If your company in North Macedonia takes a loan from a foreign source — including from a related foreign entity — you are legally required to notify the National Bank of North Macedonia. This obligation applies regardless of the loan amount and is primarily for statistical purposes. Failing to notify on time can result in fines for both the company and its authorized representative. This page is part of our practice in business and corporate law. 

Domestic companies that secure financing from foreign sources through loans are required to notify the National Bank about these transactions. This obligation is outlined in the Law on Foreign Exchange Operations (Article 42 – Notification of Credit Transactions) and further detailed in the Guidelines on the Method and Conditions for Individual Notification of Loans Taken by Non-Residents.

These regulations mandate the submission of a report for all credit transactions with non-residents within 10 days following the conclusion of the agreement, or within 5 working days after the full or partial repayment of the loan or any modification to the loan agreement.

ND Forms – Notification Forms for Cross-Border Loans

Notifications are submitted on special forms (ND forms):

• ND 1 – Application for a loan taken from a non-resident: submitted when reporting a new loan.
• ND 2 – Realization of funds: submitted when reporting the use of funds from the loan, based on previously recorded credit transactions.
• ND 3 – Repayment realization: submitted when reporting principal or interest repayment based on previously recorded credit transactions.
• ND 4 – Principal repayment plan: submitted if the repayment plan in the loan agreement does not have regular periodicity — i.e. irregular principal repayments that cannot be calculated according to the basic loan terms.
• ND 5 – Specification of creditors/beneficiaries: used if, according to the loan agreement, several creditors or beneficiaries of the loan are involved.

These forms are appendices to the Guidelines and are accessible via the National Bank of North Macedonia website.

Fines for Non-Compliance

Failure to comply with the notification obligation not only breaches the regulatory framework but also subjects the company to potential fines. These fines range from EUR 200 to EUR 3,000 in denar equivalent for the company, and from EUR 50 to EUR 300 in denar equivalent for the authorised person of the company.

Practical Checklist

If your company in North Macedonia has taken or is planning to take a cross-border loan, verify the following: (1) Notify within 10 days of signing — submit ND 1 to the National Bank within 10 days of concluding the loan agreement. Do not wait for funds to be received. (2) Report drawdowns with ND 2 — each time funds are drawn down from the loan, submit ND 2 within 5 working days. (3) Report repayments with ND 3 — each principal or interest repayment must be reported via ND 3 within 5 working days of the repayment. (4) Use ND 4 for irregular repayment schedules — if the loan agreement does not specify regular periodic repayments, submit ND 4 to report the repayment plan. (5) Use ND 5 for multiple creditors — if the loan involves more than one creditor or beneficiary, ND 5 must accompany the relevant notification. (6) Report any loan modifications within 10 days — changes to the loan agreement (amount, interest rate, term, etc.) must also be notified to the National Bank within 10 days. 

Frequently Asked Questions

Does the notification obligation apply to loans from related foreign entities?

Yes. The obligation applies to all cross-border loan transactions with non-residents, including loans received from parent companies, sister companies or other related foreign entities. The purpose is statistical — all such transactions must be reported regardless of the relationship between the parties.

What is the deadline for notifying the National Bank?

The ND 1 form must be submitted within 10 days of concluding the loan agreement. Subsequent notifications (drawdowns, repayments, modifications) must be submitted within 5 working days of the relevant event.

What are the fines for failing to notify?

Fines range from EUR 200 to EUR 3,000 (in denar equivalent) for the company, and from EUR 50 to EUR 300 for the authorized person of the company. The obligation is treated seriously by the National Bank and failure to comply is regularly sanctioned.

Which form do I use when the loan is first agreed?

Submit ND 1 (Application for a loan taken from a non-resident) within 10 days of signing the loan agreement. This is the first notification and establishes the credit transaction in the National Bank’s records. All subsequent ND forms reference this initial registration.

Are there any exemptions from the notification requirement?

The Law on Foreign Exchange Operations and the National Bank Guidelines do not provide a general exemption based on loan size or relationship between parties. All cross-border loan transactions with non-residents must be notified. If you are uncertain whether a specific transaction is subject to this requirement, legal advice is recommended.

Need legal guidance?

If you need assistance with cross-border financing notifications or foreign exchange compliance in North Macedonia, the team at Lalicic & Partners is at your disposal. Contact us through our website.