Although relatively rare, the European Consumer Centre Bulgaria receives complaints from consumers who experience problems with airlines registered in Serbia. In order to assist these consumers, we contacted the Civil Aviation Directorate of the Republic of Serbia. Below is their response:
Does the Civil Aviation Directorate handle individual passenger complaints?
According to the European Commission, passenger complaints should be addressed to the competent authority responsible for ensuring effective enforcement of the legislation only after the complaint has already been submitted to the air carrier and the passenger disagrees with the reply or the air carrier has not replied at all. The Commission recommends that the air carrier respond within two months.
However, in accordance with Regulation 261/04, the Commission considers that national enforcement bodies competent for the application of this Regulation are not obliged to handle complaints in a manner that guarantees the exercise of each individual passenger's rights.
Accordingly, the national authority responsible for the effective enforcement of the Regulation is not required to take enforcement measures against an air carrier in order to compel it to pay compensation provided for in the Regulation in each individual case, as the sanctioning role of the authority, arising from Article 16(3) of the Regulation, consists of measures to be adopted in response to an infringement detected by the authority in the course of its regular monitoring activities, as provided for in Article 16(1).
Civil aviation authorities strive to provide each passenger with an adequate response that would help them exercise their rights if they are at risk, as well as in cases prescribed by EC 261/04 where there is clear jurisdiction of the supervisory authorities in the Republic of Serbia.
In 2024, the Passenger Rights Department of the Directorate processed 658 individual complaints, and in 2025, approximately 600. Each complaint was assigned a registration number and processed in accordance with the recommendations of the European Commission’s Directorate-General for Mobility and Transport.
What is the usual response time for passenger complaints?
There are no statutory deadlines for authorities responsible for protecting passenger rights to act on a complaint. According to the European Commission’s guidelines on complaint-handling procedures, the processing time should be at most:
-
1–2 months for clear cases;
-
4–6 months for complex cases;
-
more than 6 months for cases involving court proceedings.
Due to procedural steps related to conducting infringement proceedings, particularly measures to establish the necessary facts and to provide the right to be heard to the company concerned, longer processing times may occur.
In practice, most complaints that do not require special action by the competent inspectors are resolved within 15 days.
What documents must a passenger submit for a case to be examined by the authority?
There is no set list of required documentation, as passenger-reported cases vary and may not require the same documents. As a general rule, passengers are required to provide proof of status: a contract of carriage, a response from the carrier if a complaint has been submitted, and a description of the problem.
Passengers submit complaints regarding the operation of aircraft and airport operators:
via the form on the Civil Aviation Directorate’s website or by post: Civil Aviation Directorate of the Republic of Serbia, 23 Skadarska Street, 11000 Belgrade
Which authority is competent to handle cases related to delayed, lost, or damaged baggage on flights operated by airlines registered in Serbia?
The Civil Aviation Directorate is not competent to resolve civil-law claims related to baggage. Passengers must address their claims to the air carrier and, in the event of a dispute, may initiate court proceedings or use internal Alternative Dispute Resolution (ADR) bodies – contacts are available here:
https://vansudsko.must.gov.rs
ADR offers a free mechanism with the same legal effect as a formal complaint or debt collection proceedings.
Aviation inspectors oversee operational aviation processes, while the assessment of actual damage to baggage or cargo and the related costs falls within the jurisdiction of the courts or ADR bodies.
The liability of the air carrier is governed by:
-
Montreal Convention (MC99);
-
Regulation (EC) No 785/2004;
-
national legislation - the Law on Obligations and the Basics of Property Relations in Air Transport.