A startup registered in the Registry of Subjects of the National Innovation System does not have to prove to the tax authorities that it conducts innovative activity. The Registry confirms that on its behalf. That is not a minor point: the registration is a condition for accessing a range of tax incentives, grants and support programs that can decisively influence the first phase of growth.
According to data published by the Innovation Fund of Serbia, the number of entities registered in the Registry grows year over year, as does the total value of awarded grants. For startups and spin-offs developing their own products and models, registration in the Registry is one of the first and most practical steps toward structured institutional support.
This blog explains who can be registered, what the specific conditions are for startups and spin-offs, and why registration delivers concrete value. For an overview of how to incorporate the company before applying for registration, see our blog on company formation in Serbia.
Contents
- What is the Registry of Subjects of the National Innovation System?
- Who Can Be Registered?
- Conditions for Startup Registration
- Conditions for Spin-Off Registration
- Tax Incentives from Registration
- Innovation Fund Programs and Support
- Visibility Before Investors and Business Angels
- Startup vs. Spin-Off: What is the Difference?
- Frequently Asked Questions
What is the Registry of Subjects of the National Innovation System?
The Registry of Subjects of the National Innovation System is the central database tracking and promoting innovative activity in Serbia. It is maintained by the Innovation Fund. Registration is not a legal obligation: it is an opportunity that innovative companies can use to their advantage.
A useful analogy: think of the Registry as a quality certificate issued by a state institution. Without it, you can claim your company is innovative. With it, you have proven it before a competent authority that has conducted a detailed review of your activity.
If you were previously registered in the Innovation Activities Register (the earlier system), you will have been or will be automatically transferred to the new Registry of Subjects of the National Innovation System. New applicants file their registration request under the Rulebook on the Registry of Subjects of the National Innovation System.
Who Can Be Registered?
The Registry is not limited to newly incorporated companies. The following categories of innovative entities may apply: startups, spin-offs, spin-off research organisations, development and production centres, startup support organisations, and business angels investing in innovative projects.
The fact that business angels can register in the same database as startups is intentional. The Registry is designed as a platform for connecting innovators with capital, which is one of the concrete operational benefits of registration, described in detail in the investor section below.
Conditions for Startup Registration
The Rulebook on the Registry of Subjects of the National Innovation System sets out clear conditions for registration. They are divided into general conditions, which must all be met simultaneously, and specific conditions, of which only one needs to be satisfied.
General Conditions (all must be met)
A startup applying for registration must satisfy all three general conditions at the same time:
- It is not older than 10 years from the date of incorporation at the time of submitting the registration application.
- It is incorporated as a company that was not established through a status change by means of a spin-off or merger, or it is registered as a sole entrepreneur in accordance with the Companies Act.
- No bankruptcy or liquidation proceedings have been initiated against it.
Specific Conditions (one is sufficient)
In addition to the general conditions, the startup must satisfy at least one of the following specific conditions:
- Research and development (R&D) expenses accounted for at least 10% of total expenses in the previous calendar year. For startups incorporated in the year of application that have no financial history, the reference period is from the date of incorporation to the date of submission.
- The startup holds intellectual property rights or other intellectual assets directly related to the innovative activity it performs.
- The Evaluation Committee established by the Fund has assessed and confirmed that the applicant is developing an innovative product or service and a scalable business model.
The third specific condition is the most flexible and the most useful for early-stage startups that do not yet have R&D history in their financial statements or registered intellectual property rights. The Fund's Committee evaluates the business model directly, without formal financial preconditions.
Conditions for Spin-Off Registration
A spin-off is formed when a company or a natural person with developed resources, expertise and a business network establishes a new entity that builds on those foundations. This makes it attractive to investors, as the new venture already rests on a proven base from the founders.
The general conditions for a spin-off are the following:
- It is incorporated as a company whose founder is a company and/or a natural person.
- It is not older than 10 years from the date of incorporation at the time of submitting the application.
- No bankruptcy or liquidation proceedings have been initiated against it.
In addition to the general conditions, a spin-off must satisfy the same set of alternative specific conditions as a startup: R&D expenses of at least 10%, ownership of intellectual property rights directly related to its innovative activity, or a positive assessment by the Fund's Evaluation Committee.
Developing an innovative product in-house, rather than relying on outsourcing, has a direct impact on the ability to register. A spin-off that outsources development and holds no IP rights and has no R&D expenses will find it harder to satisfy the specific conditions than one that builds everything internally.
Tax Incentives from Registration
The tax value of registration is concrete and measurable. The Corporate Income Tax Act provides that a company that is not itself a startup (i.e., an investor) may, where it invests in the share capital of a registered startup engaged in innovative activity, achieve a reduction of its corporate income tax liability in the amount of 30% of the investment made.
This is important to understand from two perspectives. From the startup's standpoint: registration makes it more attractive to corporate investors for whom the tax incentive is a direct financial motivation. From the investor's standpoint: without proof that the startup is registered and conducts innovative activity, the tax authority may challenge the right to the incentive during an audit.
Registration is that proof. The Fund has already verified the conditions at the time of registration, so the startup does not have to prove this again to the tax authorities. More on tax incentives available to innovative companies is available in our blog on startup investment in Serbia.
Innovation Fund Programs and Support
The Innovation Fund is not only a registration body: it is an active financier of innovative projects. Through various programs, it offers support tailored to different stages of development.
The Katapult program targets early-stage startups developing innovative products or services that have not yet reached commercial validation. The Smart Start program targets later-stage companies seeking capital to scale.
Beyond financial support, the Fund organises investment conferences where registered entities can directly present their projects to investors. This is, alongside the tax benefits, one of the concrete operational values of registration.
A practical note: do not wait until you are fully prepared before applying for registration. Registration does not require business maturity. It requires the prescribed conditions to be met and the innovative character of the activity to be clearly articulated. The earlier you register, the sooner you begin building visibility and accessing support.
Visibility Before Investors and Business Angels
Investors, both institutional and private business angels, increasingly use the Registry as a filter for identifying startups that have passed a minimum level of review by a state institution. Registration signals: this company develops its own innovative product, has R&D activity or IP rights, and is not in bankruptcy or liquidation.
That is not a small signal. Many early-stage investors receive hundreds of inbound requests weekly. A startup registered in the Registry immediately stands out from one that is not, because it carries a regulatory confirmation of its innovative activity.
The Fund regularly organises annual investment conferences where registered entities can present their projects directly to investors. This is, alongside the tax benefits, one of the concrete operational values of registration. For a broader overview of fundraising models and investor negotiations, see our blog on startup investment in Serbia and term sheets.
Startup vs. Spin-Off: What is the Difference and Why Does it Matter?
In practice, a startup and a spin-off can look identical from the outside: a new company, a young team, an innovative product in development. The difference lies in the origin and background of the founders.
A startup is a new company born from an idea, without a mandatory prior corporate parent. A spin-off is formed when an existing company or an experienced natural person with established resources, networks and expertise creates a new company to develop a specific innovative line separately from the main business.
This distinction has practical significance for the registration process. Spin-offs do not need to prove they were not formed through a status change, but must demonstrate the corporate or natural person origin of their founder. Startups must prove they were not formed through a merger or spin-off.
| Feature | Startup | Spin-Off |
|---|---|---|
| Origin | New idea, no mandatory prior corporate parent | Formed from an existing company or experienced founder |
| Founder | Natural or legal person (no restriction) | Company and/or natural person |
| Age limit for registration | Up to 10 years from incorporation | Up to 10 years from incorporation |
| Specific conditions | Same set (R&D, IP rights or Committee assessment) | Same set (R&D, IP rights or Committee assessment) |
| Appeal to investors | Growth potential, originality of idea | Proven founder expertise, lower execution risk |
Frequently Asked Questions
How do you register a startup in Serbia's Innovation Registry?
The application is submitted to the Innovation Fund through the einovacije.rs portal. Supporting documentation proving fulfilment of the prescribed conditions must be attached: an extract from the BRA register, financial documentation showing R&D expenses or proof of IP rights, or a request for Evaluation Committee assessment. The Fund conducts the review and issues a decision on registration.
What are the conditions for startup registration in the National Innovation System Registry?
A startup must satisfy three cumulative general conditions: be younger than 10 years, be incorporated as a company or sole entrepreneur (not formed through a status change), and not be in bankruptcy or liquidation. In addition, it must satisfy one of three alternative specific conditions: R&D expenses of at least 10% of total costs, ownership of IP rights directly related to its innovative activity, or a positive Committee assessment that it develops an innovative product and a scalable business model.
What is the tax incentive for investing in a registered startup?
A company that invests in the share capital of a startup registered in the Registry may achieve a 30% reduction in its corporate income tax liability on the amount invested. This right is established by the Corporate Income Tax Act. Registration in the Registry is a key piece of evidence when the tax authority audits compliance with the conditions for this incentive.
Can a newly incorporated company apply for registration immediately?
Yes. A newly incorporated company may submit its application immediately after formation, without waiting for the end of the business year. In that case, R&D expenses are shown for the period from the date of incorporation to the date of submission. Alternatively, one of the other two specific conditions may be satisfied: ownership of IP rights or a positive assessment by the Fund's Evaluation Committee.
How long does registration last and does it need to be renewed?
The Rulebook sets out the conditions and timeframes for registration, as well as the conditions for removal from the Registry. The Fund is responsible for updating registered data. Entities that cease to meet the conditions may be removed. We recommend consulting a legal team familiar with the current provisions of the Rulebook to properly monitor registration status.
What is the difference between a startup and a spin-off for Registry registration purposes?
A startup is a new company or sole entrepreneur without a mandatory prior corporate parent. A spin-off is formed from an existing company or an experienced founder. The general registration conditions differ (particularly regarding the origin of the founder), while the specific conditions are identical for both types of entity.
Does registration guarantee access to Innovation Fund programs?
No, not automatically. Registration is a prerequisite or advantage when applying for Fund programs, but each program has its own selection criteria. Registration increases the chances of success and accelerates the eligibility review, but does not replace the application process for a specific support program.
For startups and spin-offs that want to structure their intellectual assets, founding documents and investor relationships in a way that maximises their chances of registration and subsequent growth, the Zunic Law team provides legal support from company formation through to investor negotiations. Visit our IT law practice page for more on the services we provide to innovative companies.
1 Rulebook on the Registry of Subjects of the National Innovation System, available at paragraf.rs.
2 Corporate Income Tax Act (Art. 50ž), Official Gazette RS, available at paragraf.rs.
