The amendments to the Law on Electronic Delivery Notes and the Law on Electronic Invoicing were published in the “Official Gazette of the Republic of Serbia”, No. 80/2026. The amendments further regulate the electronic recording of certain types of transactions, the handling of electronic delivery notes, and the integration of the electronic invoicing system with customs declaration data.
Electronic Delivery Notes
The amendments to the Law on Electronic Delivery Notes clarify that the scope of application of the law does not include, among other things, the movement of a small quantity of goods purchased at a retail outlet which constitute representation expenses, as well as the movement of goods consisting of value vouchers, excise stamps, money constituting legal tender, newspapers, magazines and similar goods. The criteria for determining what constitutes a “small quantity” will be further prescribed by the minister responsible for finance.
A particularly relevant amendment concerns carriers that do not meet the requirements for accessing the electronic delivery note system. Such a carrier may present the electronic delivery note by displaying a QR code generated in the electronic delivery note system. In that case, the sender is required to attach an external representation of the electronic delivery note through the system no later than before the movement of the goods begins.
A new misdemeanour provision has also been introduced for failure to comply with this obligation.
An important transitional rule provides that, from the entry into force of the amendments until 1 January 2027, any errors in the presentation of data in submitted electronic delivery notes and electronic receipt notes will not be taken into account in inspections of compliance with the law.
Electronic Invoicing
The amendments to the Law on Electronic Invoicing provide more detailed rules on the electronic recording of purchases of agricultural and forestry products and agricultural services from farmers who are not VAT payers.
This obligation applies to VAT payers who receive such supplies in the Republic of Serbia. The recording is performed cumulatively for the relevant tax period after the end of that period, and no later than the 12th day of the calendar month following the tax period to which the recording relates. The recording may subsequently be corrected, while the minister responsible for finance will further regulate the manner and procedure for recording and correcting such data.
Another important change is the introduction of the possibility for users of the electronic invoicing system to access, within the system itself, data on imports or entry of goods released for free circulation, as well as exports or dispatch of goods, through lists of customs declarations. The data will be generated on the basis of information from the customs information system and related customs documentation.
When will the amendments apply:
The Law on Amendments to the Law on Electronic Delivery Notes will enter into force on the eighth day following its publication in the “Official Gazette”, while the relevant implementing regulation is to be adopted within 30 days of the law entering into force.
The Law on Amendments to the Law on Electronic Invoicing will also enter into force on the eighth day following publication, but will generally apply from 1 January 2027. An exception is made for the provisions concerning the electronic recording of purchases from farmers and the list of customs declarations for exports or dispatches of goods, which will apply from 1 July 2027.
Businesses carrying out transactions covered by these systems are advised to timely adjust their internal procedures and information systems to the new requirements, particularly with regard to electronic delivery notes, procedures to be followed before the commencement of transportation, and the electronic recording of purchases from farmers.
For additional information or consultations, the Tasić & Partners team is at your disposal.