Business Digitalization in Serbia — Questions and Answers

Find answers to the most frequently asked questions about electronic delivery notes, electronic archiving, and e-invoicing in Serbia. This content is intended for informational purposes only and is based on regulations in force as of June 2026.

1. Document Management (DMS)

1. What is a DMS (document management system)?

A DMS (Document Management System) is a software for creating, organizing, storing, and finding business documents in one place. Instead of files scattered across computers and inboxes, every document is centralized, searchable, and access-controlled.

2. What is a DMS for, and what problems does it solve?

A DMS tackles scattered documents, time lost to searching, unclear versions, and the risk of data loss. It centralizes documentation, speeds up retrieval, automates approval flows, and ensures the company always knows where each document is.

3. What is the difference between a DMS and ordinary cloud storage (Google Drive, Dropbox)?

Cloud storage only stores files. A DMS adds structure: categories and retention periods, versioning, role-based access control, approval workflows, change tracking, and compliance with archiving rules. A DMS manages a document’s entire lifecycle, not just its storage.

4. Does my company need a DMS?

A DMS makes sense as soon as the number of documents and the people using them grows to the point where search, versions, and access become a problem. It is useful for companies of every size, and especially for those with legal obligations around archiving, e-invoices, and e-delivery notes.

5. How does a DMS help with regulatory compliance?

A DMS automates exactly what the law requires: classifying documents, assigning retention periods, applying a qualified electronic signature, generating the archive book, and tracking every change. This significantly reduces the risk of oversights and penalties during an inspection.

6. What is document workflow automation?

A workflow is a predefined path a document follows through the company — for example, receiving an invoice, reviewing it, approving it, and posting it to the books. A DMS automatically routes the document to the right person, sends reminders, and records each step, speeding up processing and reducing errors.

7. What is document versioning?

Versioning means the DMS keeps every change to a document as a separate version. At any moment you know who changed what and when, and you can revert to an earlier version — removing any confusion over which version is the valid one.

8. How does a DMS keep an audit trail?

A DMS records every action taken on a document — who opened, edited, signed, or deleted it, and when. This trail is tamper-proof and serves as evidence that is especially useful during a tax or regulatory inspection.

9. How is access to each document controlled?

Through role-based permissions. You assign each user or team specific rights (view, edit, sign, delete) for particular document categories, so sensitive documentation stays available only to authorized people.

10. Can a DMS integrate with SEF, ERP, and accounting software?

Yes. A modern DMS connects with SEF (Serbia’s national e-invoicing system), ERP, and accounting software, so invoices, delivery notes, and supporting documents enter the system and are archived automatically, without manual re-entry.

11. Is a DMS the same as electronic archiving?

No, but they are related. Electronic archiving is a legal obligation to store documents reliably. A DMS is the tool that fulfills that obligation and goes further — beyond archiving, it manages the flow, access, and search of documents in day-to-day work.

12. Can I move my existing paper archive into a DMS?

Yes. Existing documentation is scanned and imported into the DMS, where it is classified and assigned retention periods. Keep in mind that, under the regulations, paper originals still remain in paper form — the scanned copy serves for easier work and search.

13. How much does implementing a DMS cost?

The price depends on the number of users, the volume of documents, and the integrations required. Cloud (SaaS) models are usually billed monthly per user, which makes them accessible to small companies too, without a large upfront investment in infrastructure.

14. How long does it take to implement a DMS?

For smaller companies, rolling out a cloud DMS can take anywhere from a few days to a couple of weeks, depending on the volume of existing documentation and the number of integrations. Larger systems with complex workflows call for a longer rollout and staff training.

15. Is the data in a DMS secure?

A reliable DMS uses data encryption, access control, backups, and a record of every action. This often makes documentation more secure than when it is scattered across local computers and shared folders.

16. Where is the data stored — in the cloud or on your own server?

Both models exist. Cloud (SaaS) requires no infrastructure of your own and is easier to maintain, while an on-premise solution keeps the data on the company’s own servers. The choice depends on your security policy, internal rules, and budget.

17. Does a DMS replace accounting software?

No. A DMS manages documents and their flow, while accounting software processes financial data. They work best together — the DMS stores and routes the documents, and the accounting software processes them, with integration between the two.

18. How does a DMS help during an inspection or audit?

A DMS lets you find a requested document in seconds, with a complete record of who changed it and when and a valid electronic signature. That shortens and simplifies the inspection and reduces the risk of penalties for poor record-keeping.

19. Does a DMS support Serbian regulations and work in the Serbian language?

That depends on the solution. For companies in Serbia, it is important to choose a DMS that works in Serbian, follows local rules on archiving and signing, and connects to local systems such as SEF — something global solutions often do not cover.

20. How do I choose a DMS for my company?

Start from your needs: how many documents and users you have, which integrations are essential (SEF, ERP), which legal obligations you need to cover, and which model (cloud or on-premise) suits you. Look for compliance with local regulations, clear access control, and support in your language.

Docloop is a Serbian platform that delivers a custom-built, state-of-the-art DMS solution for every client, regardless of industry or company size. For a free consultation, write to prodaja@docloop.rs or call +381 11 43 50 555.

2. Electronic Delivery Notes

1. What is an electronic delivery note?

An e-delivery note is a digital document that accompanies goods during transport and serves as proof of dispatch and receipt. It replaces the paper delivery note and is exchanged through the state information system linked to SEF (System for electronic invoices), and it must be sent before the goods set off.

2. When do e-delivery notes become mandatory?

From 1 January 2026 they are mandatory for the public sector, for private companies doing business with the public sector, and for everyone trading in excise goods. For all other private-sector entities, the obligation begins on 1 October 2027.

3. Who is required to use e-delivery notes?

The obligation covers all entities that handle goods in transit, as well as carriers transporting on their behalf. For excise goods, every participant must be in the system, even if they are not registered for VAT.

4. Do e-delivery notes apply to services as well?

No. E-delivery notes apply solely to the physical movement of goods. For services, only the electronic invoice through SEF is used.

5. How do I register for the e-delivery note system?

Registration is done through the official web interface that is part of the e-invoicing system (SEF). Companies that already use e-invoices have an advantage, since they work in the same environment.

6. What must an e-delivery note contain?

It must include the type (internal/external), the delivery note number, sender and recipient details, the time and addresses of dispatch and destination, details of the goods and the means of transport, and a unique identification number.

7. When must an e-delivery note be sent?

The sender must send it before the goods physically set off. The carrier must have access to the delivery note during transport and present it in the event of an inspection.

8. How long does the recipient have to accept or reject the delivery note?

The recipient has 8 days from the physical receipt of the goods to review the note and decide whether to accept or reject it. If receipt is not confirmed within 30 days, the delivery note ceases to be valid.

9. What if the internet or the system is down at the moment of dispatch?

The note may be recorded temporarily on paper, with the minimum data defined by the Rulebook. Once the system is back up, the data is subsequently entered electronically.

10. Who oversees the use of e-delivery notes?

Enforcement is carried out by the Tax Administration, the road transport inspectorate, the customs authority, and the market inspectorate. The carrier must be able to present the delivery note during oversight.

11. What are the penalties for non-compliance?

Depending on the violation, fines range from 50,000 to 2,000,000 RSD. The heaviest penalties are for transporting goods without any delivery note at all.

12. Is there a tolerance period?

Yes. During the tolerance period, errors in the data are not penalized. However, that does not mean you can ignore the system — not using e-delivery notes at all is a violation even during the tolerance period.

13. How long must an e-delivery note be kept?

The private sector must keep it for at least 10 years, the public sector permanently. Legal responsibility for storage lies with you, not with the state portal, so keeping your own copy in a DMS or ERP system is recommended.

14. Does a courier or delivery service have to be in the system?

A courier service is treated as a carrier and must have access to the e-delivery note during transport. The sender creates the note, and the courier views it in the designated app.

15. What is the difference between an e-delivery note and an e-invoice?

An e-invoice is a tax and accounting document about a transaction and its payment. An e-delivery note tracks the physical movement of goods and proves dispatch and receipt. Although they use linked infrastructure, they are two different documents.

16. Does a sole trader have to use e-delivery notes?

If they take part in the movement of goods the obligation applies to (for example, excise goods), then yes — regardless of VAT status. For services and activities that do not involve the movement of goods, the obligation does not apply.

17. What is an internal versus an external delivery note?

An external delivery note tracks the movement of goods between two different entities. An internal one tracks the movement of goods within the same company — for example, between warehouses or business units. The type must always be stated on the note.

18. Can I integrate e-delivery notes with my ERP or WMS system?

Yes. The system is designed for automated processing, so notes can be sent and received directly from connected software, without manual entry on the portal.

19. What happens if goods set off without an e-delivery note being sent?

That is a violation carrying the highest penalties, because the carrier has no valid document during an inspection. This is why the note must be sent and available before the goods depart.

20. How should a company prepare for 1 October 2027?

You should establish a routine of sending the note before dispatch, reviewing and accepting incoming notes on time, and archiving reliably. Companies that already use e-invoices and have a DMS make the transition much more easily.

3. Electronic Archiving

1. What is electronic archiving?

Electronic archiving is the classification, sorting, reliable storage, and ensured availability of documents created in electronic form. The goal is for a document to remain legible, unchanged, and accessible throughout the entire prescribed retention period.

2. When did electronic archiving become mandatory in Serbia?

It has been mandatory since 1 January 2024. Documents created in digital form from that date must be archived electronically only — printing out an electronic document is no longer sufficient.

3. Which law governs electronic archiving?

The core regulation is the Law on Archival Material and Archival Activity (Official Gazette of RS 6/2020), together with the accompanying Regulation on technical and technological requirements. The Regulation has been amended several times, most recently during 2026.

4. Who is required to archive electronically and keep an archive book?

The obligation applies to all legal entities and sole traders whose work generates documentary material. It does not depend on company size — it applies even to the smallest sole traders.

5. What is an archive book ?

The archive book is a legally prescribed register of all documentation created in a single calendar year, in both paper and electronic form. It is kept chronologically and lists document categories, retention periods, and disposal instructions.

6. By when must the archive book be submitted?

A transcript of the archive book for the previous year is submitted to the competent public archive by 30 April of the current year, according to the legal entity’s registered seat.

7. How long must documents be kept?

The period depends on the type of document. Most business and financial documentation is kept for at least 10 years, employment-related documentation for up to 50 years, while permanent archival material is handed over to the competent archive after 30 years.

8. Does an electronically archived document need an electronic signature?

Yes. Documents archived electronically must carry a qualified electronic signature or seal and be in a format suitable for long-term storage, such as PDF/A, TIFF, PNG, or JPEG.

9. Do I have to scan and electronically archive paper documents?

No. A document created on paper is still kept in paper form — scanning only creates a copy, while the original remains the paper one. Electronic archiving applies to documents created in electronic form.

10. Which general acts must a company adopt?

Most commonly: a rulebook on office operations, an act on recording, classifying, and archiving, an act on electronic documents, a decision appointing a responsible person, and a list of archival material categories with retention periods.

11. What is the list of archival material categories?

It is an inventory of the types of documents a company creates, with the prescribed retention period for each category. This list must be approved by the competent public archive.

12. What are the penalties for non-compliance?

For legal entities, fines reach up to 2,000,000 RSD, and for responsible persons from 5,000 to 150,000 RSD. They apply, for example, to failure to submit the archive book and other lapses in procedure.

13. How often should electronic archiving be carried out?

The law currently does not explicitly prescribe whether archiving is done daily, weekly, monthly, or annually. The professional recommendation is to do it gradually and in good time, before the qualified signature on a document expires.

14. Are e-invoices in SEF already archived?

SEF’s role in archiving is not precisely defined. Since invoices in SEF are standardized (XML format), part of the profession considers the reliable-storage obligation thereby fulfilled, but responsibility for reconstructing a document’s complete trail still rests with the company.

15. What is the disposal (write-off) of documentation?

Disposal is the setting aside, for destruction, of documents whose retention period has expired — one year after the period expires. The procedure must be recorded and approved by the responsible person.

16. What is the difference between archival material and documentary material?

Documentary material is all the documentation created. Archival material is the portion that has lasting significance, is kept permanently, and after a certain period is handed over to the competent archive.

17. Does a sole trader pay a fine for not keeping an archive book?

The penalty provisions are aimed primarily at legal entities and responsible persons. Even so, sole traders also have the obligation to keep one, so orderly archiving is advisable regardless of the level of sanctions.

18. Must a company use paid archiving software?

Not necessarily. A company may reliably store permanently kept documents electronically on its own, or engage a provider of qualified electronic storage services. A software solution makes keeping the book and staying compliant considerably easier.

19. Does the inspectorate announce an archiving inspection?

Not necessarily. An inspection can be unscheduled, without prior notice, so it is important that documentation is always orderly and accessible.

20. How does a DMS help with electronic archiving?

A DMS automates classification, the assignment of retention periods, signing, and generating the archive book, tracks every change, and stores documents in the prescribed format — reducing the risk of penalties during an inspection.

4. Electronic Invoices

1. What is an electronic invoice?

An e-invoice is an invoice issued, sent, and received in a structured digital format through the state System of Electronic Invoices (SEF). Unlike a PDF or paper invoice, it has a prescribed structure and legal effect, and it is exchanged exclusively through SEF.

2. What is SEF?

SEF is the System of Electronic Invoices, a state platform run by the Ministry of Finance through which electronic invoices are issued, sent, received, and recorded. Access is via a qualified certificate or an eID account.

3. Who is required to issue e-invoices?

The obligation covers VAT payers, the public sector, and entities doing business with the public sector, as well as companies in business-to-business (B2B) transactions. It does not apply to private individuals who are not registered sole traders.

4. Is retail covered?

Retail is generally not covered, except for sales to public institutions or to corporate card holders. In those cases, an electronic invoice is issued.

5. By when has full application of the Law been postponed?

The deadline for full application of certain provisions has been extended to 31 December 2026, giving companies extra time to align their systems and procedures.

6. How does a company register for SEF?

Access is obtained on the efaktura.gov.rs portal using a qualified electronic certificate or an eID account. Companies with higher volumes usually integrate their accounting or ERP software with SEF.

7. Can I issue invoices manually on the portal?

Yes. The portal allows manual issuing, which is sufficient for micro-entities with a small number of documents. Higher volumes are usually handled by integrating software with SEF.

8. What is the recording of the VAT calculation in SEF?

It is the obligation to enter the calculated VAT into SEF. The deadline for recording is 10 days after the end of the tax period. This record does not remove the obligation to file the regular VAT return.

9. How long are e-invoices kept?

The public sector keeps them permanently, and the private sector for at least 10 years from the end of the year in which the invoice was issued. Storage may also be entrusted to an authorized information intermediary.

10. What are the penalties for non-compliance?

Fines range from 200,000 to 2,000,000 RSD — for example, for failing to issue an e-invoice, failing to record VAT, improper use of the system, or failing to store invoices in accordance with the law.

11. What if I make an error in recording VAT?

If you spot and correct the error before oversight begins, under the new rules it is not treated as a violation. This is why it is useful to have a routine of internal checks before filing the return.

12. What is eVAT (e-PDV)?

eVAT is a system in which the Tax Administration pre-fills the VAT return based on data from SEF. Partial pre-filling began in 2026, while full application applies to tax periods after 31 December 2026.

13. How do I prepare my company for eVAT?

You need to align the data in SEF with your bookkeeping and ensure all invoices are accurately recorded and archived. Once eVAT goes live, any discrepancy between SEF and your records will be immediately visible.

14. What is the Central Invoice Registry (CRF)?

The CRF is a registry in which invoices to public-funds beneficiaries are recorded. It enables tracking of status and due dates, and it introduces clear statutory payment deadlines (45 or 60 days).

15. Do internal invoices go through SEF?

Yes. Under the amendments applying from April 2026, certain internal invoices that were previously kept outside the system are now issued through SEF.

16. Can I entrust the storage of invoices to someone else?

Yes. Storage may be entrusted to an authorized information intermediary. If the intermediary ceases operations, the documents are transferred to the Central Information Intermediary to ensure continuity of storage.

17. Is there a public list of e-invoice obligors?

A public list of system users with their tax ID (PIB) numbers has been announced, maintained through the Central Information Intermediary, to make it easier and faster to check business partners.

18. What technical limitations should I be aware of?

When registering in the CRF, the invoice number is limited (for example, to 22 characters), Cyrillic is not supported, and the system works to two decimal places. It is worth taking these limits into account when integrating software.

19. Is the e-invoice the only valid document?

Yes. Where there is an obligation to issue an e-invoice, it is the only legally valid document for that transaction — a parallel paper or PDF invoice does not have the same status.

20. How do e-invoices, e-delivery notes, and e-archiving form a whole?

Together they build a complete digital trail: the e-invoice covers the transaction and VAT, the e-delivery note the physical movement of goods, and e-archiving the reliable long-term storage of all these documents in compliance with the law.

Note: This content reflects the regulations in force as of June 2026. Deadlines, penalty amounts, and obligations are subject to change. For more information, you can call Docloop on +381 11 43 50 555 or write to docloop.office@docloop.rs.

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