clients should retain evidence of all payments and should not unilaterally suspend payment without first obtaining legal advice.
Bank guarantees, letters of credit and other instruments issued by ALTA Banka in favour of clients or their business partners require particular attention. Their status and enforceability must be assessed by reference to the wording of the relevant instrument, the underlying agreement and applicable law. In some cases, replacement security may need to be arranged.
Clients who have both a deposit and a loan with ALTA Banka should consider whether set-off may be available. Set-off is not automatic. The analysis must consider when the relevant claims arose, when the statutory conditions for set-off were met and how the opening of bankruptcy proceedings affects the particular relationship.
6. Custody services and securities
A cash deposit must be distinguished from securities and other assets that the bank may hold or record on behalf of a client. Clients who used custody or investment services should obtain an up-to-date record of their financial instruments and other positions, establish in whose name they are held and review the legal framework governing their safekeeping and transfer.
Client assets that are, in accordance with applicable law and the relevant contractual arrangements, segregated from the bank’s own assets should not automatically be treated as bank deposits or as assets belonging to the bank. Depending on the service provided, specific investor-protection rules may also be relevant. Clients should request the appropriate statements and confirmations and check the process for transferring their positions to another service provider.
7. What should clients do now?
- Identify the formal depositor and owner of the funds: an individual, entrepreneur, Serbian legal entity or foreign legal entity.
- Confirm the aggregate deposit balance and whether the depositor qualifies for insurance up to EUR 50,000.
- Obtain account statements, balance confirmations, agreements and other evidence of the funds and their legal basis.
- Monitor notices from the Deposit Insurance Agency and the court notice, in particular the claim-filing deadline.
- If there is an uninsured balance or the depositor is not insured, prepare and file a creditor claim within the applicable deadline.
- Arrange an alternative business account and review loans, guarantees, letters of credit, custody services and other outstanding arrangements with the bank.
- If located abroad, check the possibility of representation through a power of attorney and the formal requirements for supporting documents.
Conclusion
The bankruptcy of ALTA Banka does not mean that all client funds have been lost. Serbian law provides deposit insurance of up to EUR 50,000 per depositor for categories of clients that meet the statutory requirements. Amounts exceeding the insured limit, as well as claims of uninsured depositors, must be pursued in the bankruptcy proceedings in compliance with the applicable filing requirements and deadline.
Each client should promptly establish the legal status of the funds, collect the relevant evidence and take the necessary steps to protect its rights. Businesses must also ensure continuity of payment operations and review the impact of the bankruptcy on their existing contractual and financial arrangements.
Ikonić Stiković Advokati advises individuals, entrepreneurs and companies on bank insolvency matters and the protection of depositors’ and creditors’ rights. Our team can assist with assessing deposit-insurance eligibility, preparing and filing creditor claims, representation in bankruptcy proceedings and disputes over contested claims, as well as reviewing loans, guarantees, set-off and other banking arrangements. For clients located outside Serbia, our assistance may also include coordinating powers of attorney, supporting documents and representation before the competent Serbian authorities.
This article is for information purposes only and does not constitute legal advice. Eligibility for insured-deposit compensation and recovery of claims in bankruptcy depend on the specific facts and applicable legal requirements.
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