New Serbian Law on Gas
Author: Stefan Mićić, Legal Trainee from the Law Firm „VUK Tax Attorneys“
Date: 10th December 2025
On 3rd December 2025, the National Assembly of the Republic of Serbia adopted the Law on Gas, thereby establishing a separate and more detailed regulatory framework for the natural gas sector, in line with the process of harmonization of laws and by-laws of the Republic of Serbia with its obligations toward the European Union. Upon entry into force of the Law on Gas, the provisions of Articles 220 – 323 of the Energy Law, which regulated natural gas sector in the Republic of Serbia, ceased to apply. Simultaneously, the Law on Pipeline Transport of Gaseous and Liquid Hydrocarbons also ceased to apply.
One of the most significant novelties introduced by the Law on Gas is the possibility of hydrogen flow within the gas pipeline system of the Republic of Serbia. Namely, the Law on Gas stipulates that hydrogen may be injected into the gas pipeline system, to the extent in which it can be technically and safely used and transported through gas pipelines. From energy transition point of view, stated legal solution makes sense particularly regarding usage of green hydrogen (produced by water electrolysis using electricity generated from renewable energy sources), since green hydrogen during its usage does not emit carbon dioxide (CO₂), unlike natural gas. Introduction of such legal basis for hydrogen injection into the gas pipeline system, creates conditions for long-term decarbonization of the Serbian energy sector.
Most extensive novelties introduced by the Law on Gas relate to obligations of the storage operator, as an energy entity which performs activity of natural gas storing and management of natural gas storage. Namely, there is only one (1) storage operator in the Republic of Serbia – the company “PODZEMNO SKLADIŠTE GASA BANATSKI DVOR” d.o.o. Novi Sad (hereinafter: the “Storage Operator”), which manages the underground natural gas storage in Banatski Dvor. The Law on Gas defines that legal entity, prior obtaining licence and being designated as natural gas storage operator, must be certified for performing activity of natural gas storing and management of natural gas storage, by the Energy Agency of the Republic of Serbia (hereinafter: the “Energy Agency”), as Serbian energy-regulatory body. The certification procedure can be initiated: (i) upon request of a legal entity that is not certified as storage operator; (ii) upon request of the Energy Agency if legal entity fails to submit certification request, or (iii) upon reasoned request of the Secretariat of the Energy Community, in accordance with the Treaty establishing the Energy Community.
Considering that only the Storage Operator holds a license in the Republic of Serbia for performing activity of natural gas storing and management of natural gas storage, issued by the Energy Agency, it will continue to perform its activities until completion of the certification procedure. The Storage Operator is required to submit request for certification within six (6) months from the date of entry into force of the by-law that should be enacted by the Energy Minister, which should regulate certification procedure in more detail.
Although there is tendency to formally harmonize Serbian natural gas market with energy regulations of the European Union, Serbian market is not yet genuinely liberalized from the aspect of access to natural gas storage. Particularly, access to the natural gas storage in Banatski Dvor is exercised in accordance with the Storage Operation Rules which the Storage Operator has not yet adopted, and thereby natural gas suppliers are still denied from accessing to natural gas storage, except dominant market participants such as public supplier “JP SRBIJAGAS”, which holds 49% ownership share in the Storage Operator. We will recall that the natural gas storage in Banatski Dvor is connected to the transmission system operated by “TRANSPORTGAS SRBIJA” d.o.o. Novi Sad (hereinafter: the “TRANSPORTGAS SRBIJA”), exclusively through two-way natural gas pipeline Gospođinci – Banatski Dvor.
Furthermore, with the aim of increasing price transparency in the natural gas market and protecting end-consumers and households, the Law on Gas imposes obligation for the Energy Agency to develop the application on natural gas price comparison within two (2) years from the entry into force of the Law on Gas. End-consumers and households must be informed on availability of said application via their natural gas bills or otherwise. The subject application must, among other, fulfil the following requirements: (i) to cover the entire natural gas market in the Republic of Serbia, (ii) to be independent from market participants and ensure equal treatment of energy entities in search results, (iii) to clearly display information on the owner of the application, natural person or legal entity which manages the application, and the method of financing thereof, (iv) to establish clear and objective criteria on which comparisons are based, including services, etc.
By introducing the application on natural gas price comparison, end-consumers and households should be fully informed regarding natural gas prices offered by different suppliers, thereby reducing their dependence on specific supplier while simultaneously increasing competition among suppliers, which represents fundamental principle of a liberalized market. However, the Law on Gas does not regulate in detail modality and deadlines for operational functioning of the subject application (e.g. how, by whom and until when it must be activated), but only imposes obligation for the Energy Agency to develop the application, thereby leaving open question as to whether this mechanism will in practice truly protect interests of end-consumers and households.
In addition to formal harmonization of the Serbian natural gas sector with EU regulations, energy entities are also formally aligning their activities with the obligations imposed to them by the Law on Gas. Namely, the Law on Gas defines that the owner of transmission system who is part of vertically integrated company, must be independent in terms of legal form, organization and decision-making, from other activities non-related to the transmission of natural gas. In this regard, “JP SRBIJAGAS” acts as the public supplier of natural gas while it simultaneously owns largest transmission system in the Republic of Serbia, operated by TRANSPORTGAS SRBIJA.
In order to formally achieve independence of transmission system owners from other energy activities, public supplier “JP SRBIJAGAS” established the company “GAS INFRASTRUKTURA” d.o.o. Novi Sad (hereinafter: the “GAS INFRASTRUKTURA”) on 4th December 2025, with the aim of transferring to that company its ownership over the transmission system operated by TRANSPORTGAS SRBIJA, i.e. with the aim that the company GAS INFRASTRUKTURA performs function of the owner of that transmission system.
Although the company GAS INFRASTRUKTURA will be formally independent, given that “JP SRBIJAGAS” as its shareholder is not competent under the law to manage its business activities, practice in the energy market will demonstrate whether the company GAS INFRASTRUKTURA will be de facto independent in conducting its business activities.
From everything aforesaid, it can be concluded that in the Republic of Serbia there is, at least by declaration, a tendency toward harmonization of the natural gas sector with regulations of the European Union, that should create conditions for establishing liberalized natural gas market in the Republic of Serbia. Our Law Firm will timely and carefully monitor all upcoming activities on the Serbian natural gas market, in order to effectively assist clients with our substantial experience and professional analysis in eliminating all ambiguities in practice.