No. 011-00-13/2026-02 Date: 31. 3. 2026.
MINISTRY OF HEALTH
Dr Zlatibor Lončar, Minister
11000 BELGRADE
Nemanjina 22-26
Subject: Initiative to amend Article 114 of the Law on Health Insurance (“Official Gazette of the RS” nos. 25/2019, 92/2023 and 109/2025 – other law)
Dear Mr. Lončar,
The Commissioner for the Protection of Equality, within the competences prescribed by the Law on the Prohibition of Discrimination,[1] monitors the implementation of laws and other regulations and initiates the adoption or amendment of regulations with the aim of improving equality and protection against discrimination.
Citizens have addressed the Commissioner for the Protection of Equality, pointing to the unfavorable position of health insured persons with chronic diseases when using health care at the expense of mandatory health insurance funds in cases of emergency medical assistance during temporary stay abroad, asking the Commissioner to take measures within their competence. In this regard, the Commissioner submitted a proposal for the assessment of the constitutionality and legality of Article 114 of the Law on Health Insurance to the Constitutional Court in October 2025. However, since citizens have continued to address us regarding this issue, for example employees in diplomatic-consular missions, and bearing in mind that the decision of the Constitutional Court has still not been issued, we consider it most expedient for the Law to be amended in accordance with anti-discrimination regulations.
Citizens point to the impossibility of exercising the right to health insurance for certain health insured persons in emergency cases when they find themselves abroad. They state that, based on a certificate from the chosen doctor, the RHIF issues a certificate that may be used abroad as a basis for an emergency health service at the expense of the RHIF. If a person suffered from an acute or chronic disease in an acute phase in the last 12 months, this person, in accordance with the law, cannot exercise the right to health care abroad during their stay, which they consider unjustified and unconstitutional. They further state that in practice chronic diseases include everything from which someone suffered in the last 12 months, and that a chronic disease does not pass with the passage of time, which is why, for example, people with arthritis, lymphedema, lupus, psoriasis, people on dialysis, etc., can practically never again exercise health care abroad at the expense of the RHIF. Citizens and civil society organizations point out that such exclusion of a number of citizens based on health status is unjustified, unfair and discriminatory because if, for example, this person experiences a traffic accident or food or water poisoning, they cannot receive medical assistance at the expense of the RHIF even though the emergency condition for which they requested treatment abroad is not connected with the underlying illness. They also point out that persons with developmental difficulties or chronic or rare diseases or older persons practically can never exercise the right abroad to this type of health care, despite having health insurance that they pay like all other citizens who, unlike them, can exercise this right. They consider that the above represents the “mockery” of a legitimate mechanism that should serve citizens in accordance with the set goals and purpose of health care, and not that in this way, thanks to an “unconstitutional provision, only insurance companies benefit”. They further consider that only 5% of citizens who are “as healthy as an ox” can exercise the right to insurance, which indicates that the state has “set the bar” so high that “the vast majority of citizens can never jump over it”. In their submissions, they pointed out that the above represented a major problem in exercising some other rights, such as, for example, obtaining a temporary residence permit. They consider it unjustified that, solely because they had dental surgery or an intervention involving ultrasound therapy for breaking up kidney stones, or thyroid cancer many years ago because of which they are on constant therapy, they are excluded from this form of health care.
Furthermore, citizens employed in diplomatic-consular missions who are assigned to work abroad, and to whom the aforementioned Article 114 of the Law on Health Insurance also applies, have also addressed the Commissioner. Citizens point out that an employed worker is guaranteed the right to health care during work by the Labor Law,[2] without stating any conditions in terms of health status. It is further stated that in the Republic of Serbia there is no health status check before concluding employment (except in special cases) and that for an employee working for an employer in the Republic of Serbia, when being assigned to work abroad, the same conditions relating to their health status do not apply as for an employee who is not assigned abroad, and that the employee, based on their health status, is placed in a less favorable position if assigned to work abroad.
The Ministry of Health, by letter no. 011-00-52/2025-05 of September 12, 2025, responding to the questions of the Commissioner, informed the Commissioner for the Protection of Equality that the provision of Article 114 paragraph 1 of the Law on Health Insurance (hereinafter: the Law) is a solution that was also contained in the previous Law on Health Insurance,[3] then regulated by Article 65, which ceased to be in force with the adoption of the new Law on Health Insurance,[4] and that, accordingly, it follows that this is a legal solution that has been applied for many years and at this moment it is not possible to precisely state all the guidelines for the preparation of a law in the given time frame. It was further noted that when proposing legal solutions, account is taken of the real capacities in the mandatory health insurance system, which also relates to the funds from which the exercise of rights in that system is financed, and accordingly the most optimal solutions are proposed, which would also prevent possible abuses in the exercise of rights in that system, which, regarding the specific topic such as exercising emergency medical assistance during temporary stay abroad, means preventing the possibility that the exercise of the stated right actually represents targeted treatment of an insured person abroad, contrary to the bylaw regulating the treatment of insured persons abroad. Furthermore, in response to the question for what reasons the period of 12 months was determined, and not some other period, such as a shorter period relating to the time before travel, it was indicated that it is difficult to give a precise answer, bearing in mind the period from which this Article of the Law dates, but one may proceed from the fact that “the period of 12 months is an appropriate period in which the patient’s health status can be assessed for the purpose of issuing the certificate”. It was also indicated that the period of 12 months is taken into account for some other solutions in the Law as well e.g. the basis for calculating salary compensation is the average salary that the insured person earned in the previous 12 months, before the month in which temporary incapacity for work occurred. In response to the Commissioner’s question about what is meant by the standard “for which longer or permanent treatment is required” and whether such a fact is assessed exclusively together with the fact that the insured person is not in a condition that would, shortly after arrival abroad, require treatment, i.e. placement in an inpatient health institution, the letter of the Ministry of Health states that the Law does not regulate the standards of treatment themselves, since these are professional issues and depend on the medical indications of the patient, on the one hand, and on contemporary scientific achievements in the field of medicine, on the other. It was indicated that for an insured person for whom, based on the findings and opinion of the chosen doctor, it is established that in the last 12 months before going abroad, e.g. 11 months before requesting the certificate, they suffered from acute or chronic diseases in an acute phase, the medical commission issues an assessment that the conditions for issuing a certificate for the use of health care abroad have not been met, explaining the medical reasons for such an assessment in each individual case. Based on such an assessment issued by the medical commission, the home branch has no basis for issuing a certificate for the use of health care abroad, and the medical commission makes the assessment based on the findings and opinion of the chosen doctor, and, where necessary, also based on medical documentation and insight into an extract from the health record. According to the data available to the Republic Health Insurance Fund, private practice does not have the possibility to enter interventions and the course of treatment into the health record, but the findings and opinion of the chosen doctor are given exclusively based on medical documentation that the chosen doctor entered into the insured person’s health record, regardless of whether that documentation was issued by a “private practice” or by a health institution from the Plan of the Network of Health Institutions.
The letter of the Ministry of Health further clarified that the provision of Article 114 paragraph 1 of the Law on Health Insurance applies to all insured persons travelling abroad regardless of whether the country in question is one with which the Republic of Serbia has concluded a social insurance agreement or not, and that it also applies to employees in diplomatic-consular missions of the Republic of Serbia in countries with which we have a social insurance agreement, as well as in those with which the Republic of Serbia has not concluded a social insurance agreement. It was further stated that in the period from January 1, 2024, to December 31, 2024, the organizational units of the Republic Health Insurance Fund issued a total of 76,886 certificates on the right to use health care during stay abroad, namely 4,994 forms 03-12 for countries with which we have not concluded a social insurance agreement 4,212 certificates on the right to use health care for persons assigned to work in another contracting state, and 67,680 certificates on the right to use health care during temporary stay in another contracting state, and that as of December 31, 2024, there were a total of 6,684,586 insured persons in the branches of the Republic Health Insurance Fund. It was further stated that Bosnia and Herzegovina, Montenegro and North Macedonia have provided in their legislation for a provision establishing prior fulfilment of conditions regarding health status for the purpose of issuing a certificate on the right to health care abroad, while European Union Member States do not have such provisions.
Article 21 of the Constitution of the Republic of Serbia[5] prescribes that everyone is equal before the Constitution and the law (paragraph 1); that everyone has the right to equal legal protection, without discrimination (paragraph) 2; that any discrimination, direct or indirect, on any grounds, and particularly on the grounds of race, sex, national affiliation, social origin, birth, religion, political or other belief, property status, culture, language, age and mental or physical disability, is prohibited (paragraph 3); that special measures which the Republic of Serbia may introduce in order to achieve full equality of persons or groups of persons who are essentially in an unequal position compared with other citizens shall not be considered discrimination (paragraph 4). In addition, Article 68 of the Constitution prescribes that everyone has the right to protection of their physical and mental health.
The European Convention for the Protection of Human Rights and Fundamental Freedoms,[6] which the Republic of Serbia has ratified, in Article 14 prohibits discrimination and prescribes that the enjoyment of the rights and freedoms outlined in this Convention shall be secured without discrimination on any ground, such as sex, race, color, language, religion, political or other opinion, national or social origin, association with a national minority, property, birth or other status.
The constitutional prohibition of discrimination is further elaborated by the Law on the Prohibition of Discrimination,[7] which in Article 2 paragraph 1 item 1 prescribes that discrimination and discriminatory treatment mean any unjustified differentiation or unequal treatment, that is, omission exclusion, restriction or giving priority in relation to persons or groups as well as to members of their families, or persons close to them, in an open or concealed manner, based on race, skin color, ancestors, citizenship, national affiliation or ethnic origin, language, religious or political beliefs, sex, gender, gender identity, sexual orientation, sex characteristics, income level, property status, birth, genetic characteristics, health status, disability, marital and family status, criminal record, age, appearance, membership in political, trade union and other organizations and other actual or presumed personal characteristics. The provisions of Article 8 of the Law on the Prohibition of Discrimination prescribe that a violation of the principle of equal rights and obligations exists if a person or group of persons, because of their personal characteristic, is denied rights and freedoms or is imposed obligations which, in the same or similar situation, are not denied or imposed on another person or group of persons, unless this is justified by a legitimate aim and the means of achieving that aim are appropriate and necessary. Article 27 of this Law prescribes that discrimination against persons or groups of persons based on their health status, as well as members of their families, is prohibited.
The Law on Health Insurance,[8] in Chapter VI, Use of Health Care Abroad and Referral for Treatment Abroad, prescribes the right to use health care at the expense of mandatory health insurance funds. The provisions of Article 111 prescribe that a health insured person whom the employer sends to work, professional training or education in a country with which an international agreement on social insurance has been concluded has the right to use health care at the expense of mandatory health insurance funds in accordance with the concluded agreement. The provisions of Article 112 prescribe that in the event that the insured person is sent to a country with which an international agreement on social insurance has not been concluded, they have the right to use health care only in the case of emergency medical assistance in order to eliminate an immediate danger to the life of the insured person, if the insured person is: a detached worker; sent to work as an employee in the household of a domestic citizen serving in that country, with international and foreign organizations, i.e. an employer; sent for education, professional training and specialization, and on an official trip.
The provisions of Article 113 prescribe that an insured person during a private stay abroad has the right to use health care at the expense of mandatory health insurance funds only in the case of emergency medical assistance in order to eliminate an immediate danger to the life of the insured person.
The provisions of Article 114 of this Law prescribe that the right to use health care abroad, at the expense of mandatory health insurance funds, belongs to an insured person if their health condition before their departure abroad is such that it has been established that they do not suffer, i.e. that they have not suffered from acute or chronic diseases in an acute phase, in the last 12 months, for which longer or permanent treatment is required, i.e. that the insured person is not in a condition which would, shortly after arrival abroad, require treatment, i.e. placement in an inpatient health institution, including other health services. It is further prescribed that the health condition referred to in paragraph 1 of this Article is determined by the expert-medical body of the Republic Fund based on the findings and opinion of the chosen doctor, on the existence of the conditions referred to in paragraph 1 of this Article, and the branch issues a certificate for the use of health care abroad, (hereinafter: certificate for the use of health care) (paragraph 2). For the purpose of issuing the certificate for the use of health care, the expert-medical body of the Republic Fund may order the insured person to undergo certain types of medical examinations, to determine the health condition of the insured person (paragraph 3). The provision of the findings and opinion of the chosen doctor, i.e. the determination of the health condition by the expert-medical body of the Republic Fund, i.e. the issuing of the certificate for the use of health care, is provided to the insured person from mandatory health insurance funds (paragraph 4). The certificate for the use of health care is issued based on a direct examination of the insured person by the chosen doctor, as well as based on medical documentation, namely: insight into the health record, insight into the extract from the health record, the findings and opinion of the chosen doctor that the insured person does not suffer and has not suffered from acute or chronic diseases in an acute phase in the last 12 months for which longer or permanent treatment is required, i.e. that the insured person is not in a condition which would, shortly after arrival abroad, require longer treatment, i.e. placement in an inpatient health institution, including other health services, as well as a certificate from the chosen doctor-dentist on the condition of the teeth (paragraph 5). The Minister, at the proposal of the Republic Fund, regulates in more detail the conditions and manner for the use of health care of insured persons abroad (paragraph 6), and the branch issues the certificate for the use of health care on the form prescribed by the Minister (paragraph 7).
The provisions of Article 116 of the Law on Health Insurance prescribe that an insured person who was provided emergency medical assistance during their stay abroad, and who stayed in that country without a previously issued certificate for the use of health care, does not have the right to reimbursement of costs incurred by using emergency medical assistance during the stay abroad, including the costs of transport for return to the place of residence in the Republic of Serbia. Paragraph 2 of this Article prescribes that the costs of emergency medical assistance provided to an insured person in a country with which an international agreement on social insurance has been concluded, and who stayed in that country without a previously issued certificate for the use of health care, including the costs of transport for return to the place of residence in the Republic of Serbia, are paid by the Republic Fund, and borne by the insured person upon the submission of a request for reimbursement of costs by the Republic Fund.
It is undisputed that, in accordance with the Constitution of the Republic of Serbia (Article 21) and the Law on the Prohibition of Discrimination, discrimination is prohibited and is defined as any unjustified differentiation or unequal treatment, i.e. omission exclusion, restriction or giving priority in relation to persons or groups as well as members of their families, or persons close to them, in an open or concealed manner, based on a personal characteristic, including health status as a ground of discrimination. In order to answer the question whether entire groups of insured persons have been placed in an unjustifiably less favorable position based on their health status as a personal characteristic in relation to other insured persons who do not have such a health condition, it is necessary to consider whether the imposed restriction denies rights and freedoms or imposes obligations which, in the same or similar situation, are not denied or imposed on another person or group of persons, and whether such a restriction is justified by a legitimate aim, and whether the means for achieving that aim are appropriate and necessary.
By analyzing the stated legal provisions, it may be concluded that the law recognizes different situations depending on whether the insured person is going to a country with which an international agreement on social insurance has been concluded or not. When the employer sends the insured person to work, professional training or education in a country with which an international agreement on social insurance has been concluded, the insured person has the right to use health care at the expense of mandatory health insurance funds in accordance with the agreement (Article 111). A different situation is when the employer sends the insured person to work, training or education in a country with which an international agreement on social insurance has not been concluded (Article 112) or when the insured person is privately staying abroad (Article 113). However, the provisions of Article 114 apply to all insured persons travelling abroad regardless of whether the Republic of Serbia has concluded a social insurance agreement with the specific country or not.
Having in mind the prescribed condition from Article 114 of the Law on Health Insurance, it is undisputed that this Article places a large group of insured persons in an unequal position and prevents them from exercising the right to use health care abroad at the expense of mandatory health insurance funds, in case of urgent need in order to eliminate an immediate danger to the life of the insured person, based on their health status. That is, it is undisputed that if the insured person does not have an acute or chronic disease in an acute phase in the last 12 months, they will be able to exercise emergency medical care abroad in accordance with the stated Article. Therefore, it is undisputed that the first condition for speaking of discrimination has been met, namely that the stated restriction denies rights, i.e. imposes obligations which, in the same or similar situation, are not denied or imposed on another person or group of persons based on health status as a personal characteristic. In order to determine whether such a restriction, i.e. exclusion, is permitted, it is necessary to consider whether it is justified by a legitimate aim and whether the means for achieving that aim are appropriate and necessary.
The European Court of Human Rights, in its extensive case-law, consistently takes the position “that equality of treatment is violated if there is no objective and reasonable justification for the distinction, and that the existence of such justification must be assessed in relation to the aim and consequences of the measure under consideration, taking into account the principles that most often prevail in a democratic society”. The European Court took the position that Article 14 of the Convention, which relates to the prohibition of discrimination, is violated when it is established that there is no “reasonable relationship of proportionality between the means employed and the aim sought to be realized”[9]. Therefore, the position of the Court is that every criterion that may lead to discrimination must be carefully considered and justified. All criteria that may lead to discrimination must be proportional and justified by objective reasons[10].
The Law on Health Insurance prescribes that mandatory health insurance is organized on the principles of: mandatory participation, solidarity and reciprocity, publicity, protection of the rights of insured persons and protection of the public interest, continuous improvement of the quality of mandatory health insurance, and economy and efficiency of mandatory health insurance. The principle of solidarity and reciprocity implies a mandatory health insurance system in which the costs of mandatory health insurance are borne by insured persons and other contribution payers by paying contributions on earned income, while the rights from mandatory health insurance are used by those insured persons in whom illness or another insured event has occurred. The principle of protection of the rights of insured persons and protection of the public interest implies the duty of the Republic Fund, when exercising rights from mandatory health insurance, to enable insured persons to exercise and protect their rights as easily as possible, taking care that the exercise of their rights is not to the detriment of the rights of other persons nor contrary to the public interest established by law, while the principle of economy and efficiency implies that rights from mandatory health insurance, in full scope, content and standard, are exercised with as little financial and other resources as possible (Article 5).
Therefore, insured persons of mandatory health insurance in Serbia, who officially or privately stay abroad in a country with which an agreement on social insurance has not been concluded, have the right to health care at the expense of mandatory health insurance funds only in the case of emergency medical assistance in order to eliminate an immediate danger to the life of the insured person. In accordance with the Law on Health Care, the Republic Fund has the duty, when exercising rights from mandatory health insurance, to enable insured persons to exercise and protect their rights as easily as possible, taking care that the exercise of their rights is not to the detriment of the rights of other persons nor contrary to the public interest established by law. The decision to limit health care abroad only to emergency cases for the purpose of eliminating an immediate danger to the life of the insured person may be considered justified and proportionate in accordance with the stated principles of protection of the public interest and economy and efficiency. This is especially so because the Law on Health Insurance also regulates referral for treatment abroad, i.e. that an insured person may, exceptionally, be approved for treatment, the implementation of diagnostic procedures, i.e. the establishment of a diagnosis abroad, at the expense of mandatory health insurance funds, for the treatment of an illness, condition or injury that cannot be successfully treated in the Republic of Serbia, i.e. for diagnostic procedures that cannot be carried out in the Republic of Serbia, i.e. for the establishment of a diagnosis that cannot be established in the Republic of Serbia, and in the country to which the insured person is referred there is a possibility for successful treatment of that illness, condition or injury, i.e. for carrying out the diagnostic procedure or establishing the diagnosis (Article 120).
However, the Commissioner points out that the second part of the provision of Article 114 of the Law on Health Insurance is disputable, by which a restriction is prescribed in exercising the right to the provision of emergency medical care abroad at the expense of the RHIF: “if their health condition before their departure abroad is such that it has been established that they do not suffer, i.e. that they have not suffered from acute or chronic diseases in an acute phase, in the last 12 months, for which longer or permanent treatment is required”.
It follows from the stated provision that in this way a large number of insured persons of mandatory health insurance, who in accordance with the Constitution and the Law on Health Insurance have the right to health care provided from health insurance contributions, are excluded. In accordance with the provisions of Article 8 of the Law on the Prohibition of Discrimination, it is necessary to analyze the existence of proportionality between the measures taken and the aim sought to be achieved by those measures. The question arises of the justification and proportionality of restricting the right to health care at the expense of mandatory insurance in emergency cases abroad only for a certain group of insured persons, i.e. denying the right to insured persons who have or have had an acute or chronic disease in an acute phase, in the last 12 months, for which longer or permanent treatment is required. By analyzing the provision, the primarily disputable issue is the set time frame of 12 months, which automatically leads to exclusion from the right, with the prescribing of the broadest possible condition, namely that the person has an acute or chronic disease in an acute phase for which longer or permanent treatment is required.
According to available definitions in medical literature, an acute disease is predominantly defined as a disease that develops quickly and usually lasts for a short time, unlike chronic diseases, which are most often long-lasting and may last for months, years or even a lifetime. The word “chronic” itself indicates that such a disease requires permanent or longer treatment in order to keep the disease under control.
The provision does not make it possible to see the justification of such a condition, because the health condition of a person who had an acute disease or a chronic disease in an acute phase in the last 12 months may be stable and under control. It may even represent a lower risk in terms of the occurrence of an insured event or risk compared with a person who exercised the right and received a certificate of fulfilment of the conditions for exercising health care abroad, because a person who has a chronic disease is more often subject to constant monitoring by a doctor due to the nature of their disease, or that person themselves pays more attention to their own health because they are aware of the possible risks carried by a chronic disease if it is not treated.
The Commissioner further points out that the Republic Fund issues a certificate on the use of health care based on a direct examination by the chosen doctor and based on medical documentation: insight into the health record, insight into the extract from the health record, as well as the findings and opinion of the chosen doctor. Given that in the Republic of Serbia there is still no unified health record into which every examination or procedure performed by the insured person in a health care institution is entered, whether in an institution from the Plan of the Network of Health Institutions or one established from funds that are not state funds (so-called private practice) the possibility is opened of obtaining a certificate that enables health care abroad in emergency cases at the expense of the Fund also for persons who have, i.e. had, an acute or chronic disease in an acute condition requiring longer or permanent treatment in the last 12 months, but this fact was not entered in their record. In the same position are insured persons who contact doctors less frequently and who will exercise medical protection abroad from the Fund’s funds regardless of their health condition in the previous period, which funds, we again point out, are provided by the payment of contributions by all insured persons.
Also, the disputed provision of the law places persons of poorer financial status at greater risk of discrimination, given their limited financial ability to use the services of so-called private practice, since they are fully directed toward health care financed from the budget.
This provision could possibly be understood if the condition for exercising the right at the expense of the Fund were equal for all insured persons, in the sense that no insured person whose illness requires inpatient treatment before travel would receive a certificate on the right to health care abroad, however, the currently valid Article permanently excludes entire groups of persons from exercising the right to health care abroad because of the fact that their illness is of a permanent, i.e. chronic, character in terms of disease classification.
The Commissioner believes that such an exclusionary condition is neither balanced nor proportionate to the aim sought to be achieved, and that the same aim could have been achieved by less restrictive means, especially bearing in mind that only emergency health care is covered at the expense of the Fund in order to eliminate an immediate danger to the life of the insured person, and not treatment abroad.
The Commissioner further points out that the ratio of the norm cannot be discerned with regard to the period of 12 months before travel and what guided the legislator when choosing precisely this period. This is particularly so if a person had an acute disease which they cured, for example, 11 months ago, and in the twelfth month wishes to travel abroad. The question arises why that person would be excluded from health insurance at the expense of the Fund in the case of emergency medical assistance necessary to eliminate a danger to the life of the insured person. And conversely, an insured person who did not suffer from illness in the last 12 months before going abroad is not exempt from the risk that, after arriving in another country, the need for emergency health care will arise, while their costs will be covered by the Fund, from funds provided by the payment of contributions by all insured persons (both those who have an acute or chronic disease in an acute phase and those who do not have this health condition). Citizens have pointed out to the Commissioner in their submissions that, for example, a person suffering from diabetes or rheumatoid arthritis, due to the nature and permanence of their illness, will never be able to exercise health care abroad in the case of an emergency medical illness because Article 114 of the Law on Health Care excludes them from such a possibility. Also, from the real-life examples pointed out by citizens in their submissions to the Commissioner, situations in which emergency medical assistance is needed are mostly not caused by a chronic disease, but by an accident (e.g. injuries from a fall, poisonings, etc.), which cannot be predicted and which may happen both to a person who has no illness and to a person who was cured several months earlier or to a person with a chronic disease who is under constant therapy.
In connection with all the above, the Commissioner is of the opinion that the prescribed condition relating to the health condition of the insured person excludes a large number of insured persons of the Republic Health Insurance Fund from the possibility of using the right to health care abroad at the expense of mandatory health insurance funds, and is not appropriate and necessary for achieving the lawful aim of enabling insured persons to exercise and protect their right as easily as possible.
Having in mind all the above, in accordance with the provision of Article 33 paragraph 1 item 7 of the Law on the Prohibition of Discrimination, we submit this initiative to the Ministry of Health to consider amending Article 114 of the Law on Health Insurance so that health care at the expense of the Fund is provided to all insured persons in the case of emergency medical assistance abroad, regardless of whether the insured person suffers or has suffered from a chronic disease or a chronic disease in an acute condition in the last 12 months.
It is necessary that you inform us about the actions taken. We use this opportunity to remind you to submit the Draft Law to us for opinion in accordance with the prescribed procedures.
[1] “Official Gazette of the RS”, Nos. 22/09 and 52/21
[2] Article 12 of the Labor Law (“Official Gazette of the RS”, Nos. 24/2005, 61/2005, 54/2009, 32/2013, 75/2014, 13/2017 – CC decision, 113/2017, 95/2018 – authentic interpretation and и 109/2025 – oth. law)
[3] “Official Gazette of the RS”, Nos. 98/06 and 115/21
[4] “Official Gazette of the RS”, No. 25/19
[5] “Official Gazette of the RS”, Nos. 98/06 and 115/21
[6] “Official Gazette of Serbia and Montenegro – International Treaties”, Nos. 9/03, 5/05, and 7/05 – Corrigendum, and “Official Gazette of the Republic of Serbia – International Treaties”, Nos. 12/10 and 10/15
[7] “Official Gazette of the RS”, Nos. 22/09 and 52/21
[8] “Official Gazette of the RS”, Nos. 25/2019 and 92/2023
[9] Affaire “relative a certains aspects du regime linguistique de l’enseignement en belgique” C. Belgique (au principal), submission No. 1474/62 et al, judgement of July 23, 1968. https://hudoc.echr.coe.int/fre#{%22itemid%22:[%22001-62083%22]}
[10] Ferrero Quintana vs. Spain (2024), No. 2669/19 of November 26, 2024. https://hudoc.echr.coe.int/#{%22itemid%22:[%22001-238103%22]}
COMMISSIONER FOR THE PROTECTION OF EQUALITY
Milan Antonijević
