Attorney Miloš Stevanović appeared on the morning program of Radio Television of Republika Srpska (RTRS) on June 3, 2026, where he discussed the initiation of proceedings before the Constitutional Court of Republika Srpska regarding a decision adopted by the Management Board of the Banking Agency of Republika Srpska concerning fees for the registration and operation of licensed exchange offices.

A large number of licensed exchange offices, represented in these proceedings by the Stevanović Law Office, have filed an appeal with the Constitutional Court of Republika Srpska requesting that the challenged decision be repealed, or declared unconstitutional and unlawful.

Under the disputed decision of the Management Board of the Banking Agency of Republika Srpska, a fee of BAM 14,000.00 is charged for submitting an application for the registration of an exchange office, the annual supervisory fee amounts to BAM 10,000.00, while a fee of BAM 2,000.00 is charged for the issuance of various certificates, opinions, and other documents.

Speaking on RTRS, Stevanović emphasized that the contested decision represents a serious burden on business entities engaged in exchange operations and is not consistent with the principle of proportionality, which is one of the fundamental principles of modern administrative and constitutional law.

“In neighboring countries, the situation is entirely different. In the Federation of Bosnia and Herzegovina, administrative fees for this type of procedure amount to only a few convertible marks, in the Republic of Serbia the fees are approximately 12,000 dinars, while in the Republic of Croatia they are also symbolic. Therefore, we believe that the fees prescribed in Republika Srpska are not in line with economic reality nor with the principle of proportionality,” Stevanović stated.

During the interview, it was particularly emphasized that the Stevanović Law Office and the representatives of exchange offices do not question the work of the Banking Agency of Republika Srpska as the regulator of the financial system.

On the contrary, it was noted that over the years the Agency has demonstrated a high level of professionalism, has reacted promptly in numerous cases, and has served as a constructive partner to businesses operating in the financial sector.

However, according to the appellants, the disputed decision of the Management Board was adopted without adequate consultation with the professional community, business entities, and representatives of the exchange office sector, which has resulted in significant negative consequences for a large number of small and medium-sized enterprises.

Stevanović expressed his expectation that the Management Board of the Banking Agency of Republika Srpska will reconsider its decision and amend it before the proceedings before the Constitutional Court of Republika Srpska are concluded.

“If that does not happen, we believe that the Constitutional Court of Republika Srpska will conduct the appropriate constitutional review and remove provisions that create a disproportionate burden on business entities. Our goal is not a conflict with institutions, but rather the establishment of a fair and sustainable regulatory framework that will enable the normal operation of exchange offices and preserve jobs,” Stevanović said.

The appellants express hope that, following the amendment or annulment of the challenged decision, some exchange offices that were forced to suspend operations due to high regulatory costs will reopen their doors to citizens and continue operating in the market of Republika Srpska.

The full interview can be viewed at the following link.