Although the Electronic Delivery Note System (“SEO”) is of great importance for controlling the flow of goods, ensuring transparency in business operations, and enabling faster and safer exchange of documents, the implementation of SEO has raised numerous practical questions and issues that deserve attention, particularly as they concern the normal functioning of the system.
Complicated initial registration process – Access to SEO depends on the consistency of data across several registers, including the Serbian Business Registers Agency, the Tax Administration, the Treasury Administration and the eID portal. Even the smallest discrepancy often blocks registration and requires subsequent communication with the relevant registers in order to verify the data.
It seems that the introduction of an automatic preliminary data check, prior to registration itself, with a clear indication of the register in which the inconsistency exists, as well as the automatic generation of instructions for resolving the issue, could represent a possible solution that would improve the efficiency and speed of the system.
Unclear logic of authorisations – A large number of users do not distinguish between administrator rights in the SEF administrator module and authorisations for using SEO itself. This creates confusion and slows down the operational onboarding of employees.
The existence of a single centralised administrator panel for managing authorisations across both systems, with a clear parallel overview of active rights and warnings regarding missing authorisations, could bridge the existing issue of differentiation between the systems.
Excessive dependence on the statutory representative – If authorisations remain linked to only one person, any change or absence of that person may practically paralyse the work of the entire company.
A possible solution to potential blockages that may arise in the event of termination of the office of the statutory representative who holds all authorisations would be the mandatory registration of at least two administrators during the initial system setup, with clearly defined authorisations for both persons, as well as a clearly determined procedure for the urgent transfer of authorisations to a third person.
Incomplete integration with the Electronic Invoicing System – Although automatic data synchronisation with SEF is reasonably expected, it currently exists only for a limited number of entities. For all others, this means additional administrative steps.
Full synchronisation of data between SEO and SEF, as is the case with public sector entities, through a single user profile and automatic retrieval of all relevant business parameters, would eliminate the need for additional steps in updating two separate systems.
Rigid organisation of document display – At present, it is not possible to filter documents by branches or facilities, which represents a serious issue for companies with an extensive network of locations.
In this regard, if there were a clear overview of a company’s branches and facilities in the form of separate “sub-profiles” forming an integral part of the company’s “main profile”, it would be possible to access document filtering in a clear and simple manner.
The transition to an electronic platform for invoices and delivery notes is certainly a positive development for companies. However, digitalisation must not result in additional technical dependence for users. A system used by the business sector on a daily basis must be intuitive, predictable and operationally sustainable without the need for constant IT intervention.
For additional information or consultations, the Tasić & Partners team is at your disposal.