Briefing document & Podcast: Serbia – E-Invoicing, E-Reporting, E-Transport

SUMMARY

Executive Summary:

Serbia is implementing a comprehensive digital fiscal framework comprising mandatory e-invoicing, real-time e-reporting, and e-transport systems. The overarching goal is to reduce tax evasion, streamline compliance, and modernize tax administration. E-invoicing is fully implemented for B2B and B2G transactions. E-reporting is integrated with e-invoicing and fiscal systems. E-transport is being rolled out. All these systems leverage a central platform, SEF (Sistem e-Faktura). Compliance is enforced through significant financial penalties.

1. E-Invoicing (Sistem e-Faktura):

• Overview: Serbia’s Law on Electronic Invoicing established SEF, a centralized platform managed by the Ministry of Finance.
  • “SEF, or Sistem e-Faktura, is Serbia’s centralized e-invoicing platform managed by the Ministry of Finance. Its primary purpose is to facilitate the electronic issuance, exchange, and storage of invoices, ensuring authenticity and integrity while streamlining tax reporting and reducing tax evasion.”
• Timeline:May 1, 2022: Mandatory for B2G invoices.
  • July 1, 2022: Mandatory for G2B invoices.
  • January 1, 2023: Mandatory for B2B invoices.
• Scope: Covers B2G, G2B, and B2B invoices. Not mandated for B2C sales (handled via fiscalization), but if a VAT-registered business chooses to issue an invoice to a natural person, it must comply with e-invoicing requirements.
  • Taxable Persons:All VAT-registered persons in Serbia (domestic and foreign with Serbian VAT registration).
  • Public sector entities.
  • Exemptions exist for small entities under the VAT threshold or flat-rate VAT payers not in the VAT system.
  • Data and Format:Standardized XML format using UBL 2.1 schema and EU EN 16931 standard (CIUS format). PEPPOL BIS 3.0 is also supported.
  • Mandatory content includes seller and buyer details (name, address, TIN/PIB), unique invoice number, date of supply, description of goods/services, VAT information, and other legally required fields. The VAT status of the issuer is also a requirement.
  • E-invoices must be signed with a qualified electronic signature.
• Transmission: Uses a “clearance model” where all invoices must pass through SEF before being deemed legally valid.
  • “The ‘clearance model’ means that all e-invoices must be submitted to and validated by the central government’s SEF platform before being considered legally valid. The system checks compliance and makes the invoice available to the buyer, which makes SEF a central clearinghouse.”
  • Suppliers submit e-invoices in real-time via SEF portal or API.
  • Buyers are notified and can accept or reject invoices electronically. Public-sector buyers have 15 days to accept or reject.
• Archiving: E-invoices must be stored electronically for at least 10 years. SEF stores public-sector invoices permanently.
• Penalties for Non-Compliance: Substantial fines.
  • Failure to issue a required e-invoice or issuing it outside SEF: RSD 200,000 to RSD 2,000,000 (approximately €1,700 to €17,000).
  • Failure to comply with system usage requirements or maintain electronic VAT records: up to RSD 2,000,000.
• Future Developments: Amendments to the law introduce new reporting requirements and content changes. Some enhanced features postponed to the end of 2026.

2. E-Reporting (Real-Time VAT Reporting):

• Overview: Electronic reporting of transactional data and VAT information to tax authorities in real-time, primarily via SEF. Complements e-invoicing. Captures transactions not covered by e-invoices.
  • “E-reporting in Serbia involves the real-time electronic reporting of transactional data and VAT information to the tax authorities, primarily through the SEF platform. E-invoices submitted via SEF are automatically reported, while B2C sales data from fiscal cash registers is aggregated and reported into the SEF system. All taxable transactions are captured with E-reporting.”
• Scope: All transactions subject to VAT.
  • E-invoices submitted through SEF are automatically reported.
  • B2C sales: Aggregate data from fiscal cash registers is reported into SEF. The Law on Fiscalization mandates every retail sale be reported in real time.
  • Other transactions (e.g., VAT on import, reverse-charge self-invoices, first sale of new real estate) must also be recorded.
• Timeline:Mid-2022: Real-time reporting of invoice data (B2B, B2G) in SEF and POS cash receipts via the fiscal system.
  • January 1, 2023: Comprehensive continuous transaction reporting framework in place.
  • Mid-2023: Taxpayers required to use SEF for electronic VAT ledgers.
  • October 1, 2024: Obligation to electronically record input VAT in SEF.
  • January 1, 2025: New e-reporting rules, updated procedures.
  • January 1, 2025: Deadline for finalizing electronic VAT records extended to the 12th of the month following the tax period.
  • From January 2026: Preliminary (pre-filled) VAT returns will be available in SEF.
• Requirements and Data:Electronic VAT records (output VAT and input VAT) must be maintained in SEF.
  • Each e-invoice issued/received is automatically recorded.
  • Total daily/periodic gross sales and VAT from fiscal cash registers must be recorded for B2C sales.
  • Integration with customs data for recording import VAT.
  • Declaration of VAT status in SEF.
• Deadlines:Real-time for individual transactions (invoices and fiscal receipts).
  • Periodic deadline for VAT record completion: 12th of the month following the tax period.
• Penalties for Non-Compliance: Fines up to RSD 2,000,000 for failure to electronically record VAT or declare VAT status.
  • Corrections are allowed without penalty if made before an audit.

3. E-Transport (Electronic Delivery Notes):

• Overview: Mandate for electronic transport documents (“e-Otpremnica”), digitizing shipping documents.
  • Implementation Timeline:Law passed: November 27, 2024, effective Dec 6, 2024.
  • Phase 1 (January 1, 2026): Mandatory for public sector-related goods transport and excise goods in B2B transactions. Carriers involved in these transactions must also be registered.
• Phase 2 (October 1, 2027): Extends to all B2B goods transports domestically.
  • Scope: Movement of goods within Serbia for taxable persons.
    • Business-to-Government (B2G) movements.
    • Business-to-Business (B2B) movements (initially excise goods, then all goods by 2027).
    • Public sector entities and private sector entities.
    • Transporters/Carriers.
  • Process and Data:E-delivery note must be issued before transportation begins.
    • Required information includes shipment ID, sender/receiver details, goods description, transport details, timestamps, and digital signatures.
    • Format: XML conforming to UBL 2.1.
    • Centralized e-Delivery Note platform (integrated with SEF).
    • Validation by the platform.
  • Recipient must confirm receipt of the shipment through the system (electronic receipt confirmation).
  • Exceptions: Goods transported via utility networks, retail goods under specific regimes, military or sensitive goods, cross-border transit.
  • Penalties for Non-Compliance: Fines ranging from approximately €430 up to €17,100 (RSD 50,000 to RSD 2,000,000). Shipments without proper documentation can be delayed or stopped.

4. Pre-Filled VAT Returns:

• Serbia is moving towards pre-populated VAT returns using SEF data.
• Starting in 2026, a “preliminary tax return” will be available in the system for each taxpayer, generated automatically based on sales and purchase data recorded in SEF. Taxpayers will then review, adjust, and submit.
• As of now, taxpayers still file VAT returns manually.

5. Key Government Resources:

• Law on Electronic Invoicing (Official Gazette RS No. 44/2021 and 129/2021).
• Law on Electronic Delivery Notes (Official Gazette RS No. 94/2024).
• eFaktura portal (efaktura.gov.rs).

Potential Benefits and Challenges for Businesses:

• Benefits: Streamlined compliance, reduced administrative burden (eventually with pre-filled VAT returns), increased transparency, reduced tax evasion.
• Challenges: Initial implementation costs, need for staff training, potential technical issues, and adapting to new deadlines and procedures.

INDEPTH ANALYSIS

• Implementation Timeline (Past–Present):
  • May 1, 2022 (Phase 1): Mandatory e-invoicing for B2G – all suppliers issuing invoices to public sector entities must do so via the SEF platform (paper invoices no longer accepted). Public entities had to be able to receive/store e-invoices from this date. [cleartax.com]
  • July 1, 2022 (Phase 2): G2B e-invoicing – government and public sector bodies must issue invoices electronically to businesses, and businesses must be capable of receiving them. [cleartax.com]
  • January 1, 2023 (Phase 3): B2B e-invoicing became mandatory for all transactions between VAT-registered businesses. This completed the rollout – electronic invoices are now required for all B2B, B2G, and G2B invoices in Serbia. (Consumer invoices/receipts are handled under fiscalization, see E-Reporting below.) [cleartax.com]
  • Future Developments: Amendments to the e-invoicing law were adopted on Nov 27, 2024 (Official Gazette RS No. 116/2023) with effect from Dec 15, 2024 and Jan 1, 2025. These introduce new reporting requirements (detailed under E-Reporting) and some content changes effective in 2025–2026. Notably, certain enhanced features (additional invoice content, expanded record-keeping rules, etc.) have been postponed to end of 2026 to give businesses more time to adapt. [fonoa.com] [vatcalc.com], [vatcalc.com]
• Transactions in Scope: The e-invoicing mandate covers Business-to-Government (B2G), Government-to-Business (G2B), and Business-to-Business (B2B) invoices. In practice this means:
  • All invoices issued to or by public sector entities (B2G and G2B) must be electronic. [cleartax.com]
  • All invoices between two VAT-registered private entities (B2B) must be electronic. [cleartax.com]
  • B2C transactions: Electronic invoicing is not mandated for sales to consumers, since retail sales to individuals are covered by Serbia’s fiscal cash register system (with receipts reported electronically via fiscalization). Instead of individual e-invoices for B2C, businesses must report aggregate retail sales data through the e-reporting system (see E-Reporting). However, if a VAT-registered business does issue an invoice to a natural person by choice, it would also need to comply with e-invoice requirements. [pwc.rs]
• Taxable Persons in Scope: All VAT-registered persons in Serbia are required to use the e-invoicing system for in-scope transactions. This includes: [cleartax.com]
  • Domestic businesses that are registered for VAT in Serbia (including companies and entrepreneurs).
  • Foreign entities doing business in Serbia if they are VAT-registered or have a fiscal representative in Serbia. Non-resident companies with a Serbian VAT number must comply with e-invoicing for their Serbian operations. [cleartax.com], [vatcalc.com]
  • Public sector entities (central and local government, public institutions) must use SEF for sending, receiving, and storing invoices. [cleartax.com]
  • Exemptions: Small entities under Serbia’s VAT threshold or flat-rate VAT payers not in the VAT system are not obliged to issue e-invoices (since they are not VAT-liable), and entities not dealing with the public sector can opt out if outside VAT scope. However, even non-mandated taxpayers may join SEF voluntarily. Public sector suppliers that are flat-rate (non-VAT) taxpayers are exempt from mandatory e-invoicing by law, though they can use it voluntarily. [cleartax.com]
• Data and Format Requirements: Serbian e-invoices must be issued in a standardized electronic format (XML) that conforms to the UBL 2.1 schema and the EU EN 16931 standard (CIUS format). Key technical and content requirements: [cleartax.com], [cleartax.com]
  • Format: The official format is UBL 2.1 XML, aligned with the European normative standard for e-invoices. Serbia’s system uses a national standard (SRBEFN) based on EN 16931, and also supports PEPPOL BIS 3.0 for interoperability. Each invoice is a structured XML file transmitted via the SEF platform. [cleartax.com]
  • Mandatory content: The Law on E-Invoicing defines an e-invoice as an electronic document containing all information required by tax law, with authenticity and integrity ensured. Every e-invoice must include all legally required fields, such as: [cleartax.com]
    • Seller’s and buyer’s full name, address, and Tax Identification Number (PIB/TIN). [cleartax.com]
    • Unique invoice number and invoice date. [vatcalc.com]
    • Date of supply (if different from invoice date). [vatcalc.com]
    • Description of goods/services, unit measures, quantity, and unit price for each line item. [vatcalc.com]
    • Net amount, applicable VAT rate for each item, VAT amount per rate, and total invoice amount with VAT. [vatcalc.com]
    • Indications of any VAT exemptions or reverse-charge if applicable (using codes per the standard). [vatcalc.com]
    • Buyer’s public sector ID (if the buyer is a public entity, JBKJS code) and seller’s bank account details. [vatcalc.com]
    • VAT status of the issuer (a new requirement in the amended law – whether the issuer is VAT-registered and their VAT period frequency). [fonoa.com]
  • Electronic signature: E-invoices must be signed with a qualified electronic signature or sent through a secure authenticated channel. This guarantees the authenticity of origin. Companies typically obtain digital certificates for signing invoices on the platform. [cleartax.com]
  • Attachments: The system permits up to 3 PDF attachments (e.g. purchase orders, contracts) totaling up to 75 MB to be sent along with the e-invoice if needed. [cleartax.com]
  • Validation: The SEF platform automatically validates each invoice’s format and data upon submission. Only invoices that pass validation are delivered to the recipient and considered issued. The tax authority (Central Information Intermediary) will accept or reject the e-invoice within 15 days of submission if there are issues. (In practice, most invoices are validated in real-time; a 15-day window is a legal maximum for any rejection by authorities.) [complyance.io]
• Transmission Process & Deadlines: Serbia uses a clearance model – all invoices must transit through the central government platform before they are deemed legally valid. Key process steps and timing: [cleartax.com]
  • Invoice issuance and clearance: Suppliers must submit e-invoices electronically in real-time via the SEF portal or API. In practice, an invoice should be entered into SEF at the time of issuance. The system then clears the invoice: it checks compliance and makes it available to the buyer. The buyer is notified through the system. (If the buyer is a public entity, they are required to acknowledge receipt; private buyers may also confirm or can implicitly accept by not disputing.)
  • Delivery to buyer: Once cleared, the e-invoice is delivered electronically to the buyer’s SEF account. The buyer can download or integrate it into their ERP. Public-sector buyers are obliged to formally accept or reject invoices within 15 days in SEF. For B2B, the platform also allows buyers to confirm receipt and either accept or contest the invoice electronically, though if no action is taken it is considered accepted after 15 days. [complyance.io]
  • Recording of invoice data for VAT: (See E-Reporting below – the data from each e-invoice is automatically recorded in the taxpayer’s electronic VAT ledger in the system, which must be finalized shortly after each tax period.)
  • Archiving: E-invoices must be stored electronically for at least 10 years after the end of the year of issuance for tax control purposes. The SEF platform itself stores all public-sector invoices permanently, and private-sector users can use it as an archive or store copies externally as long as integrity is preserved. [cleartax.com], [complyance.io]
• Penalties for Non-Compliance (E-Invoicing): Failing to comply with e-invoicing obligations can lead to substantial fines under Serbian law. According to the law and recent amendments: [fonoa.com], [comarch.com]
  • A business that fails to issue a required e-invoice, or issues it outside the SEF system, can be fined between RSD 200,000 and RSD 2,000,000 (approximately €1,700 to €17,000). Entrepreneurs (sole traders) face lower fines (e.g. RSD 50k–150k) under the same provisions, and responsible officers within a company can be fined individually (e.g. RSD 50k–150k) for violations. [fonoa.com], [comarch.com]
  • Failure to comply with system usage requirements, such as not registering on the platform or not declaring the company’s VAT status in SEF, is also subject to fines up to RSD 2,000,000. (The amended law requires companies to declare whether they are VAT payers and their filing period in the system; not doing so is an offense.) [fonoa.com], [comarch.com]
  • Failure to maintain the required electronic records of VAT (i.e. not recording output/input VAT in the system as required) can likewise incur penalties up to RSD 2,000,000. [fonoa.com]
  • Unauthorized use of system data (for purposes outside those allowed by law) also carries fines (similarly up to about 2 million RSD). [fonoa.com]
  • These penalties are defined in the Law on Electronic Invoicing and its amendments. Enforcement began in 2023 and has been reinforced in 2025 with stricter penalty provisions, though a grace for error correction is given (see E-Reporting below). In summary, non-compliance can be costly, so businesses are strongly incentivized to use the e-invoice system correctly.

• Scope of E-Reporting: Essentially all transactions subject to VAT must be reported electronically to the tax authority, either on an invoice-by-invoice basis or in aggregate, through one of two channels:
  • Invoices (B2B/B2G/G2B) – All e-invoices submitted through SEF are automatically reported to the authorities as part of the clearance process (the tax authority has the data in real time). No separate VAT report is needed for those, aside from the periodic summary. [complyance.io]
  • Receipts (B2C sales) – Retail transactions with consumers are recorded through Serbia’s fiscal cash register system. Since 2022, Serbia has an upgraded fiscalization system requiring point-of-sale devices to transmit receipt data instantly to the Tax Administration. The Law on Fiscalization (separate from e-invoice law) mandates that every retail sale (B2C) be reported in real time and a fiscal receipt (with a QR code) be issued to the customer. E-Reporting integrates this by requiring businesses to input the aggregate data of these B2C receipts into the SEF system. The 2024 amendments explicitly added an obligation to record aggregate VAT totals for retail sales (where fiscal receipts were issued) into the electronic VAT records in SEF. This ensures even B2C turnover is accounted for in the central system for VAT purposes. [pwc.rs]
  • Other transactions: Certain special transactions (e.g. VAT on import, reverse-charge self-invoices, or first sale of new real estate) also must be recorded. The law specifies that VAT on the first transfer of newly constructed buildings etc. is to be recorded in individual records in SEF as well. [pwc.rs]
  • In summary, by the end of 2023 Serbia achieved full coverage of transactions: B2B and B2G via e-invoice reporting, and cash retail via fiscal device reporting. From 2024, these streams feed into a unified electronic VAT ledger for each taxpayer.
• Timeline of E-Reporting Measures:
  • Initial Launch (2022–2023): Real-time reporting began alongside e-invoicing. Since mid-2022, all invoice data (B2B, B2G) is captured in SEF as invoices are issued, and all POS cash receipts are captured via the fiscal system. Effectively, 2022 marked the start of Serbia’s continuous transaction controls for VAT. [complyance.io], [complyance.io]
  • January 1, 2023: With e-invoicing fully live for B2B, Serbia had in place a comprehensive continuous transaction reporting framework. Every invoice or receipt is reported, enabling cross-checks.
  • Mid-2023: The focus shifted to electronic VAT ledgers (evidencije). Taxpayers were required to use the SEF system to keep records of VAT due and VAT deductions. Initially, the deadline for recording each month’s VAT data was the 15th of the following month.
  • January 1, 2024: A new rule shortened the deadline for electronically recording VAT calculations. Starting in 2024, taxpayers had to finalize the electronic recording of all VAT for a tax period by the 10th of the month following that period. (For example, for January 2024 transactions, all required entries needed to be recorded in SEF by February 10, 2024.) This was intended to speed up reporting and move closer to real-time VAT oversight. [vatcalc.com]
  • October 1, 2024: The obligation to electronically record input VAT (VAT on purchases) in SEF took effect for VAT periods starting on or after this date. (It was initially expected one month earlier but deferred due to technical prep.) From this point, businesses must log their purchase invoices (input VAT) in the SEF system electronically. Notably, if both seller and buyer use SEF for e-invoicing, input VAT is recorded automatically when the invoice flows through the system; but for any purchases not received via SEF, the buyer must enter the data. This closed the loop so that both output VAT and input VAT are tracked electronically. [kpmg.com], [kpmg.com] [kpmg.com]
  • December 15, 2024: Amendments (Law on Amendments to the E-Invoicing Law) became effective, setting the stage for further changes from 2025. [fonoa.com]
  • January 1, 2025: New E-Reporting rules kick in: Per the amended law, for VAT periods in 2025 onward, taxpayers must adhere to updated procedures: declare their VAT status, follow the new 12-day deadline (see below), and handle any new content requirements. [fonoa.com], [fonoa.com]
  • January 1, 2025 – Deadline adjustment: The monthly deadline for finalizing electronic VAT records was slightly relaxed: it was extended from the 10th to the 12th day of the month following the tax period. (This change, effective for 2025 periods, gives two extra days beyond the 10th, likely in response to feedback after the 2024 ten-day rule.) For example, a January 2025 VAT period must be recorded by February 12, 2025. This deadline applies to both sales/output VAT and purchase/input VAT entries. [pwc.rs], [comarch.com]
  • Beyond 2025: Starting with tax periods after Dec 31, 2025, Serbia will introduce a Preliminary (Pre-filled) VAT Return in the system (see “Pre-Filled VAT Returns” below). Also, some new content requirements for e-invoices (Article 7 of the amended law) will apply from 2026, and certain stricter enforcement measures were postponed to end of 2026. [pwc.rs], [comarch.com] [vatcalc.com], [vatcalc.com]
• Requirements and Data to be Reported: Under the e-reporting mandate, businesses must maintain electronic VAT records each tax period through SEF. This effectively replaces or supplements the old paper “VAT books.” Key requirements:
  • Electronic VAT Ledger: Taxpayers have to keep an electronic record of all output VAT and input VAT for each VAT period (month or quarter) in the SEF system. The system segregates individual records (for B2B/B2G invoices and certain specific sales) and aggregate records (for retail sales). Specifically: [fonoa.com], [pwc.rs]
    • Each e-invoice issued is automatically recorded as an output VAT item in the system under the appropriate tax period.
    • Each e-invoice received (from a supplier) is recorded as an input VAT item once the buyer confirms it in their purchase ledger. Starting late 2024, if any purchase invoices are not already in SEF (e.g. imports or invoices from small suppliers), the taxpayer must enter the input VAT data manually or via import so that all inputs are accounted for electronically. [kpmg.com]
    • Retail sales (B2C): Instead of each receipt, the total daily or periodic gross sales and VAT from fiscal cash registers must be recorded. The law explicitly added “obligation to record VAT in aggregate for retail transactions for which a fiscal receipt has been issued”. In practice, this means at the end of a tax period, a business will input a summary of its B2C sales (e.g. total taxable turnover at each VAT rate as per fiscal device reports) into the SEF electronic record. [pwc.rs]
    • VAT on imports and customs: The system is integrated with customs data. Users of SEF can access a “Customs Declaration List” which provides information on imports and goods released into free circulation, so they can easily include import VAT in their records. This data is pulled from customs declarations, allowing import VAT to be recorded electronically without manual entry. [fonoa.com], [pwc.rs]
    • Advance payments and VAT advances: The law also covers recording of any advance VAT (for advance invoices) in the period and provides for correcting those records if needed. [comarch.com], [comarch.com]
    • Period closure: By the 12th of the next month (for monthly filers), the taxpayer should have all relevant sales and purchase data recorded in SEF for the prior month.
  • VAT Status Declaration: Every entity in the system must declare its VAT status in SEF – specifically whether it is a VAT payer and whether it files monthly or quarterly. New registrants must declare status within 5 days of registering in SEF. (If they don’t, the Tax Admin will populate the status based on its data.) This status info is used to determine how the system handles their reporting (e.g. periodicity). [fonoa.com], [comarch.com] [comarch.com]
  • Corrections: The system allows corrections to the electronic VAT records. The amended rules explicitly permit taxpayers to correct mistakes in their electronic VAT entries (output or input) if an error is discovered, without it being considered a violation, provided the correction is made before any tax inspection starts. This encourages taxpayers to fix data proactively. [pwc.rs], [comarch.com]
  • Format & Technical: The data is reported via the same SEF platform, using XML messages. For invoices, the XML invoice suffices. For additional records (like aggregate retail or import entries), the interface allows input or upload in a structured format defined by the Ministry’s technical guidance (the “Internal Technical Instruction” was updated accordingly). Essentially, the entire VAT book is digitized.
• Deadlines for Data Submission:
  • Real-time for individual transactions: All invoice data is transmitted in real time (as invoices are issued or received). Fiscal receipts are also transmitted in real time to tax authorities via cash registers. So individual transaction reporting is instantaneous in 2022–2025.
  • Periodic deadline for VAT record completion: After a VAT period ends (monthly or quarterly), taxpayers must complete the electronic recording of all required data shortly after period-end. Initially this deadline was 10 days after month-end in early 2024, but now it is 12 days after the end of the tax period. For example: [vatcalc.com] [pwc.rs]
    • A monthly VAT payer must finalize entries by the 12th of the next month.
    • A quarterly VAT payer would do so by the 12th of the month following the quarter.
    • If recording after the 10th, the system uses the status as of the 10th for consistency. (This ensures late adjustments still use the proper tax rates/status that were in effect.) [pwc.rs]
  • VAT Return filing: Despite all data being in SEF, taxpayers currently still file periodic VAT returns to the Tax Authority. The due date for filing the VAT return and paying VAT remains the standard (generally 15 days after the end of the month for monthly filers, per the VAT Law). However, with the introduction of the preliminary tax return in SEF (see below), the process is becoming more automated.
• Penalties for Non-Compliance (E-Reporting): The law imposes fines for failures in the electronic reporting and record-keeping obligations, in addition to the e-invoice issuance fines noted earlier. Key penalty provisions (per the Law on E-Invoicing as amended) include:
  • Failure to electronically record VAT or input VAT as required: fines up to RSD 2,000,000 for a company. For example, if a taxpayer does not input their purchase invoices or does not report retail VAT data as required, this is an offense. [fonoa.com], [comarch.com]
  • Failure to declare VAT status (not indicating VAT payer status or period in SEF): fines up to RSD 2,000,000. [fonoa.com]
  • General non-use of the system (e.g. if a company tries to bypass SEF or fails to register): also subject to fines (ranges overlap with above, up to ~2 million RSD). [fonoa.com], [comarch.com]
  • Note: Importantly, the amended rules provide that if errors in VAT records are corrected before an audit, they will not be treated as violations. This grace encourages compliance; in other words, no penalty will apply for an incorrect or missing entry if the taxpayer fixes it proactively prior to enforcement action. [pwc.rs], [comarch.com]
  • Enforcement of these reporting-related penalties started in 2024. Additionally, Serbia’s Tax Administration can remove a taxpayer from the SEF user list for serious non-compliance, and information intermediaries (service providers) can have their licenses revoked for failing to meet obligations. [fonoa.com]
• Pre-Filled VAT Returns: As part of the e-reporting initiative, Serbia is moving toward pre-populated VAT returns using the data in SEF. From January 2026, a “preliminary tax return” (pre-filled VAT return) will be available in the system for each taxpayer. Here’s what is known: [pwc.rs], [comarch.com]
  • The amended law mandates that the e-invoicing system automatically generate a draft VAT return based on all the sales and purchase data recorded in SEF for the tax period. This preliminary declaration will serve to “simplify the process for businesses and tax authorities” by reducing manual input. [comarch.com]
  • This feature is set to apply for periods after Dec 31, 2025 – meaning the first auto-generated returns would be for January 2026 (for monthly filers) or Q1 2026 (for quarterlies). Taxpayers will likely review this pre-filled return and then officially submit it (or correct it if needed) rather than preparing returns from scratch. [pwc.rs]
  • Current status: As of 2025, Serbia does not yet have fully pre-filled VAT returns issued by the tax authority. Taxpayers still must file their VAT returns themselves (albeit using the data from SEF). However, the system is being put in place to enable pre-filled returns, which is a major step towards easing compliance. In short, pre-filled VAT returns are planned (via SEF’s “preliminary tax declaration” functionality), but were not in effect before 2026. [pwc.rs], [comarch.com]

• Implementation Timeline: The e-Transport mandate is being rolled out in phases to allow adaptation:
  • Law Adoption: The law was passed on November 27, 2024 and took effect on Dec 6, 2024. Technical specifications and a demo system were released in 2025 to prepare businesses. [ctlegal.rs], [sovos.com] [sapeinvoice.com]
  • Phase 1 – Effective January 1, 2026: Electronic delivery notes become mandatory for public sector related goods transport and for certain transactions involving excise goods:
    • All public sector entities must issue and receive electronic delivery notes for any movement of goods involving the public sector (this includes government-to-government and B2G deliveries). In practice, any supplier delivering goods to a state body will need to create an e-delivery note, and state entities shipping goods out will do likewise. [edicomgroup.com], [edicomgroup.com]
    • Private companies sending goods to public entities (B2G) must use e-delivery notes from this date as well. [edicomgroup.com]
    • Excise goods in B2B transactions: Notably, the law brings excise product shipments into scope early. From 2026, business-to-business transport of excisable goods (such as fuel, alcohol, tobacco, electricity, etc.) requires e-delivery notes even if both sender and receiver are private companies. This is aimed at high-risk goods to improve tax control on those from day one. (Manufacturers, importers, and distributors of excise goods must comply in 2026). [vatupdate.com], [sapeinvoice.com] [vatupdate.com]
    • Carriers: In this phase, transport carriers involved in the above transactions also must be registered and ready to carry electronic notes (they don’t issue them, but must be able to present them during transit). [ctlegal.rs], [edicomgroup.com]
  • Phase 2 – Effective October 1, 2027: The mandate extends to all B2B goods transports domestically:
    • All private-sector companies transporting goods to other companies (B2B) will be required to issue and receive e-delivery notes for every shipment. This means from Oct 2027, **electronic delivery notes are compulsory for every movement of goods within Serbia’s business sector, with very limited exceptions. [edicomgroup.com], [sapeinvoice.com]
    • Transport operators (logistics providers) in B2B supply chains must also support the system by ensuring the electronic note is available during transport.
  • These deadlines are firmly established in the law. The phased approach (2026 then 2027) gives companies extra time to implement the system for purely private-sector shipments after handling the public-sector and excise goods first. [ctlegal.rs] [sapeinvoice.com]
• Transactions and Entities in Scope: The e-Transport system applies to the movement of goods within Serbia, for taxable persons and certain goods. Specifically:
  • Business-to-Government (B2G) movements: Any shipment of goods from a business to a public sector entity requires an e-delivery note (from 2026). Likewise, government bodies sending goods to businesses (G2B) or to each other (G2G) will use e-notes. [edicomgroup.com]
  • Business-to-Business (B2B) movements: By 2027, all shipments of goods from one company to another within Serbia must be accompanied by an electronic delivery note. In 2026, this requirement is only enforced if the goods are excise products or the sending/receiving party is in the public sector; after Oct 2027 it covers all goods and all sectors. [edicomgroup.com]
  • B2C deliveries: The law does not specifically mandate e-delivery notes for deliveries to end consumers (individuals). In practice, delivery notes are typically used for business transactions. Consumer deliveries (e.g. from an online retailer’s warehouse to a customer) are generally accompanied by a waybill, but it’s not clear that the e-Delivery law forces those to be electronic unless required by other regulations. The focus is on B2B and B2G.
  • Excise goods: As noted, special attention is on excisable goods. Any movement of excise goods between businesses falls under the mandate starting 2026. This means even if it’s two private companies (which normally would have until 2027), if the cargo is, say, fuel or alcohol, an e-note is needed in 2026. [vatupdate.com]
  • Public sector entities: All government units, public institutions, and state-owned companies must use the system when they are senders or recipients of goods. [edicomgroup.com], [ctlegal.rs]
  • Private sector entities: All companies (VAT taxpayers) engaged in the shipment of goods domestically will be subject by 2027, with many (especially those dealing in regulated goods) pulled in by 2026. [ctlegal.rs]
  • Transporters/Carriers: The law explicitly includes transport carriers (logistics operators) as participants. Carriers must ensure during transport that the electronic delivery note is available for inspection (typically by carrying a digital or printed reference to it). They also may need to confirm in the system when goods are delivered if acting on behalf of the supplier/receiver. [ctlegal.rs], [edicomgroup.com]
  • Foreign entities: If a foreign company is involved in domestic Serbian goods movement (e.g. a non-resident supplier storing goods in Serbia and distributing locally via a rep), they would need to comply through their Serbian entity or representative. Cross-border movements under international customs regimes are generally excluded (see exceptions below).
• Process and Data Requirements: The e-Transport system functions similarly to e-invoicing in that it uses a central electronic platform (likely integrated with SEF) to register and approve delivery documents. Key details on process and data:
  • Issuance Before Movement: An electronic delivery note must be issued and registered before the physical transportation of goods begins. The supplier or sender of the goods is responsible for preparing the e-note with all required info and submitting it to the central platform (through a web portal or API) prior to dispatch. This is crucial – it means the digital document must exist in the system at the time of loading the goods. [edicomgroup.com], [sovos.com]
  • Required Information: The e-delivery note (e-otpremnica) is essentially an electronic consignment note containing:
    • Shipment ID: A unique identification number for the delivery note (the system will assign or validate this).
    • Sender details: Name, address, and tax ID of the consignor (who is sending the goods). [sapeinvoice.com], [sapeinvoice.com]
    • Receiver details: Name, address, and tax ID of the consignee (who is supposed to receive the goods). [sapeinvoice.com], [sapeinvoice.com]
    • Goods description: Itemized list or description of the goods in transit, including product codes (if applicable), names, quantities, and units of measure. [sapeinvoice.com]
    • Transport details: Information about the transport – e.g. vehicle or transport means, carrier name and ID, route, departure time/date. The note will include the date of dispatch, and may include the expected delivery date. [sapeinvoice.com], [sapeinvoice.com]
    • Unique consignment code: The system may generate a unique code or number (akin to a QR or reference) that represents that delivery note, which inspectors can use to look it up. [sapeinvoice.com]
    • Timestamps: The time of issuance and subsequent events (like delivery receipt) are recorded. [sapeinvoice.com]
    • Digital signatures or authentication: Likely the note needs to be signed by the issuer’s digital certificate, similar to e-invoices, to ensure authenticity (the law mirrors many provisions of the e-invoice law). [vatcalc.com]
  • Format: The delivery note must be submitted in XML format conforming to UBL 2.1 (same standard as e-invoices). The government provides schemas and a standardized format for the e-Delivery document. By using UBL 2.1, the system aligns with international standards for electronic transport documents, ensuring compatibility and easy processing. [sapeinvoice.com], [sapeinvoice.com]
  • Central Platform: The Ministry of Finance will host a centralized e-Delivery Note platform, analogous to SEF. In fact, the e-otpremnica system is integrated with the existing e-faktura infrastructure – accessible via the same eID portal and with a similar web interface/API for submissions. (A public demo environment was made available for companies to test the process in advance.) This centralized clearinghouse approach means every delivery note is logged with the authorities. [vatupdate.com] [sapeinvoice.com], [sapeinvoice.com] [sapeinvoice.com]
  • Validation and Availability: Once submitted, the platform validates the e-note (checks required fields, format). The delivery note then becomes available to the recipient and to inspectors in real-time. Transport inspectors or tax officials can verify a shipment by referencing the e-note in the system (e.g., via a QR code or ID provided to them). The transporter is required to present proof of the electronic delivery note during any inspection – typically this could be done by showing a printed document with the note’s reference or a digital confirmation. [edicomgroup.com], [vatupdate.com]
  • Receipt and Acknowledgment: The law stipulates that the receiver of the goods must confirm receipt of the shipment through the system. Specifically, upon delivery of the goods:
    • The recipient should issue an “electronic receipt confirmation” (electronic prijemnica) in the system on the same day of receipt or within 2 business days after receiving the goods. This confirmation notes that the goods have been physically received (or notes discrepancies). [edicomgroup.com]
    • The recipient then has up to 8 days from receipt to formally accept or reject the delivery by updating the status in the system (issuing an acceptance or rejection message). For example, if the goods delivered do not match the order, the buyer can electronically reject the delivery note, which flags the issue for authorities and the supplier. [edicomgroup.com]
    • If the buyer does nothing, presumably the delivery is considered accepted after that time window. This mechanism is similar to invoice acceptance but applied to delivery documentation, ensuring both parties acknowledge the transaction.
  • Archiving: Electronic delivery notes and confirmations must be stored and archived similarly to e-invoices. The platform will store them, and businesses likely need to retain them for a set period (expected 5 or 10 years, aligned with tax record requirements). The law states the platform will handle storage of e-delivery notes and e-receipts and provide a secure audit trail. [ctlegal.rs], [ctlegal.rs]
  • Integration with VAT records: The e-delivery note itself is not a fiscal invoice, but the amended e-invoicing rules allow linking delivery notes to e-invoices. For instance, a delivery note number can be referenced on an e-invoice. The 2024 rule updates mention “adding delivery notes” in the e-invoicing context, indicating that the systems will be interconnected (likely to ensure that for every invoice of goods, a matching delivery note can be tracked, and vice versa for goods movement leading to an invoice). [vatcalc.com]
• Exceptions: Not all movements of goods require an electronic delivery note. The law and its bylaws carve out exceptions for certain types of goods or scenarios: [edicomgroup.com], [vatupdate.com]
  • Goods transported via utility networks (e.g. electricity, gas, water pipelines) are exempt, since their “movement” is continuous and metered differently. [edicomgroup.com]
  • Retail goods under specific regimes: If goods are moving under the retail distribution where other tax controls apply (perhaps consignment to stores with fiscal receipt systems), they may not require an e-note – one source mentions “retail goods subject to specific tax regulations” as exceptions. This likely covers situations like small courier deliveries to consumers or movements within a single legal entity’s locations. [vatupdate.com]
  • Military or sensitive goods: Goods important for national security, or those moving under special international agreements (e.g. diplomatic shipments), can be exempt from the e-note requirement. These are cases where documenting movements publicly might be inappropriate or already handled by other protocols. [edicomgroup.com]
  • Immediate return of goods with the same transport: (From local sources) If goods are delivered and immediately some or all are returned with the same vehicle (undelivered), there may be a simplified handling in the system via an electronic rejection (this detail comes from draft discussions).
  • Cross-border transit: Although not explicitly stated above, typically international exports/imports have their own customs documentation (CMR, etc.). The e-Delivery law targets domestic movements. If goods are under a customs transit procedure or being exported, they might not require an e-otpremnica (because customs docs serve that purpose). The mention of international agreements in exceptions covers this scenario. [edicomgroup.com]
• Penalties for Non-Compliance (E-Transport): Compliance with the e-Delivery note system is enforced by the Ministry of Finance and other inspectorates. Violations can result in penalties:
  • According to summaries of the new law, failure to comply with the e-delivery mandate can incur fines ranging from approximately €430 up to €17,100. (In Serbian dinars, this is roughly RSD 50,000 to RSD 2,000,000, aligning with the e-invoicing penalties.) The lower end might apply to minor offenses or small taxpayers, and the upper end to larger entities or severe breaches. [sapeinvoice.com], [sapeinvoice.com]
  • For example, not issuing an e-delivery note when required, or not presenting one during transport, would be an offense. Similarly, providing false data or failing to register in the system would draw penalties.
  • Additionally, non-compliance risks other consequences: shipments without proper e-documentation can be delayed or stopped by inspectors, and in serious repeat cases businesses might face audits or even loss of licenses/permits (particularly for excise goods traders). Essentially, ignoring the e-transport rules isn’t feasible without business disruption. [vatupdate.com]
  • The exact penalty amounts and provisions are defined in the law and upcoming bylaws. They typically differentiate fines for companies, responsible persons, and entrepreneurs, similar to the e-invoice law. Early reports indicate the ranges above, ensuring consistency with other fiscal penalties.
  • Enforcement timeline: Though the law is effective, enforcement of penalties will coincide with the mandate start dates (2026 for the first phase). The authorities are likely to show some leniency in initial weeks if technical issues arise, but the legal mechanism to fine non-compliance will be in place from day one of the mandate. The Ministry of Finance and other relevant agencies (e.g. Customs or Market Inspectorate for goods transport) will oversee compliance. [ctlegal.rs]
• Relevant Regulations and Resources:
  • Law on Electronic Invoicing: Official Gazette RS No. 44/2021 and 129/2021 (with amendments in 2023/2024) – this is the primary law that governs e-invoicing and e-reporting requirements. [cleartax.com], [complyance.io]
  • Law on Electronic Delivery Notes: Official Gazette RS No. 94/2024 – this law (adopted Nov 27, 2024) establishes the e-Transport (e-otpremnica) system and its obligations. [ctlegal.rs], [sovos.com]
  • Bylaws and Technical Rulebooks: The Ministry of Finance issues rulebooks for technical implementation. For instance, a Rulebook on Electronic Delivery Notes (published in 2025) details the XML schema and usage rules. Similarly, rulebooks under the e-invoice law (updated in 2023 and 2024) define invoice content and VAT record procedures. [vatcalc.com]
  • Official Portal: The Serbian government’s eFaktura portal (efaktura.gov.rs) is the official platform for e-invoicing (and will integrate e-Delivery). It provides documentation, API guides, and user instructions. The National eID system (eid.gov.rs) is used for access. The Ministry of Finance’s website also has a dedicated section for electronic invoicing and delivery notes with announcements and manuals. [cleartax.com] [kpmg.com]
  • Government Announcements: For example, on October 9, 2024 the Ministry of Finance’s e-invoicing webpage announced the starting date for input VAT recording. Keeping an eye on such official news and the Official Gazette for new regulations is crucial, as Serbia continues to refine these systems. [kpmg.com]
  • Newsletters and Guides: Tax consulting firms (KPMG, PwC, Deloitte), solution providers (Comarch, Sovos, Fonoa, etc.), and local law firms have published detailed alerts on Serbia’s e-invoicing and e-transport mandates. These can be useful for interpretation and practical guidance. (Sources used here include updates from late 2024 and 2025 covering the latest deadlines and rules.) For instance, the Comarch and PwC Serbia bulletins from Jan 2025 summarize the amended law’s key points including the new 12-day deadline and penalty ranges. The Sovos and Edicom releases from Jan–Jul 2025 outline the e-Transport law’s requirements and timeline. [comarch.com], [sapeinvoice.com] [comarch.com], [comarch.com] [sovos.com], [edicomgroup.com]

• E-Invoicing: Fully implemented (since 2023) for all B2B and B2G invoices, via a centralized clearance platform (SEF). Uses UBL 2.1 XML. All VAT-registered domestic and foreign businesses (with Serbian VAT registration) must comply. Non-compliance can trigger fines up to ~€17k. This has removed paper invoicing from the B2B/B2G sphere. [cleartax.com], [cleartax.com]
• E-Reporting: Integrated in real-time with e-invoicing and fiscal systems. Ensures every transaction’s VAT is reported. New rules in 2024–25 require electronic VAT ledgers and timely reporting of all output/input VAT (generally by the 10th–12th of next month). This covers B2C sales (in aggregate) in addition to invoices. It lays groundwork for automated VAT return preparation. Penalties up to ~RSD 2 million ensure compliance, though corrections are allowed without penalty if timely. [vatcalc.com], [comarch.com] [comarch.com], [pwc.rs]
• E-Transport: Planned rollout starting 2026, mandating electronic delivery notes for goods in transit. Initially applies to public sector-related shipments and all excise goods, then all B2B shipments by 2027. The e-notes must be issued in UBL 2.1 XML via the central system before goods move, and receivers must confirm delivery electronically. This enhances supply-chain transparency and tax control (especially for high-risk goods). Fines for non-compliance parallel those for e-invoicing (up to ~€17k). [edicomgroup.com], [sapeinvoice.com] [edicomgroup.com] [sapeinvoice.com]

• Law on Electronic Invoicing, Official Gaz. RS 44/2021 and 129/2021 (phased mandates in 2022–2023); Ministry of Finance – eFaktura portal guidelines. [cleartax.com], [cleartax.com]
• Complyance.io – Serbia E-Invoicing & E-Reporting Overview (real-time invoice and receipt reporting since 2022; mandatory UBL format; law amendments in 2025). [complyance.io], [complyance.io]
• ClearTax & Comarch – Serbia E-Invoicing Timeline and Requirements (UBL 2.1, clearance model, who must comply, penalties up to RSD 2 million). [cleartax.com], [cleartax.com], [cleartax.com], [comarch.com]
• Fonoa – Key Amendments Dec 2024 (new VAT recording rules effective 2025, penalties for failing to issue e-invoices or update status: RSD 200k–2M). [fonoa.com], [fonoa.com]
• PwC Serbia Tax Alert Dec 2024 – Amendments to Law on E-Invoicing (electronic input VAT record from Oct 2024, deadline extended to 12 days, preliminary return from 2026, no violation if errors corrected pre-audit). [pwc.rs], [pwc.rs]
• KPMG Serbia – Tax News Oct 2024 (official postponement notice: electronic input VAT recording started with October 2024 period, not required for Sept 2024). [kpmg.com], [kpmg.com]
• VATupdate & Vatcalc (Richard Asquith) – updates 2024/2025 (VAT recording deadline 10 days in 2024, plans for pre-filled returns, changes to penalty regime, delay of some requirements to 2026). [vatcalc.com] [vatcalc.com], [vatcalc.com]
• Law on Electronic Delivery Notes (e-Transport), Official Gaz. RS 94/2024 (phased obligations 2026/2027); Edicom & Sovos – Serbia E-Delivery Notes Law (mandatory e-note for goods transport, timeline, central platform, exceptions). [ctlegal.rs], [ctlegal.rs] [edicomgroup.com], [edicomgroup.com], [sovos.com]
• Melasoft (Sapeinvoice) – Serbia e-Delivery 2026 Overview (technical details of e-Transport system, UBL 2.1 format, registration via eID, process steps, penalty range €430–€17k). [sapeinvoice.com], [sapeinvoice.com]
• VATupdate/Melasoft – note on Excise goods e-Delivery from 2026 (covers fuel, alcohol, etc., requiring real-time e-delivery reporting; non-compliance risks fines, audits, license loss). [vatupdate.com]
• CT Legal (Dec 2024) – summary of the adopted e-Otpremnica law (rationale, centralized system for e-notes and e-confirmations, phased application dates). [ctlegal.rs], [ctlegal.rs]