While much of the business community was focused on the implementation of e-Delivery Notes (eOtpremnice) and the end of the grace period, another important regulatory change went largely unnoticed. The new Rulebook on the Central Invoice Register was published in the Official Gazette of the Republic of Serbia, No. 45/2026, and entered into force on July 1, 2026.
If your company supplies goods or provides services to government authorities, local self-government units, public enterprises, public institutions, or any other public sector entity, these changes affect you directly. Not because they introduce additional administrative work, but because they change how the registration and payment status of your invoices is monitored.
What Is the Central Invoice Register?
The Central Invoice Register (CIR) is established and maintained by the Ministry of Finance – Treasury Administration through a dedicated information system and its accompanying web application.
The Register records data on electronic invoices issued in commercial transactions where the debtor is a public sector entity, including transactions between public sector entities themselves.
Within this framework, your company is the creditor, while the public institution purchasing your goods or services is the debtor. These legal terms are used consistently throughout the Rulebook and are important to understand because they determine the rights and permissions each party has within the system.
Invoice registration is not performed manually. Instead, the CIR automatically retrieves relevant data from the electronic invoice submitted through the Electronic Invoicing System (SEF) and assigns each record a unique identification number. This identifier later becomes essential because it is used as the payment reference number when the invoice is settled.
What Changed on July 1?
Shortly before the Rulebook became applicable, the Ministry of Finance announced that, starting on July 1, all electronic invoices issued in commercial transactions where the recipient is a public sector entity must be registered in the Central Invoice Register, regardless of the specific category of public funds beneficiary involved.
This is the key change.
Previously, there had been uncertainty in practice regarding whether certain categories of public funds beneficiaries were subject to mandatory registration. That distinction no longer exists. If the invoice recipient is a public sector entity, the invoice must be registered in the CIR.
For reference, a public sector entity includes organizations that belong to the government sector under Serbia’s Budget System Law, as well as public enterprises and companies majority-owned by the Republic of Serbia, regardless of whether they formally fall within the government sector classification. In other words, the scope is broader than many businesses assume.
User Roles and Permissions
The Rulebook distinguishes between two user roles within the system: Administrator and Local User. This distinction is more than a formality.
An Administrator can:
- create and deactivate user accounts;
- view account details;
- review registered invoices;
- export invoice records;
- assign invoices; and
- for creditors, cancel invoice registrations.
A Local User has a narrower set of permissions. Local Users may review and export invoices and assign them, but the available actions then differ depending on the party involved.
For creditors (suppliers), Local Users may amend recorded amounts and cancel invoice registrations.
For debtors (public sector entities), the complaint (reclamation) procedure is available instead.
In practical terms, this means that if an invoice has been incorrectly registered, the formal complaint mechanism is not available to the supplier. Your primary safeguard is ensuring the accuracy of the invoice before it is submitted through the Electronic Invoicing System and, where legally justified, promptly correcting the recorded amount or cancelling the registration.
Payments Now Include Mandatory Reference Data
This change directly affects invoice settlement.
When making payments arising from commercial transactions involving the supply of goods or services for consideration—including construction works, investment projects, and utility services—public sector entities are now required to include two mandatory elements in the payment order.
The first is the appropriate payment code from the range 220–226.
The second is the payment reference number, which is the electronic invoice number assigned by the Central Invoice Register.
For suppliers, this means payments will no longer appear as unidentified bank transfers that accounting teams must manually reconcile with outstanding invoices. Instead, every payment carries a unique identifier linked directly to a specific invoice record in the Register. When applied consistently, this should significantly simplify the reconciliation of receivables from public sector customers.
Three-Business-Day Reporting Deadline
Public sector entities that make payments through bank accounts maintained with commercial banks must record payment information in the Central Invoice Register within three business days of settling the financial obligation.
For suppliers, the practical benefit is greater transparency. The payment status in the Register should be updated within a few days rather than several weeks, providing a much more accurate picture of which invoices have been paid and which remain outstanding—based on a centralized official source rather than follow-up phone calls with customers.
Complaints Are Recorded Separately
If, after accepting an electronic invoice, a public sector entity determines that it has not been correctly recorded in the Register, it must submit information corresponding to the appropriate complaint category in accordance with the technical instructions issued by the Treasury Administration.
Importantly, the CIR maintains a separate register of disputed (complained-about) invoices specifically for supervisory purposes.
In other words, registration errors are not simply corrected and forgotten. They are formally recorded in a centralized register and remain visible to supervisory authorities.
For suppliers, this provides yet another reason to ensure invoice data is accurate before submission. Correcting mistakes after registration is invariably more time-consuming than entering the correct information from the outset.
What the Central Invoice Register Is Not
It is equally important to understand what the CIR does not do.
The Central Invoice Register is designed to record invoice registration, payment status, and settlement relating to public sector transactions. It is not your accounting archive and does not replace your statutory obligation to retain accounting documentation.
The responsibility for storing electronic invoices and supporting documentation remains with your company, in accordance with applicable Serbian tax and accounting regulations.
Even if you can verify an invoice’s status in the Register during an audit, you must still be able to reconstruct the complete document trail on your side—including the original invoice, proof of delivery, and any supporting documentation. Failure to do so remains your responsibility.
What Should You Do Now?
First, verify who within your organization has access to the Central Invoice Register and which permissions they hold. If the designated administrator has changed roles or is absent for an extended period, this should be addressed before it becomes a critical issue.
Second, establish a routine for monitoring invoice statuses in the Register, particularly for high-value invoices and those approaching their contractual payment deadline. Many payment issues can be resolved more quickly simply by identifying an unexpected status at an early stage.
Third, if your company uses its own ERP or information system, test the integration. Registration of electronic invoices in the CIR can be tested within the DEMO environment of the Electronic Invoicing System, both through the user interface and via the application programming interface (API).
Finally, update your internal procedures. Clearly define who is responsible for monitoring invoice statuses, how frequently reviews should be performed, and what actions should be taken when an invoice has not been registered or its recorded status does not reflect reality.
How Docloop Helps
Docloop is the first information intermediary licensed by the Serbian Ministry of Finance, serving more than 4,800 active clients and over 220,000 indirect users.
Through our mojDMS platform, we connect your business with Serbia’s government systems, allowing electronic document exchange to take place without manual processing or repetitive status checks.
Our integration supports more than 220 ERP systems, including SAP, Infosoft, and Microsoft Dynamics NAV (Navision). This means the data used to generate electronic invoices flows directly from your ERP system, eliminating manual data entry and reducing the risk of errors that may later result in disputed invoice registrations.
Our clients include Zepter, Siemens, Würth, Swisslion, MaxBet, AbelaPharm, and Prvi Partizan.
If you would like to assess whether your company is fully compliant with the new public sector invoicing requirements—or learn how to streamline your document workflow to improve payment visibility—we invite you to schedule a free consultation.
Email us at prodaja@docloop.rs or call +381 11 43 50 555.
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