Business Digitalization in Serbia — Questions and Answers

1. Electronic Delivery Notes (e-Delivery Notes)

1. What is an electronic delivery note (e-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 a state information system connected to the SEF, 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?

All entities that handle goods in transit are required to use them, as are carriers transporting goods on their behalf. For excise goods, all participants must be in the system, even if they are not VAT-registered.

4. Do e-delivery notes also apply to services?

No. E-delivery notes apply exclusively to the physical movement of goods. For services, only the electronic invoice through the SEF is still 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 electronic invoicing system (SEF). Companies that already use e-invoices have an advantage because they operate in the same environment.

6. What must an e-delivery note contain?

It must contain: the type (internal/external), the delivery note number, details of the sender and recipient, the time and addresses of dispatch and destination, details of the goods and the means of transport, as well as 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 much time does the recipient have to accept or reject a delivery note?

The recipient has 8 days from the physical receipt of the goods to check the delivery 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 goes down or the system is unavailable at the time of dispatch?

Temporary recording of the delivery note in paper form is provided for, with the minimum data defined by the Rulebook. Once the system recovers, the data is subsequently entered electronically.

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

Application is overseen by the Tax Administration, the road transport inspectorate, the customs administration, and the market inspectorate. The carrier must be able to present the delivery note during supervision.

11. What are the penalties for non-compliance?

Depending on the offence, penalties range from 50,000 to 2,000,000 RSD. The most severe penalties are provided 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 penalised. However, that does not mean you can ignore the system, completely failing to use e-delivery notes is an offence even during the tolerance period.

13. How long is an e-delivery note kept?

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

14. Must a courier/delivery service 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 delivery note, and the courier views it in the designated application.

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

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

16. Must a sole trader use e-delivery notes?

If they take part in the movement of goods to which the obligation applies (for example excise goods), then yes, regardless of VAT status. For services and activities without movement of goods, the obligation does not apply.

17. What is an internal and what is 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 be stated in the delivery note.

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

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

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

That is an offence with the highest penalties, because during an inspection the carrier has no valid document. That is why the delivery note must be sent and available before the goods depart.

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

It should establish a routine of sending the delivery note before dispatch, checking and accepting received delivery notes in good time, and reliable archiving. Companies that already use e-invoices and have a DMS make the transition far more easily.

 

 

 

 

2. Electronic Archiving (e-Archiving)

1. What is electronic archiving?

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

2. Since when has electronic archiving been mandatory in Serbia?

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

3. Which law governs electronic archiving?

The basic 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 contains document categories, retention periods, and instructions for disposal.

6. By when must the archive book be submitted?

A copy 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 registered seat of the legal entity.

7. How long must documents be retained?

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

8. Must an electronically archived document have an electronic signature?

Yes. Documents that are archived electronically must bear a qualified electronic signature or seal and be in a format suitable for long-term retention, 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 a list of the types of documents a company creates, with a prescribed retention period for each category. Approval from the competent public archive is required for this list.

12. What are the penalties for non-compliance?

For legal entities, fines go up to 2,000,000 RSD, and for responsible persons from 5,000 to 150,000 RSD. They apply, for example, to failing to submit the archive book and other procedural omissions.

13. How often should electronic archiving be carried out?

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

14. Are e-invoices in the SEF already archived?

The SEF’s role in archiving is not precisely defined. Since invoices in the SEF are standardised (XML format), part of the profession considers the reliable-retention obligation thereby fulfilled, but responsibility for reconstructing the complete document flow remains with the company.

15. What is the disposal of documentation?

Disposal is the separating out of documents whose retention period has expired for the purpose of destruction, carried out 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 the entire body of documentation created. Archival material is the portion that has permanent 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 primarily aimed at legal entities and responsible persons. Even so, sole traders also have an obligation to keep one, so proper archiving is advisable regardless of the level of sanctions.

18. Must a company use paid software for archiving?

Not necessarily. A company can reliably keep permanently retained documents electronically itself, or engage a provider of qualified electronic retention services. A software solution greatly simplifies keeping the book and compliance.

19. Does the inspectorate announce archiving inspections?

Not necessarily. An inspection may be unscheduled, without prior notice, so it is important that documentation is constantly tidy and available.

20. How does a DMS help with electronic archiving?

A DMS automates classification, the assignment of retention periods, signing, and the creation of the archive book, keeps a trail of every change, and stores documents in the prescribed format, which reduces the risk of penalties during an inspection.

 

 

 

 

3. Electronic Invoices (e-Invoices)

1. What is an electronic invoice (e-invoice)?

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

2. What is the SEF?

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

3. Who is required to issue e-invoices?

VAT payers, the public sector, and entities doing business with the public sector are required to, as are companies in mutual (B2B) trade. The obligation does not apply to individuals who are not registered sole traders.

4. Is retail covered?

Retail is generally not covered, except in the case of sales to public institutions or to holders of corporate cards. In those cases an electronic invoice is issued.

5. Until 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 additional time to align their systems and procedures.

6. How does a company register for the SEF?

Access is gained on the efaktura.gov.rs portal using a qualified electronic certificate or an eID account. Companies with a larger volume of business usually integrate their accounting or ERP software with the 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. Larger volumes are usually handled by integrating software with the SEF.

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

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

9. How long are e-invoices retained?

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. Retention may also be entrusted to an authorised 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 not retaining invoices in accordance with the law.

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

If you notice and correct the error before supervision begins, under the new rules it is not considered an offence. That is why it is useful to have a routine of internal checks before submitting 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 the SEF. Partial pre-filling began in 2026, and full application applies to tax periods after 31 December 2026.

13. How do I prepare my company for eVAT?

You should align the data in the SEF with the accounting records and ensure that all invoices are accurately recorded and archived. Once eVAT is up and running, any discrepancy between the SEF and the records will be immediately visible.

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

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

15. Do internal invoices go through the SEF?

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

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

Yes. Retention may be entrusted to an authorised information intermediary. If the intermediary ceases operations, the documents are transferred to the Central Information Intermediary to ensure continuity of retention.

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

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

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 wise to take these limitations 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 the e-invoice, e-delivery note, 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 retention of all these documents in accordance with the law.

Note: The content reflects regulations in force as of June 2026. Deadlines, fine amounts, and obligations are subject to change. For specific situations, consult official sources or a professional.