Category: Serbia

The Commission For Protection Of Competition of the Republic of Serbia (“Commission“) recently announced that it will conduct a sectoral analysis of the pharmaceutical industry, specifically examining market conditions and competition in the human drug market in Serbia. This decision comes in light of increasing regulatory oversight and the need to assess competitive conditions in this key sector.

The announced sectoral analysis commenced with the distribution of questionnaires to pharmacy institutions operating a larger number of retail outlets, aimed at gathering essential data for the analysis.

Throughout the sectoral analysis, the Commission will review medicines listed under the reimbursement scheme of mandatory health insurance, as well as pricing formation, market shares, competition conditions, potential barriers to market entry, vertical relationships between wholesalers and pharmacies, and other relevant factors.

What Does a Sectoral Analysis Entail?

A sectoral analysis involves the examination and monitoring of a specific industry to identify potential distortions of competition. Unlike procedures focused on specific market participants and individual cases, a sectoral analysis provides a broader overview of market conditions. These analyses may result in recommendations for regulatory changes or the initiation of proceedings against entities that violate competition rules.

The primary objective of this analysis is to define potential measures and activities that the Commission, in the form of opinions and recommendations, would present to the relevant authorities and market participants. The goal is to enhance the competitive landscape of the industry under review.

Legal Basis for Conducting Sectoral Analysis

The authority of the Commission to conduct sectoral analyses is regulated by Article 47 of the Law on Protection of Competition (Official Gazette of the Republic of Serbia No. 51/2009 and 95/2013). Specifically, in cases where price trends or other circumstances indicate the possibility of restricting, distorting, or preventing competition, the Commission may analyze the state of competition within a specific industry or certain categories of agreements across different industries.

In this regard, for the purpose of conducting sectoral analyses, the Commission may request market participants to provide all necessary data or documents, particularly concerning concerted practices, and may carry out any required investigations.

The Commission is obligated to publish a report on the conducted sectoral analyses in an appropriate manner, primarily on its official website, and may invite market participants to submit their comments on the report.

Reasons for Analyzing the Pharmaceutical Industry

The pharmaceutical industry is unique due to its complex structure and critical importance to public health. Factors such as drug pricing, distribution channels, and potential abuses of dominant market positions are among the key reasons why the Commission pays special attention to this sector.

In recent years, many countries have uncovered anti-competitive practices, including cartel agreements, artificial restrictions on drug supply, and unfair competition. The Commission’s goal in Serbia is to use the sectoral analysis to identify potential risks and ensure a level playing field for all market participants.

If the Commission detects irregularities, it may initiate proceedings for competition law violations, which could lead to enforcement measures, including significant financial penalties. On the other hand, sectoral analysis can also drive positive changes, such as improved drug availability and better conditions for patients and consumers.

This article is to be considered as exclusively informative, with no intention to provide legal advice. If you should need additional information, please contact us directly.

By Marija Muzevic, Counsel, PR Legal

Kinstellar has advised Globe Trade Centre on the sale of its subsidiary Glamp Beograd, which owns the GTC X Building, to Forstone Realty.

GTC is a real estate investor and developer in Central and Southeast Europe.

According to Kinstellar, the GTC X Building is located in a prime area of New Belgrade, Serbia, and comprises nearly 18,000 square meters of office space, along with 300 parking spaces in a three-level underground garage.

The Kinstellar team included Partner Milan Samardzic, Managing Associate Mina Sreckovic, and Associates Djordje Ilijasevic and Jelisaveta Folic.

Kinstellar did not respond to our inquiry on the matter.

CMS has advised Actis on the acquisition of Dot Towers through its Connectis Tower platform, adding 50 sites to Actis’ portfolio.

According to CMS, the deal includes 12 ground-based macro towers and 38 rooftops, primarily located in central Belgrade and other key Serbian cities.

The CMS team included Partner Marija Tesic, Counsles Marija Marosan and Srdjan Jankovic, Senior Lawyer Sandra Miljanic, and Lawyers Jelena Djordjevic and Teodora Vujosevic.

Kinstellar has advised Lafarge Serbia on its acquisition of Tribex Mining.

Lafarge Serbia is a member of the Holcim Lafarge Group.

Tribex Mining is the owner of the Jazovnik stone quarry. 

According to Kinstellar, Lafarge Serbia, as part of the world’s leading cement manufacturer, is strengthening its presence in Central and Eastern Europe through this strategic expansion.

The Kinstellar team included Managing Partner Milos Velimirovic, Managing Associates Mina Sreckovic and Mario Kijanovic, and Associates Djordje Ilijasevic, Jelisaveta Folic, and Vuk Vuckovic.

Kinstellar did not respond to our inquiry on the matter.

Moravcevic Vojnovic and Partners in cooperation with Schoenherr has advised Fifth Quarter Ventures on its investment in Nextesy. Advoro reportedly advised Nextesy.

Fifth Quarter Ventures is an early-stage venture capital fund.

Nextesy, based in Zurich, is an AI-driven start-up for business administration.

The Schoenherr team was led by Partner Igor Zivkovski.

Stefan Savic has joined NKO Partners as the firm’s new Head of Antitrust and Competition Practice.

Before the move, Savic worked for Kinstellar as a Senior Associate between 2023 and 2025. Earlier, he worked for Karanovic & Partners as a Junior Associate between 2017 and 2020, as an Associate between 2020 and 2023, and finally as a Senior Associate in 2023.

“We are excited to have Stefan on board and look forward to the contributions he will make to our team and our clients,” stated NKO Partners.

Gecic Law, working with Clifford Chance, has advised Telekom Srbija on its acquisition of Eon TV International from United Group as part of a deal that also saw United Group sell SBB Belgrade to e& PPF Telecom Group. Kinstellar, working with Sullivan & Cromwell, advised e& PPF Telecom Group. Moravcevic Vojnovic and partners in cooperation with Schoenherr, working with Kirkland & Ellis, advised United Group.

The transactions, which remain contingent on regulatory approval, have a combined enterprise value of EUR 1.5 billion.

SBB Belgrade offers alternative pay TV, broadband internet, and fixed telephone services in Serbia.

According to Kinstellar, “the deal, structured on a debt-free and cash-free basis, paves the way for e& PPF Telecom Group to merge SBB with Yettel, its mobile operator. This merger will unlock new opportunities, enhancing services for clients in Serbia. SBB will continue its media broadcasting operations seamlessly.”

According to United Group, Eon TV International – the holding company of the NetTV Plus business – was sold along with its sports broadcasting rights for the Western Balkans. Furthermore, United Group stated that it will retain its key media outlets in Serbia, including N1 and Nova S, which will continue to be available on SBB’s fixed network and to Yettel customers.

The Kinstellar team included Partner Milan Samardzic, Special Counsel Olga Sipka, Managing Associates Mina Sreckovic, Katarina Zivkovic, and Mario Kijanovic, Senior Associate Srna Popovic, Associates Djordje Ilijasevic and Jelisaveta Folic, and Junior Associate Dusan Djuric.

The Schoenherr team included Partners Slaven Moravcevic, Andrea Radonjanin, Jelena Bezarevic Pajic, and Jovan Barovic and Attorneys at Law Luka Veljovic and Vanja Tica.

Editor’s Note: After this article was published, Gecic Law informed CEE Legal Matters that its team included Partners Bogdan Gecic, Ognjen Colic, and Miodrag Jevtic, Counsel Milos Petakovic, Senior Associates Vuk Lekovic and Zarko Popovic, and Associates Dusan Jablan, Vasilije Boskovic, Nikola Ivkovic, Marko Jovic, and Aleksa Stojanovic.

NKO Partners has advised CTP on the acquisition of land in Kragujevac, Serbia, from Stellantis’ subsidiary Fiat Srbija. Karanovic & Partners advised Fiat Srbija.

According to NKO Partners, “the acquired location is situated within a major commercial zone and falls within the FAS Free Trade Zone, where CTP plans to develop up to 50,000 square meters of industrial and manufacturing facilities.”

The NKO team included Partner Djordje Nikolic and Senior Associate Luka Aleksic.

The Karanovic & Partners team included Partner Ana Lukovic and Senior Associate Nikola Siljegovic.

Last year, a new regulation on artificial intelligence (“AI Act”) was published in the Official Journal of the European Union. This new AI Act lays down legal framework for the development, placing on the market, putting into service and use of artificial intelligence systems (“AI systems”) in the EU, in order to, inter alia, promote the uptake of human centric and trustworthy artificial intelligence, protect against harmful effects of AI systems and to support innovation.

What is AI?

AI is a fast-evolving technology that offers numerous benefits across various industries. AI can provide a number of solutions and improvements particularly evident in fields such as healthcare, food safety, education, media, infrastructure management, transportation and logistics. However, the use of AI can also pose risks and potentially cause harm. Having this in mind, it is of paramount importance to support the development and use of AI, on one hand, as well as to meet a high level of protection of public interests, such as health and safety and protection of fundamental rights, on the other hand. This should be achieved by regulating this technology, i.e., regulating placing on the market, putting into service and use of certain AI systems.

Summary of the AI Act

In order to ensure effective protection of rights and freedoms of individuals across the European Union, the rules established by the AI Act apply to both public and private entities from the EU or from a third country if the AI system is placed on the EU market, or its use has an impact on individuals located in the EU.

We are hereby providing a brief overview of some of the key provisions of the AI Act.

Risk-Based Approach

The AI Act defines 4 levels of risk for AI systems: (i) Unacceptable risk; (ii) High-risk; (iii) Limited risk; and (iv) Minimal risk.

Unacceptable risk (Prohibited AI practices)

Aside from the many beneficial uses of AI, certain AI practices can be particularly harmful and shall therefore be prohibited. In accordance with the AI Act, placing on the market, putting into service or use of an AI systems that exploit vulnerabilities related to age, disability or a specific social or economic situation, AI systems that deploy subliminal, manipulative or deceptive techniques to distort behavior, or AI systems for emotion recognition in the workplace and education institutions (except when used for medical or safety reasons), etc., are considered as AI practices that shall be prohibited.

High-risk AI systems

High-risk AI systems include AI used in areas such as critical infrastructure (AI systems intended to be used as safety components in the management and operation of critical digital infrastructure, road traffic, or in the supply of water, gas, heating or electricity), education and vocational training (AI systems intended to be used to evaluate learning outcomes), employment, workers’ management and access to self-employment (AI systems intended to be used for the recruitment or selection, in particular to place targeted job advertisements, to analyze and filter job applications, and to evaluate candidates), education, etc.

These AI systems shall not be considered to be high-risk in case the specific AI system does not pose a significant risk of harm to health, safety or fundamental rights of natural persons, and if- the AI system is intended to perform a narrow procedural task, improve the result of a previously completed human activity, detect decision-making patterns or deviations from prior decision-making patterns and is not meant to replace or influence the previously completed human assessment, without proper human review, or to perform a preparatory task to an assessment relevant for the purposes of the use cases listed in Annex III of the AI Act.

However, AI systems shall always be considered to be high-risk when they perform profiling of natural persons (i.e. automated processing of personal data, such as for the purpose of assessing work performance).

A provider of an AI system referred to in Annex III of the AI Act as a high-risk AI system who considers that the specific AI system is not high-risk shall document its assessment before the system is placed on the market or put into service, as well as register the system in the EU database.

In accordance with the AI Act, the EU Commission shall, after consulting the European Artificial Intelligence Board, and no later than 2 February 2026, provide guidelines specifying the implementation of the above provisions, together with a comprehensive list of practical examples of use cases of AI systems that are high-risk or not high-risk.

Requirements and obligations for high-risk AI systems

High-risk AI systems shall comply with certain requirements prescribed in the AI Act before they can be placed on the market.

For example, a risk management system shall be established, implemented, documented and maintained. The purpose of this risk management is to identify any possible risks that the high-risk AI system can pose and adopt appropriate measures in order to address these risks. Moreover, the technical documentation of a high-risk AI system shall be drawn up before that system is placed on the market or put into service and shall be kept up-to date, and an appropriate human oversight shall also be provided in order to minimize potential risks.

In relation to the high-risk AI systems, different roles in the AI value chain have certain obligations.

The majority of obligations fall on providers (developers) of high-risk AI systems. For example, providers of high-risk AI systems shall ensure that the high-risk AI system is in compliance with all of the requirements prescribed in the AI Act, have a quality management system in place that ensures compliance with the AI Act, keep a set of prescribed documentation at the disposal of the competent authorities, etc.

It is important to note that the AI Act also applies to providers placing on the market or putting into service AI systems in the EU, even if they are established or located in a third country, as well as to providers and deployers of AI systems that have their place of establishment or are located in a third country, where the output produced by the AI system is used in the EU.

Providers established or located in a third country shall, prior to making their high-risk AI system available on the EU market appoint a representative, who shall be authorized to cooperate with competent authorities in relation to the high-risk AI system.

Moreover, importers of a high-risk AI system are obliged to, before placing it on the market, ensure that the system is in compliance with the AI Act, by ensuring that the provider has appointed an authorized representative, among other requirements.

Deployers (entity using an AI system under its authority except where the AI system is used in the course of a personal non-professional activity) also have some obligations (certainly less than providers), such as obligation to cooperate with the relevant competent authorities in any action those authorities take in relation to the high-risk AI system. It should also be noted that deployers who are employers and intend to use a high-risk AI system at the workplace, shall inform workers’ representatives and the affected workers that they will be subject to the use of a high-risk AI system. This applies to deployers located in the EU, as well as third country deployers where the AI system’s output is used in the EU.

Limited risk AI systems

Providers and deployers of limited risk AI systems are subject to lighter transparency obligations. These requirements mostly comprise providing certain information to end-users (such as information that they are interacting with an AI system in cases when the AI system is intended to interact directly with the natural person – e.g. chatbots) or disclosing that the content has been artificially generated, etc.

Minimal risk AI systems

Minimal risk AI systems are unregulated. Those are the AI systems that pose very little or no risk to the safety, rights, or well-being of individuals (such as AI systems that recommend movies, music, or books based on user preferences (e.g., Netflix, Spotify), or AI systems in wearable devices (e.g., Apple Watch) that track exercise, heart rate, or steps).

Application of the AI Act

The AI Act entered into force on 1 August 2024, and it shall apply from 2 August 2026. However, the provisions regulating prohibited AI systems shall apply from 2 February 2025; some provisions regulating high-risk AI systems shall apply from 2 August 2026, while others shall apply from 2 August 2027.

Conclusion

The AI Act marks a pivotal moment in AI regulation. While it sets ambitious goals for the safe, transparent, and ethical deployment of AI, businesses must act now to prepare for its full implementation.  Early action will help businesses avoid penalties and build trust with consumers by demonstrating a commitment to responsible AI use.

By Katarina Rosic, Senior Associate, and Andjela Sever, Associate, JPM Partners

Belgrade’s history is a testament to its resilience and adaptability. Over centuries, the city has been a crossroads of civilizations, with each era bringing new rulers, new ideas, and new architectural styles.

From the medieval Serbian dynasties to the Ottoman Empire’s mosques and hammams, and from Austro-Hungarian neoclassical buildings to the brutalist structures of the socialist era, Belgrade has always absorbed the influences of its occupants. Even the scars of World War II and the subsequent socialist reconstruction contributed to its unique urban fabric. However, the reshaping of Belgrade today is unlike anything the city has experienced before. This time, the transformation is not driven by conquest or occupation, but by ambition, investment, and a vision for the future.

The modern era of Belgrade’s reshaping began over a decade ago with the emergence of large-scale development projects. These marked the start of a trend that continues to redefine the cityscape. Among the most significant transformations is the redevelopment of neglected areas, including industrial zones, into vibrant urban spaces. Cities industrial heritage, old factories and mills, once the backbone of Belgrade’s economy, are being repurposed into vivid cultural hubs, office spaces, and residential complexes. This process reflects a global trend seen in cities worldwide, where old structures are either repurposed or replaced by modern developments.

Belgrade’s transformation is taking two distinct paths. On one hand, historic industrial buildings are being reimagined, preserving their facades while introducing new purposes, such as office spaces or cultural venues. On the other hand, entirely new developments are springing up, characterized by modern high-rises and expansive residential and commercial complexes.

One notable example of industrial transformation is the repurposing of former factories into mixed-use spaces. The ongoing redevelopment of a metal products factory is a prime example of this shift, transforming the site into a mixed-use complex. The trend is set to continue with the planned redevelopment of large industrial sites. These vast plots of land, once dedicated to heavy industry, are being rezoned for residential and commercial use, paving the way for their transition into modern urban developments.

Belgrade is following in the footsteps of other major cities that have successfully blended preservation and innovation. In New York, for instance, old warehouses in Brooklyn have been converted into trendy lofts, and London, where the iconic Tate Modern stands as a shining example of industrial revitalization. Tate Modern one of the worlds most famous museums of contemporary art is housed in the former Bankside Power Station. However, Belgrade’s transformation faces unique challenges, as the balance between preserving its heritage and embracing modernization becomes increasingly delicate.

In the coming years, the city is set to gain over a million square meters of new developments. This rapid growth will reshape Belgrade’s identity, leaving residents and visitors alike to witness how effectively its architects and planners navigate this transformative period. Will the new architecture harmonize wilt the old, or will it overshadow Belgrade’s historic charm?  As the stitches of this urban “surgery” take hold, time will reveal whether the city’s latest reinvention enhances its charm and vitality or introduces new complexities to its historic character.

By Petar Mrdja, Associate, JPM Partners