Alta Banka Bankruptcy: How to Recover Deposits, What Happens to Loans, and Which Deadlines Must Not Be Missed

1. Introduction

At its session held on 30 October 2026, the Executive Board of the National Bank of Serbia (the “NBS”) adopted a decision revoking the operating licence of Alta banka a.d. Beograd (“Alta Banka”). As of the date of the revocation decision, all accounts of Alta Banka were blocked and any disposal of the bank’s assets was prohibited pending the commencement of bankruptcy proceedings.

In its press release, the NBS stated that the licence was revoked in order to protect depositors and other creditors and to prevent the spread of any negative effects on society and the economy. The decision was adopted following supervisory control activities and the imposition of a temporary measure.

Subsequently, on 3 November 2026, the Commercial Court in Belgrade issued Decision No. 10 St 275/26, by which bankruptcy proceedings were commenced against Alta Banka. The decision established that the function of bankruptcy administrator would be performed by the Deposit Insurance Agency and invited all creditors of Alta Banka to file their secured and unsecured claims within 90 days of the date of publication of the notice of commencement of bankruptcy proceedings in the Official Gazette of the Republic of Serbia.

Following the commencement of bankruptcy proceedings, most clients of Alta Banka have been faced with the same questions: what happens to their deposits, securities and items held in safe deposit boxes, and how can they recover them; whether, and in what manner, they must continue to repay their loans; and, more generally, what are the rights and obligations of Alta Banka’s clients after the commencement of bankruptcy proceedings?

As regards the deposits held by clients with Alta Banka, in most cases, recovery may be pursued through two separate procedures:

• payment of the insured portion of the deposits; and
• filing of a claim in the bankruptcy proceedings.

Depending on the category of depositor and the amount of funds held with the bank, a client will use one or both of these procedures to exercise its rights against Alta Banka.

Clients whose securities are held by the bank on their behalf, as well as clients who have concluded a safe deposit box agreement with the bank, exercise their rights by filing a request for the separation of assets, since such assets do not form part of the bankruptcy estate.

On the other hand, clients who have taken out loans with Alta Banka must continue to repay them in accordance with the terms of the loan agreement and the accompanying instructions of the Deposit Insurance Agency, since the commencement of bankruptcy proceedings does not release the bank’s debtors from their obligations.

1. Payment of the Insured Deposit Amount

The questions of who is entitled to payment of the insured deposit amount, when, and under what conditions, are governed by the Law on Deposit Insurance, supplemented by the instructions issued by the Deposit Insurance Agency.

1. Who is entitled to payment of the insured deposit amount?

Under the Law on Deposit Insurance, natural persons, entrepreneurs and micro, small and medium-sized legal entities that held deposits with Alta Banka are entitled to payment of the insured deposit amount.

According to the website of the Deposit Insurance Agency, the insured categories of depositors also include:

• residential building councils;
• registered agricultural holdings;
• religious associations and citizens’ associations;
• attorneys and law offices;
• trade unions;
• sports clubs;

as well as all legal entities that would qualify as micro, small or medium-sized legal entities under the classification criteria set out in the Law on Accounting.

On the other hand, large legal entities, legal and natural persons related to the bank, depositors whose deposits are held under a code or in bearer form, and depositors whose deposits arose from money laundering or terrorist financing are not entitled to payment of the insured deposit amount. Such depositors may therefore enforce their claims against Alta Banka only by filing a claim in the bankruptcy proceedings.

It should also be noted that natural persons are insured irrespective of whether they are residents or non-residents. For entrepreneurs and legal entities, however, residency is a condition, so a foreign company not registered in the Republic of Serbia must exercise its rights by filing a timely claim in the bankruptcy proceedings.

•  What is the insured deposit amount?

Under the Law on Deposit Insurance, deposits are insured up to EUR 50,000 per depositor per bank.

This amount is determined per depositor, on the basis of the balance of all of the depositor’s deposits with Alta Banka, including accrued interest, irrespective of the number or type of accounts and the currency.

In addition, retail investors who used investment services provided by Alta Banka are entitled to request from the Deposit Insurance Agency payment of their protected claim, which covers the cash and financial instruments that the bank held, administered and managed on their behalf, up to a maximum of EUR 20,000 in dinar equivalent. The request must be submitted no later than 3 May 2027.

• When does payment of insured deposits begin and which bank is the paying bank?

According to the Deposit Insurance Agency’s announcement of 6 November 2026, payment of insured deposit amounts begins on 13 November 2026 through Banka Poštanska štedionica a.d. Beograd as the paying bank.

Insured amounts of dinar deposits are paid in dinars, while insured amounts of foreign currency deposits are paid in euros, at the official middle exchange rate of the euro against the relevant currency applicable on 3 November 2026.

Depositors may submit a request for payment of the insured amount at the branches of Banka Poštanska štedionica a.d. Beograd designated for payments to Alta Banka depositors, during regular business hours.

A list of the branches of Banka Poštanska štedionica a.d. Beograd where insured amounts are paid, together with their telephone numbers, is available on the website of the Deposit Insurance Agency.

• What documentation is required for payment of the insured deposit amount?

According to the website of the Deposit Insurance Agency, when submitting a request for payment, the depositor must present:

• a valid identity document; and
• original documentation evidencing the claim, such as a deposit agreement, savings agreement, current account agreement, savings passbook or account card, or any other valid document showing that the depositor had access to the deposited funds before 30 October 2026.

In addition to the above, the authorised representative of a depositor that is an entrepreneur or a micro, small or medium-sized legal entity must present:

• where the request is not submitted by the person registered with the competent authority as legal representative, an authorisation to dispose of funds up to the insured deposit amount, issued on the entity’s letterhead in the name of the authorised person, signed by the registered legal representative and stamped;
• the specimen signature form of the persons authorised to represent the entity, certified by the competent authority (original or certified copy to be presented for inspection). The form must contain the details of the registered legal representative and, where the request is submitted by an authorised person, also the details of that person;
• the original identity card of the registered legal representative or of the person authorised to collect the insured deposit amount, or, exceptionally, a passport or other photo identification document, in accordance with applicable regulations;
• where the depositor instructs that the insured amount in euros be paid by transfer to another domestic bank, the depositor must provide the paying bank with transfer instructions containing the following details: the name of the other domestic bank with which the depositor holds a foreign currency account, the name of the correspondent bank abroad, and the IBAN or account number held with the other domestic bank.

• What is the deadline for submitting a payment request and how can insured amounts be collected?

Depositors are entitled to submit a request for payment of the insured amount within three years of the date of the decision commencing bankruptcy proceedings against the bank, i.e. no later than 3 November 2029.

Natural persons may collect the funds in cash or request that the paying bank transfer them to an account.

Legal entities may receive the insured deposit amount exclusively by transfer to an account.

• How do depositors with funds exceeding the insured amount and depositors whose deposits are not insured enforce their claims?

A depositor whose funds held with Alta Banka exceed the insured amount of EUR 50,000 recovers up to EUR 50,000 through payment of the insured deposit, while the portion of the claim exceeding that amount may be recovered only in the bankruptcy proceedings, by filing a timely proof of claim.

Furthermore, depositors whose deposits are not covered by deposit insurance, primarily large legal entities, may enforce their entire claim against Alta Banka only by filing a timely proof of claim in the bankruptcy proceedings.

1. Filing of Claims in the Alta Banka Bankruptcy Proceedings

The questions of who may file a claim in the bankruptcy proceedings against Alta Banka, when, and in what manner, are governed by the Law on Bankruptcy and Liquidation of Banks and Insurance Companies (the „Law”) and by the Bankruptcy Law.

1. To whom and within what deadline must a claim be filed in the Alta Banka bankruptcy proceedings?

Claims in the Alta Banka bankruptcy proceedings must be filed in writing with the Commercial Court in Belgrade.

The decision commencing bankruptcy proceedings against Alta Banka set a deadline for filing claims of 90 days from the date of publication of the notice of commencement of bankruptcy proceedings in the Official Gazette of the Republic of Serbia.

• What must a proof of claim contain?

A timely proof of claim filed with the competent Commercial Court in Belgrade must contain the following elements:

1. the name and registered office or residence of the creditor, with a contact address;
2. the registration number of the legal entity or, for natural persons, the unique personal identification number;
3. the business or current account number;
4. the legal basis of the claim;
5. the amount of the claim, stating separately the principal amount and the interest calculation;
6. where the claim is secured, the asset over which the creditor has acquired a right to separate satisfaction and, if the claim is not fully secured, the unsecured portion of the claim;
7. a specific claim for relief, applying mutatis mutandis the provisions on the content of a statement of claim under the law governing civil procedure.

• How long do bankruptcy proceedings last and when can creditors expect to be paid?

The Law does not prescribe a deadline by which bankruptcy proceedings against a bank must be concluded.

The Law sets deadlines only for the verification of claims: the Deposit Insurance Agency must determine the validity and amount of the filed claims within six months of the expiry of the deadline for filing claims, and the claims examination hearing must be held no later than 60 days after the expiry of that six-month period.

In addition, within 60 days of the date on which the legal effects of the commencement of bankruptcy proceedings arise, or of the date on which it takes over the assets and rights of the bankrupt debtor, the Deposit Insurance Agency must draw up an inventory of the bankrupt debtor’s assets and prepare an opening bankruptcy balance sheet. The balance sheet must contain, in chronological order, information on significant transactions concluded by the bankrupt debtor during the six months preceding the commencement of bankruptcy proceedings.

The satisfaction of creditors depends on the pace and success of the realisation of the bank’s assets, which is why bankruptcy proceedings against banks tend to be lengthy.

•  In what order of priority are claims paid in the bankruptcy of a bank?

Under the Law, the claims of creditors of a bank in bankruptcy are verified at the claims examination hearing and paid in the following order of priority (payment classes):

1. claims of creditors remaining after payment of the deposit amounts insured under the law governing deposit insurance, i.e. claims of insured depositors for the portion of their deposits exceeding the insured amount of EUR 50,000. Depositors not covered by deposit insurance, primarily large legal entities, are paid their deposit claims in the fourth payment class;
2. claims for public revenues that fell due in the three months preceding the commencement of bankruptcy proceedings, other than pension and disability insurance contributions for employees;
3. claims of the National Bank of Serbia, including claims arising from loans granted to the bank that have not been fully repaid due to a shortfall in the value of the collateral;
4. claims of creditors arising from deposits, other than deposits of banks and other financial institutions;
5. claims of other creditors, other than creditors referred to in items 6) and 7);
6. claims of creditors arising from subordinated liabilities of the bank;
7. claims of creditors who are also shareholders of the bank, other than claims in respect of share capital, which are satisfied from any surplus of the distribution estate in accordance with the law governing the bankruptcy of companies.

1. Repayment of Loans Taken with Alta Banka after the Commencement of Bankruptcy

The commencement of bankruptcy proceedings does not release the bank’s debtors from their obligation to repay their debts. Borrowers must therefore continue to meet their obligations in accordance with the terms of the loan agreements concluded with Alta Banka.

In its announcement of 6 November 2026, the Deposit Insurance Agency called on all debtors to settle their due obligations to Alta Banka by payment to the dinar account held with the NBS specified in the announcement.

• Safe Deposit Boxes and Securities Held with Alta Banka

Unlike cash deposits, items kept in safe deposit boxes and securities held by the bank on behalf of clients are not covered by deposit insurance. These assets belong to the client, not to the bank, and therefore do not form part of the bankruptcy estate and are not used to satisfy the creditors of Alta Banka.

Consequently, in respect of such assets the client is not a bankruptcy creditor required to file a proof of claim, but a creditor with a right of separation, entitled to request Alta Banka in bankruptcy to separate and release its assets.

The manner and timing of the opening of safe deposit boxes are determined by the bankruptcy administrator, and clients should therefore follow the announcements of the Deposit Insurance Agency, which acts as bankruptcy administrator.

• Concluding Remarks

The bankruptcy proceedings involving Alta Bank have raised a number of legal issues for its clients, ranging from the recovery of deposits and the exercise of rights arising from securities to the repayment of outstanding loan obligations. It is of particular importance that clients take all necessary steps in a timely manner to protect and enforce their rights in the bankruptcy proceedings. In particular, depositors whose funds are not fully or are not at all covered by the applicable deposit insurance scheme should ensure that their claims are duly filed in the bankruptcy proceedings within the applicable statutory deadlines.

Bankruptcy law is a significant area of commercial law and an important practice area of Milošević Law Firm.

Our attorneys have extensive experience in representing both creditors and debtors in bankruptcy proceedings, providing comprehensive legal advice at all stages of the proceedings.

Should you have any further questions regarding the exercise of your rights in the bankruptcy proceedings, please do not hesitate to contact us.