Serbia Postpones Preliminary VAT Return Requirement to January 2027

Timeline & Legal Amendments

On 3 December 2025, the Serbian Parliament passed amendments to the VAT Law. The amendments were published in the Official Gazette on 4 December 2025 and took effect on 12 December 2025, with most provisions applying from 1 April 2026. [vatcalc.com], [kpmg.com]
As part of this reform, the pre-filled (preliminary) VAT return requirement was delayed by one year. It will now apply for:
- The January 2027 tax period for monthly filers
- The January–March 2027 period for quarterly filers [vatcalc.com], [kpmg.com]

What Is a Preliminary VAT Return?

A preliminary or pre-filled VAT return means that the tax authority populates your VAT return with data—typically from the SEF e-invoicing system—and the taxpayer reviews, confirms, or corrects it before final submission. Serbia had planned to abolish the old POPDV form and replace it with this new process. [sovos.com], [fiscal-req…ements.com]

Reasons for the Delay

The extra year allows businesses and system owners more time to:
- Adapt and test IT infrastructure
- Manage data integration between VAT reporting and SEF e-invoicing
- Familiarize users and internal processes with the new VAT procedures [vatcalc.com], [kpmg.com]

⚙️ Other Key VAT Law Changes (From 2027 Onward)

Error correction flexibility: Starting 1 January 2027, errors from prior periods (under-declared output VAT or over-claimed input VAT) may be corrected directly in the current return, avoiding the need for amended filings. [vatcalc.com], [kpmg.com], [assets.kpmg.com]
Broader VAT debtor definition: The amendments include:
- VAT incorrectly stated on internal invoices
- Investment gold transactions between VAT-registered parties—where the recipient becomes the debtor. [vatcalc.com], [kpmg.com], [assets.kpmg.com]
Mandatory SEF invoicing: Internal invoices, including self-billing and advance payments, must now be prepared in the SEF electronic invoicing system for users of the system. [vatcalc.com], [kpmg.com]

Serbia Delays Introduction of Preliminary Pre-filled VAT Returns

Serbia’s Ministry of Finance approved amendments to the Law on Electronic Invoicing on December 3, 2025, primarily concerning the introduction of new preliminary pre-filled VAT returns.
The implementation of these pre-filled VAT returns, originally set for January 2026, has been delayed by the latest law until January 2027.
These returns, generated automatically by the tax authority from the Electronic Invoicing System (SEF), aim to simplify the filing process by eliminating the POPDV form, becoming a mandatory annex to regular VAT returns, and potentially serving as the final return if a taxpayer fails to submit their own.

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