In announcements published on 31 October 2026, the National Bank of Serbia (“NBS“) confirmed the revocation of the operating licence of ALTA banka a.d. Beograd (“Bank“), following a significant deterioration in its financial position and concerns over liquidity. The NBS also determined that the conditions for bankruptcy were met, transferred management to the Deposit Insurance Agency (“Agency“) and announced proceedings against the Bank, its shareholders, management and other responsible persons.
The Commercial Court in Belgrade must open bankruptcy proceedings no later than the next business day after receiving the NBS decision. The Agency will act as bankruptcy administrator under judicial supervision, alongside a creditors’ committee. Bank bankruptcy follows a special statutory regime, with general corporate bankruptcy rules applying only in a supplementary manner. Clients and counterparties should focus on the following:
1. Banking and payments: Withdrawal of the license means that the Bank’s accounts are blocked and its ability to deal with its assets is restricted. Clients should arrange alternative banking for incoming payments, salaries and supplier payments, update their payment instructions and check the status of pending transfers.
2. Deposit protection: Eligible individuals, entrepreneurs and micro, small and medium-sized entities are protected up to EUR 50,000 per depositor at the Bank. This is a single limit covering all eligible accounts and currencies, including interest earned under the agreed terms. Large companies, public authorities and certain other categories, including persons connected with the Bank, are excluded from deposit insurance.
3. Access to insured funds: The Agency must announce how payments will be made within three business days of the court’s decision to open bankruptcy proceedings. Insured funds must be available within seven business days of that decision. Payments will be made through a bank selected for this purpose: in RSD for RSD deposits and in EUR for foreign-currency deposits, using the conversion rules set by law. These deadlines start from the court’s decision, rather than the withdrawal of the license.
4. Uninsured amounts and payment priority: Amounts not covered by deposit insurance must be claimed through the bankruptcy process. The Agency’s reimbursement for insured payouts is treated as a cost of the proceedings and is paid before distributions to the statutory creditor groups. Within those groups, eligible depositors’ remaining balances rank first; certain recent tax and other public revenue claims rank second; NBS claims rank third; and large-company deposits generally rank fourth. Ordinary claims by suppliers and other trade creditors, as well as claims under guarantees issued by the Bank, generally rank fifth. Creditors holding collateral and other special cases may be treated differently.
5. Filing claims and ongoing cases: The court will set a deadline of 30 to 90 days from publication of the bankruptcy opening notice in the Official Gazette for creditors to file their claims, whether or not they hold collateral. Creditors should prepare their written claims, supporting documents and details of any collateral. Existing court and enforcement cases may be paused or restricted under bankruptcy rules. Having an ongoing case does not remove the need to file a bankruptcy claim where required.
6. Loans and set-off: Borrowers must continue to repay their debts. The Bank’s bankruptcy does not, by itself, release collateral or guarantees securing those debts. Borrowers should confirm repayment instructions with the Agency. Clients who both hold deposits and owe money to the Bank can generally offset those amounts against each other, except in cases the law excludes the possibility of set-off:
- If the bankruptcy creditor acquired the claim within the six-month period preceding the date of filing the application for the initiation of bankruptcy proceedings, and the bankruptcy creditor knew or ought to have known that the debtor was unable to pay its debts as they fell due or was over-indebted;
- If the conditions for set-off were established through a legal transaction or other legal act that may be subject to legal contesting (actio pauliana)
7. Earlier transactions: The Agency or creditors may challenge transactions that favoured particular creditors, subject to the conditions and exceptions set by law. This can cover transactions in the six months before bankruptcy takes legal effect, or one year for transactions with related parties. The deadline for bringing a challenge is 12 months from the date bankruptcy takes legal effect.
8. Guarantees and letters of credit: Businesses relying on guarantees or letters of credit issued by the Bank should check whether their contracts require them to obtain replacements. They should also keep the relevant documents and correspondence.
Clients of the bank should now assess their exposure, preserve records and monitor court and Agency notices. Our Banking & Finance and Dispute Resolution teams, together with our cooperating lawyers across the region, are closely following further developments.
The information in this document does not constitute legal advice on any particular matter and is provided for general informational purposes only.
