Over the past half-decade, surveillance infrastructure has proliferated across Bosnia and Herzegovina. In the Republika Srpska entity, 505 cameras were acquired in 2020, mostly in Banja Luka and East Sarajevo. More than 40 of these cameras have capabilities for facial recognition.
The authorities insist that these cameras are not used for facial recognition, and there is no formal legal basis allowing the deployment of facial recognition technology, FRT, in Bosnia. But the physical infrastructure for its potential deployment is expanding.
Djordje Krivokapic, associate professor at the University of Belgrade, warns that this powerful surveillance tool, already the subject of ethical and legal debates around the world, could pose a risk to fundamental rights in a country where institutional oversight remains fragile, laws are patchy, and political divisions run deep.
A Sarajevo-based lawyer, Admir Duranovic, says the biggest problem is the various layers of jurisdiction in Bosnia, a result of its highly complex post-war governance set-up. “We lack an understanding of who is in charge of enforcing those laws,” Duranovic told BIRN.
“Then we reach the issue of the lack of public education on these issues, we also lack public consultations, while the Data Protection Agency, which should be monitoring implementation of these laws, is extremely under-capacity when it comes to human resources and technical capacities,” he added.
Adding to the need for regulation is Bosnia’s EU accession process, which requires it to align its legislation with EU law. This includes: compliance with the newly adopted EU Artificial Intelligence Act, which bans live FRT in public spaces; the indiscriminate scraping of biometric data from online sources and CCTV footage; and the classification of individuals based on sensitive personal traits.
“While we have aligned many of our data protection laws with those in the European Union, and GDPR law will go into force from October, which was one of the EU requirements, we are witnessing selective application of the laws,” Duranovic said.
But cybersecurity expert Softic says that, while recognising the dangers in the unregulated use of FRT, there is potential in deploying this technology under “strictly controlled conditions”, such as locating missing persons, or responding to terrorist threats.
Softic said the key lies in embedding transparency, consent and accountability into the design and deployment process. “A total ban would ignore the potential benefits, but unregulated use opens the door to mass surveillance, discrimination, and violations of basic human rights,” he argued.
At present, Bosnia lacks specific legislation that allows or regulates the use of FRT in public spaces. Both of the country’s entities, the Federation and Republika Srpska, and the Brcko District, have their own regulation regarding the use of technologies in public and private surveillance.
Bosnia’s Personal Data Protection Agency in 2021 explicitly warned that using FRT without a clear legal foundation is illegal under current laws, especially since biometric data falls under sensitive personal information, requiring heightened protection.
Freedom of information requests submitted to police authorities in Republika Srpska, the Federation, the Federation cantons of Sarajevo and Tuzla, and Brcko District, prompted official denials about the use of FRT.
However, a report, Surveillance and Censorship in the Western Balkans, published in 2025 by BIRN, notes that smart surveillance cameras can easily be upgraded with facial recognition software.
Serbia has already deployed such cameras for mass surveillance without legal grounds, sparking criticism from rights groups and activists. Serbian investigative journalists uncovered the use of FRT in schools, markets, kindergartens and public squares despite the absence of any enabling legal framework.
“On several occasions, the [Serbian] Interior Ministry attempted to initiate procedures to regulate these systems in law, but – owing to pressure from civil society, citizens, the media, and perhaps other factors – this process has been repeatedly postponed,” Bojana Kostic, a human rights and tech researcher from Serbia, told BIRN.
Similarly, Montenegro has reportedly procured biometric surveillance tools for potential use in public spaces. These cases highlight a regional trend: the rapid adoption of advanced surveillance technologies without the adoption of corresponding democratic safeguards.
While police in Bosnia officially deny using facial recognition technology, the authorities have been building the infrastructure capable of enabling it.
Softic insists that the technology itself is not inherently dangerous – “but how it is used, who controls it, and under what conditions, will ultimately determine whether it serves the public good or undermines democratic freedoms”.
Dizdarevic noted that some facial detection cameras already exist in Bosnia, in some prisons and on border crossings.
“When it comes to use of facial recognition cameras in public spaces by the police, despite them recording 24/7, they would still only identify the people who are already registered as breaking the law, have already been processed, or are wanted by police agencies, all by using some 89 points on the face,” he said, adding that those who did not break the law would have nothing to worry about.